From: npm8@columbia.edu [mailto:npm8@columbia.edu]
Sent: Thursday, September 16, 2004 1:00 PM
To: Comments
Cc: nmelton@ncrc.org
Subject: RIN 3064-AC50
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429
Dear Mr. Feldman:
I am a concerned citizen opposed to watering down CRA (Community
Reinvestment Act) requirements for mid-sized banks. CRA is vital
for
increasing homeownership and economic development in lower-income
communities. However, your proposed changes will halt the progress
that
has been made.
I understand that banks with over $250 million in assets must be
tested on
their number of loans, investments, and services to low- and
moderate-income communities. But your proposal would eliminate the
investment and service requirements for all banks with under $1 billion
in
assets. This will result in significantly fewer loans and investments
in
affordable rental housing, health clinics, community centers, and
economic
development projects.
In the watered-down exam, you would allow mid-sized banks to choose
which
community development activities they will undertake. Right now,
these
banks must make community development loans, investments, and services.
Your proposed test allows banks to choose only one of the three
activities. The result will be less community development activity.
You also propose that community development activities in rural
areas
should benefit any group of individuals instead of only low- and
moderate-income individuals. But this will allow banks to cherry-pick
and
focus on affluent residents of rural areas rather than the lower
income
consumers CRA targets. Finally, you would also eliminate publicly
available data on the small business lending of mid-sized banks.
Without
data, community groups and citizens cannot hold banks accountable
for
lending to small businesses in their neighborhoods.
Your changes directly oppose CRA's mandate to require lenders to
meet
community needs. CRA is too important to be gutted. Please drop your
proposal like the two other federal agencies that recognized its
harm to
underserved communities.
****************************************************************
Nicole P. Marwell
Assistant Professor
Department of Sociology and Latino/a Studies Program
Columbia University
323M Fayerweather Hall, MC 2551
1180 Amsterdam Avenue, NY, NY
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