From: Quynh Nguyen [mailto:quynh@onlinecpi.org]
Sent: Thursday, September 16, 2004 9:46 PM
To: Comments
Cc: cford@ncrc.org
Subject: RIN 3064-AC50, Community Reinvestment
September 16, 2004
Mr. Robert Feldman
Executive Secretary
Attention: Comment/Legal ESS
Federal Deposit Insurance Corporation
Subject: RIN 3064-AC50
Dear Mr. Feldman,
The Center on Policy Initiatives is strongly opposed to your proposal
to
significantly weaken the Community Reinvestment Act (CRA). You propose
much
easier CRA requirements for banks between $250 million to $1 billion
in
assets. This proposal will result in much fewer home and small business
loans to low- and moderate-income borrowers and much fewer community
development loans and investments in low- and moderate-income communities.
In addition, you propose that all FDIC-supervised banks can earn
CRA points
by financing community development projects that benefit affluent
residents
in rural areas, instead of low- and moderate-income consumers and
communities in rural America. This is directly contrary to CRA’s
focus on
meeting credit needs of low- and moderate-income communities.
Your proposal to change the CRA regulation will result in much fewer
loans,
investments, and branches in low- and moderate-income communities.
Please
withdraw your harmful proposal.
Sincerely,
Quynh Nguyen
Center on Policy Initiatives
3727 Camino del Rio So, Ste 100
San Diego, CA