From: Ray Neirinckx [mailto:rneirinckx@rihousing.com]
Sent: Thursday, September 16, 2004 1:00 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
My name is Ray Neirinckx. I am the coordinator for the Office of
Community Development for the State of Rhode Island Housing Resources
Commission*. I have been involved in CRA work since 1985.
I am opposed to the FDIC rule change to allow banks with assets above
$250 million to be examined as small banks under the Community
Reinvestment Act (CRA). This policy would reduce lending, investments
and services in low-income communities.
Creating strategic alliances with financial institutions is critical
to community asset building. CRA is an important tool to engage lenders
in community economic development work in our neighborhoods. The
proposed rule change could reduce the percentage of banks with full CRA
exams to 6%. We need all banks to partners in our community development
work. We are reaching out to expand the level of investment, lending and
services being offered by our small bank in Rhode Island. The proposed
rule change will be a set-back to expanding engagement by our small
banks in Rhode Island and across the country. We urge the FDIC to
reconfirm the important alliances to community reinvestment by rejecting
the rule change on small banks.
Sincerely,
Ray Neirinckx
RIHRC
41 Eddy Street
Providence, RI 02903
401-450-1356
