Federal Deposit
Insurance Corporation

From: SAdams7943@aol.com [mailto:SAdams7943@aol.com]
Sent: Tuesday, December 13, 2005 5:45 PM
To: Comments
Cc: jsilver@ncrc.org
Subject: Re: RIN 3064-AC95

Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, D.C. 20429

Re: RIN 3064-AC95

Dear Mr. Feldman:

I urge you to drop your proposal to preempt certain state laws in connection with the lending and deposit activities of state-chartered banks. Your proposal would strip states of their power to enforce and enact meaningful consumer protections for its citizens.

The implications of your request are profound. Your proposal would allow FDIC-chartered banks to skirt strong consumer protection laws in North Carolina in which they make loans and follow weaker laws of the state in which they are headquartered. If the FDIC enacts this proposal, state-chartered banks will be tempted to place their headquarters in states with weak laws and then “export” these laws to North Carolina and other states in which they make loans. The end result would be a regulatory race to the bottom and the stripping away of states rights, leaving consumers without strong protections against predatory lenders.

A recent Federal Reserve study of the new 2004 HMDA data confirmed two National Community Reinvestment Coalition (NCRC) reports, which found that minorities continue to pay more for loans as they are more likely to receive high cost loans than whites. With these possibilities of price discrimination and steering, the new HMDA data suggests that predatory lending is a widespread problem and that states must have the authority to clamp down on predatory practices.

In addition, in the last year federal regulators have been chipping away at important consumer protections. Now is not the time to weaken laws for state-chartered banks.

Ultimately, this proposal will further undermine the gains American communities and consumers have made in community development and wealth building.

I strongly urge you to drop your proposal and to remind state-chartered banks that they have a moral and civic responsibility to respect the will and the rights of the states to protect its citizens. Thank you for your consideration of my comments.

Sincerely,

Stella J. Adams
NC Fair Housing Center