From: Jean Lipani [mailto:jlipani@ruralinc.org]
Sent: Friday, September 17, 2004 9:55 AM
To: Comments
Subject: CRA
Dear Mr. Feldman:
Rural Opportunities, Inc (ROI) a not for profit community service
organization is strongly opposed to your proposal to significantly
weaken the Community Reinvestment Act (CRA). You propose much easier CRA
requirements for banks between $500 million to $1 billion in assets.
This new ruling would negatively impact our current relationships with
Lenders that have assets of of less that $1 billion as well as with
establishing new relationships with future Lenders/Banks. The new ruling
provides an incentive to not lend in what is now considered CRA lending
areas or to low to moderate income families. Community Development
Corporations like ROI have worked diligently with Banks or Lenders to
ensure that they offer affordable products to everyone in the community
so that low to moderate income families can afford to live an work in
the communities of their choice. The new FDIC ruling would undo all the
good that has been done. Please withdraw your harmful proposal.
"I am stunned that, after years of progress in opening up the
channels of credit and capital to lower income communities, this
Administration is now proposing to undo it. This is a slap in the face
of citizens all around the country who will, undoubtedly, see less
willingness on the part of the banks to reach out and provide mortgages
for first time homebuyers, small business loans and other services vital
to our communities. This proposal is especially harmful to our rural
areas. How can this Administration be serious about the economic health
of our communities when they so actively and directly try to disrupt the
flow of capital we so desperately need? It is precisely the Community
Reinvestment Act (CRA) that has led banks in Pennsylvania like Altoona
First Savings Bank to form a partnership with Rural Opportunities, Inc.
(ROI) and with USDA Rural Development to provide home mortgages to
first-time homebuyers, or Clearfield Bank and Trust to design new and
exciting first mortgage products, or Farmers and Merchants Trust of
Chambersburg to directly support ROI's counseling and education course
for first-time homebuyers". Lee Beaulac, VP Housing And Economic
Development, Rural Opportunities, Inc.
Sincerely,
Jean Marie Lipani
Director of Homeownership
Rural Opportunities, Inc.
400 East Avenue
Rochester, NY 14607
585-340-3359
585-340-3326 (fax)
