From: Joshua Van tol [mailto:josh@spiny.com]
Sent: Thursday, September 16, 2004 9:17 PM
To: Comments
Subject:
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St., NW
Washington, DC 20429
September 16, 2004
RE: RIN 3064-AC50
Dear Mr. Feldman:
As a concerned citizen, I am requesting that the FDIC withdraw its
proposal to change the Community Reinvestment Act regulations for
mid-sized banks. The FDIC proposal will especially harm the more
rural parts of the United States, where there are already fewer banks
that are covered by the "large bank" regulations of CRA.
The difference
between how "small" banks and "large" banks
are
currently reviewed for CRA purposes is that the large banks have
a
service test and investment test in addition to a lending test. The
investment test is an important tool for increasing the amount of
affordable housing and community development investments in our
communities because the banks that are subject to the large bank
test
feel more need to work harder to support affordable housing and make
the kinds of investments that help low and moderate income people.
The proposal by the FDIC to allow banks between $250 million and
$1
billion in assets to pick and choose which types of activities they
do
to meet a new community development test will prove to provide little
value to the intended beneficiaries of the Community Reinvestment
Act,
the low and moderate income people of our communities. In rural areas
this is particularly true because the FDIC's proposes that "'community
development' activity could benefit either low- and moderate-income
individuals or individuals who reside in rural areas." Creating
such a
broad definition of community development, which could easily be
interpreted to mean that loaning money to a Wal-Mart store opened
in a
rural area is "community development," will make the Community
Reinvestment Act virtually meaningless in rural communities.
I urge the FDIC to listen to the voices of National Community
Reinvestment Coalition members and withdraw this proposal and then
begin to more rigorously enforce the Community Reinvestment Act in
rural areas. Too many of the mid-sized banks, which are so important
for our rural economy, are getting by with doing very little community
development service and investment in our communities. We need you
to
do a better job enforcing the Community Reinvestment Act.
Sincerely,
Joshua van Tol
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