From:
Alexander Roberts
Sent: Friday, September 17, 2004 10:27 AM
To: Comments
Subject: SPAM::Community Reinvestment -- RIN 3064-AC50
As the Executive
Director of a nonprofit agency that provides millions of dollars
in down payment assistance to first time homebuyers pursuant to contracts
with the New York State Housing Trust Fund and Affordable Housing Corporation, I oppose the FDIC's proposal to allow banks with assets
above
$250 million to be examined as small banks under the Community Reinvestment Act.
This policy would reduce lending, investments and services in low-income
communities. The CRA should be strengthened, not weakened at this
critical time when low income communities are beset with sub-prime lenders.
Legitimate banks must play a larger role in the revitalization of low-income
communities because any rule changes that would have the effect of
reducing options to low -income families only increase the likelihood they will be forced to turn to sub-prime lenders.
Alexander H. Roberts, Community Housing Innovations, Inc.
