Mr. Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ISS - FDIC
550 17th Street NW
Washington, DC 20429-9990
RE: RIN 3064-AC50
Dear Mr. Feldman,
During the 20 years I have worked in community services, I have
encouraged non-profit organizations to partner with banks to make the
CRA work for both of them. In particular, banks have collaborated with
Habitat for Humanity affiliates in Alabama by providing office space,
making no-interest loans, funding homes, teaching budgeting classes, and
partnering in other innovative ways.
I oppose the proposed changes, which among other things will exempt
banks with assets of between $250 million to $500 million from the
lending and services provisions. I believe that the proposed changes
will only continue to diminish the effectiveness of the CRA in our
communities. Based on the Lending Test, the fifth criteria offers the
community an expectation that the bank will be diligent in working
collaboratively within the community, finding innovative and flexible
lending practices to serve low-moderate income individuals and
businesses. The statement "to reflect economic change and to reduce
unwarranted burden" seems to me an intentional method of excluding
low-moderate families from financial services.
After reviewing the number of banks in Alabama that are currently
held accountable for their adherence to the CRA, and subtracting the
number of banks that the exemptions will affect, I find that only nine
banks in Alabama will be obligated to meet the full requirement of the
CRA! Add to that a new definition for community development- “Activity
(that) could benefit either low- and moderate-income individuals or
individuals who reside in rural areas"- and we have a vague and hollow
Community Reinvestment Act. How will bank’s “reinvestment” appear, if
they are released from the obligation to provide services to
low-moderate income families?
Sincerely,
Lisa Yee, ASM- SE Regional Support Center
Habitat Southeast
4525 Fairlane Court
Montgomery, AL 36106
