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FDIC Federal Register Citations
October 14, 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance
Corporation
550 17th Street NW Washington, DC 20429
RE: 12 CFR part 345
CRA (69FR51611)
Dear Mr. Feldman:
I oppose the FDIC's proposal to allow banks with assets
above $250 million to be examined as small banks under the Community Reinvestment
Act. This policy change would reduce lending, investments and services
in low-moderate income communities in inner-city neighborhoods like Harlem,
New York City.
The full CRA review of larger banks like Citibank forced
this financial institution to make construction loans and
other investments in Harlem that encouraged local entrepreneurs and developers
to produce
affordable housing for very low, low and moderate income families and existing
residents.
With the full weight of the Community Reinvestment Act, Citibank
provided our company with a $12.5 million construction loan which helped
us perform gut rehabilitation on five city-owned multifamily buildings
to produce 97 affordable housing apartment units.
It is absolutely necessary
that the FDIC and other banking regulatory agencies require larger banks
to comply with the full CRA review to maintain and expand the role that
larger banks play in the local economy, commerce and affordable housing
areas of low-moderate income inner city urban communities. I urge you and
other members of the FDIC to preserve the Community Reinvestment Act to
prevent the roll back of lending, investments and services.
I invite you
and FDIC members to join us on December 7, 2004 for a ribbon cutting ceremony
in Harlem to dedicate the newly rehabilitated affordable housing and see
first hand the accomplishments of CRA working in our community.
Sincerely
Coy M. LaSister
President & CEO
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