Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit
Insurance Corporation
550 17th Street NW
Washington, DC 20429
RE: PIN 3064-AC50
Dear Mr. Feldman:
We at Ho-Chunk Housing and Community Development Agency, affordable
housing provider of the Ho-Chunk Nation, deplore the proposed changes
to the Community Reinvestment Act (CRA), changes that would considerably
lessen the accountability of mid-sized banks in the Ho-Chunk Nation
service area in regard to the banks' providing loans for homeownership
and economic development to the low- and moderate-income communities.
As I am sure you know, Native Americans fall disproportionately into
these income categories, have a much lower historical level of homeownership
than does the population as a whole or indeed than does any other
minority, and benefit greatly from the provisions of C.RA, as they
stand now. Members of the Ho-Chunk Nation are beginning to see the
fruits of activism to increase the number of government and private
loans on trust land and on fee-simple land, and the presence of a
strong CRA is a great bulwark in this effort.
Your proposed changes to CRA are in direct contravention of CRA's
purpose to hold lenders' feet to the fire in regard to the meeting
of community needs. The act is far too important to be undercut.
We respectfully request that you withdraw your
proposal, as did two other federal agencies the Office of Thrifts
Supervision and Office of the Comptroller of the Currency that recognized
the harm that would be inflicted upon underserved communities by
similar changes.
Sincerely,
Myra J. Price, Executive Director
Ho-Chunk Housing and Community
Development Agency
