From: Rodney Sanchez [mailto:rodneysanchez@hotmail.com]
Sent: Tuesday, April 06, 2004 1:50 PM
To: regs.comments@occ.treas.gov; regs.comments@federalreserve.gov;
regs.comments@fdic.gov; Comments; regs.comments@ots.treas.gov
Subject: CRA Regulations
Rodney Sanchez
2303 E. Belleview Pl. #1
Milwaukee, WI 53211
April 5, 2004
Communications Division
Public Information Room, Mailstop 1-5
Office of the Comptroller of the Currency
250 E St. SW,
Washington 20219
Docket No. R-1181
Jennifer J. Johnson
Secretary, Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington DC 20551
Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th St NW
Washington DC 20429
Regulation Comments, Attention: No. 2004-04
Chief Counsel's Office
Office of Thrift Supervision
1700 G Street NW
Washington DC 20552
Dear Officials of Federal Bank and Thrift Regulatory Agencies:
As a banking customer, and a borrower who is concerned about predatory
lending, I am writing to urge you to change your proposed Community
Reinvestment Act (CRA) regulation before it is finalized. I believe
you need a stronger predatory lending standard and I believe you should
keep the small bank definition as it is at $250 million in assets.
Wisconsin would be hard-hit by the proposed changes in requirements
for small banks. Over 10% of our state’s banks would be exempted
from most CRA regulations if the changes are enacted.
I am also very concerned about the proposed standard regarding predatory
loans. I am very aware of rip-off lenders who do what you call "asset-based
lending" and try to force borrowers into foreclosure so they can
take over their homes. However, there are many other ways that seemingly
good banks take advantage of customers who don't understand the loan
process. I think the regulators should use the CRA exams to penalize
lenders who push high cost loans with high fees and those who get you
into a bad loan and then try to flip you into an even worse loan. I
also oppose prepayment penalties that keep you from getting out of
a bad loan, loans with balloon payments, and single premium credit
insurance policies that cost a lot but don't really help the customer.
Regulators should lower a bank's CRA rating when they include loan “features” like
that.
I hope that instead of exempting the smaller banks from CRA regulations,
you will pay more attention to the smaller banks. They would do more
in lower income communities if the regulators would encourage them
to support community development lending and investments in smaller
communities. I'm asking you not to raise the asset threshold definition
of a small bank.
I am familiar with the National Community Reinvestment Coalition, which
has submitted more detailed comments than mine. I feel confident that
they understand the complexities of CRA better than I do, and I support
their comments.
Thank you very much for paying attention to my concerns.
