From: Blair W. Sebastian
[mailto:blair@ruralhousing.org]
Sent: Thursday, September 16, 2004 4:39 PM
To: Comments
Subject: RIN 3064-AC50, Community Reinvestment
The New York State Rural Housing Coalition is strongly opposed to
your proposal to alter the definition of a small bank for purposes of
the Community Reinvestment Act.
We believe that there are a significant number of institutions in New
York State that would be impacted by this change and we believe that the
action would be a serious set back for efforts to provide capital in the
form of bank loans and investments to low and moderate income
communities all across our state.
Our organization represents a network of over one hundred community
based, not-for-profits serving rural areas in New York. These
organizations find that many of the banks that are most active in rural
areas are those with assets between $250 million and $1 billion. We find
that these banks make significant investments in low and moderate-income
communities and that they do so primarily because of the Community
Reinvestment Act.
We are convinced that if these institutions are held to a lesser CRA
standard, the result will be a serious and very damaging reduction in
loans, investments and branches in rural areas. We urge you to withdraw
this proposal.
Blair W. Sebastian
Executive Director
New York State Rural Housing Coalition
879 Madison Ave
Albany, NY 12208
(518) 458-8696
