Utica/Central
New York Citizens in Action
From: Cnycitizenaction@aol.com
[mailto:Cnycitizenaction@aol.com]
Sent: Friday, September 17, 2004 1:15 PM
To: comments@FDIC.gov.
Subject: RIN 3064-AC50
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
RE: RIN 3064-AC50
Dear Mr. Feldman:
I am the President of the Utica/Central New York Citizens in Action.
We are writing to voice our opposition to watering down CRA (Community
Reinvestment Act) requirements for mid-sized banks. CRA has been
a successful tool 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.
The City of Utica is located in Upstate NY between Albany and Syracuse.
We have lost one-third of our population since 1970 and have rates
of poverty. Much of our housing stock has been demolished. However,
we have significant opportunities at this time to transform our community
into a model for sustainable urban redevelopment. The CRA is essential
to our community redevelopment efforts.
The Utica Citizens in Action is a multi-issue advocacy organization
concerned with neighborhood redevelopment, predatory lending, affordable
housing, and community-based economic development. We have over 500
members.
Located In Utica, New York, our community-based and multicultural
organization is committed to living wage jobs, affordable health
care and education, educational opportunities, and improvement in
living conditions for low and moderate income people. We are a membership
organization which consists of working people, tenants, small business
persons, the elderly, students, clergy, and representatives of the
labor movement. Our organization is a community-labor-faith-based
coalition dedicated to revitalizing Utica's distressed neighborhoods.
We also advocate for low-income and marginalized neighborhoods in
the Central New York region. Our group is affiliated with Citizen
Action of New York, a large multi-issue membership organization consisting
of over 20,000 members.
Established in 1997, our organization has been successful in highlighting
public attention on local economic development issues, health maintenance
organization reform, affordable housing, and consumer rights. We
have successfully conducted campaigns on neighborhood development,
media accountability, and health care and joined state and national
organizations in advocating for progressive policies.
We are respectfully requesting that you withdraw your proposal to
gut the CRA. Thank you for considering our comments.
Sincerely,
John Furman
President
Utica Citizens in Action
P.O. Box 411
Utica, New York
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