From: Banjoker@aol.com [mailto:Banjoker@aol.com]
Sent: Thursday, September 16, 2004 8:51 PM
To: Comments
Subject: Proposed Change in Threshhold Requirements for CRA Lending
Although small local banks may have their own set of issues, they
are generally easier to work with in delivering CRa products to first-time
homebuyers. Any reduction in their level of obligation will make
it more necessary to work with the larger institutions.
In our experience, the larger the bank, the more difficult it is
to shape a response to local needs. Large banks have developed national
strategies to respond to their CRA obligations. They are “siloed” institutions,
meaning that CRA responsibilities and personnel work independent
of mortgage or other lending personnel. Mortgage personnel understand
the local market and are anxious to work with NWOs on special mortgage
products; but they do not have the power to design CRA programs for
the bank. CRA personnel are often limited by national policy in how
funds are to be expended. The special mortgage loan products designed
at the national level (if any) may or may not respond to local needs.
Edward F. Moncrief
Executive Director
Neighborhood Housing Services Silicon Valley
1156 North Fourth Street
San Jose, CA
