From: John Waite [mailto:johnw@fccdc.org]
Sent: Thursday, September 16, 2004 4:37 PM
To: Comments
Subject: RIN 3064-AC50
Please see attached letter, which is also printed below, in
opposition to the changes in CRA.
Franklin County Community Development Corporation
September 15, 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429
RE: Community Reinvestment - RIN 3064-AC50
Dear Mr. Feldman:
I urge you to withdraw your proposed changes to the Community
Reinvestment Act (CRA) regulations. CRA has been instrumental in
increasing homeownership, boosting economic development, and expanding
small businesses in the nation’s minority, rural, and low- and
moderate-income communities. Your proposed changes are contrary to the
CRA statute and Congress’ intent because they will reverse the progress
made in community reinvestment.
On behalf of the Franklin County Community Development Corporation (FCCDC),
I want to register opposition to the above proposed rule changes
regarding the asset threshold for banks covered by the Community
Reinvestment Act. We believe that the rule should be left as it
currently stands.
FCCDC is a rural private not for profit corporation that has
developed partnerships with banks on a variety of community and economic
development projects and investments. Most of the banks we work with
fall below the threshold that is proposed under the new rules. I believe
that CRA was pivotal in opening the door and cementing the relationship
between our organization and our partner banks.
Rural, low-income communities typically have the greatest need for
public and private capital. Yet, it is these very communities that also
lack banks large enough to meet the new thresholds proposed by the FDIC
rule changes. The proposed change threatens to stop the kind of public
private investments that are so needed in our poorer rural communities.
In the long term, exempting the rural banks will hurt both the banks and
the community. For these reasons, I want to strongly state our
opposition to the proposed FDIC change.
John Waite
Executive Director
Franklin County Community Development Corporation
324 Wells Street
Greenfield, MA 01301
