Concord Area Trust for Community Housing
From: Amy Lockwood [mailto:alockwood@catchhousing.org]
Sent: Friday, September 17, 2004 1:07 PM
To: Comments
Subject: RIN 3064-AC50
September 16, 2004
Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ISS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429-9990.
Re! : RIN 3064-AC50
Gentlemen Re RIN 3064-AC50:
I strongly oppose the proposed rule changing the Community Reinvestment
Act
regulations. In my opinion, it will really undermine rural communities.
Please do not adopt this rule.
The changes proposed would make approximately 1,100 banks across
the United
States subject to less rigorous CRA exams by changing the "small
bank" limit
from $250 million to $1 billion. The proposal would particularly
impact
rural communities, where the number of institutions subject to complete
CRA
exams would decline by an estimated 73%. In New Hampshire the number
of
banks subject to complete CRA exams could drop from 15 to 3. This
would
significantly negatively impact community development work in this
primarily
rural state.
CRA has been one of the most effective tools in encouraging private
sector
investment in community development. Private sector participation
is a key
to successful development in our communities, and we urge the FDIC
to
preserve it.
Respectfully,
Amy L. Lockwood
Executive Director
Concord Area Trust for Community Housing
79 South State Street
Concord, NH
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