Housing Association of Delaware Valley

From: Housing Association of Delaware Valley
Sent: Monday, August 23, 2004 9:37 AM
To: Comments
Subject: Housing Association of Delaware Valley Opposes increase in small bank threshold.

The Housing Association of Delaware Valley (HADV) is the nation's oldest housing advocacy agency, founded in 1909. We work with neighborhood groups, community development corporations and housing developers to promote the construction and rehabilitation of affordable housing, and to encourage equal housing opportunities for all citizens. Nonprofit organizations benefit tremendously from CRA-incented participation of lenders in their communities. This participation is critical to reverse the many years of dis-investment, redlining and discrimination that has blighted our cities.

The Community Reinvestment Act is a critical component to our community’s affordable housing and community development solutions. We oppose any increase to the threshold of what is considered to be small bank. The proposed FDIC rule would exempt many of our community’s critical partners from the effective and productive requirements currently in place. We urge FDIC to withdraw its proposed rule.


Marcus Saitschenko
Housing Advocate
Housing Association of Delaware Valley
1528 Walnut Street, ste. 1000
Philadelphia, PA 19102