From: Bethany Porter Sanchez [mailto:clubbethany@hotmail.com]
Sent: Thursday, September 16, 2004 5:58 PM
To: Comments
Subject: RIN 3064-AC50, Community Reinvestment
RE: RIN 3064-AC50, Community Reinvestment
Dear Mr. Feldman:
I am writing as a concerned citizen to express my strong opposition
to the FDIC's proposal to significantly weaken the Community
Reinvestment Act (CRA).
Having worked for nonprofits involved in housing and community
development for over 25 years, and having worked with lenders trying to
meet their CRA requirements, I believe that the FDIC's proposal will
result in significantly fewer home loans and small business loans to low
and moderate income borrowers, and significantly fewer community
development loans and investments in low and moderate income
communities.
The impact of the proposed CRA changes would be huge. Nationally,
this proposed definition would would make 879 state-chartered banks with
over $392 billion in assets eligible for a streamlined and cursory CRA
exam. The impact on FDIC-regulated institutions in Wisconsin would be
that an additional 27 Wisconsin institutions' CRA commitments would be
reduced significantly. While this represents 12.5% of the FDIC-regulated
institutions in the state, their $10.35 billion in assets represent
35.88% of the of Wisconsin's FDIC institutions.
Looking at just the urban areas, an additional 22 urban-based
Wisconsin institutions' CRA commitments would be reduced significantly.
This represents 24.4% of the urban FDIC-regulated institutions in the
state and their $8.9 billion in assets represent 52.5% of the assets of
Wisconsin's FDIC-regulated institutions. Again, these numbers represent
the additional Wisconsin institutions and assets that would have
significantly reduced CRA requirements under this proposal.
In addition, the proposal would allow banks to earn CRA points by
financing community development projects that benefit affluent residents
in rural areas, instead of low and moderate income consumers and
communities in rural America. This is directly contrary to CRA’s focus
on meeting credit needs of low and moderate income communities.
In summary, these proposals will result in significantly fewer loans,
investments, and branches in low and moderate income communities. Please
withdraw this harmful proposal.
Sincerely,
Bethany Sanchez
2303 E. Belleview Place, #1
Milwaukee, WI 53211
