From: tclarsen@fastmail.fm [mailto:tclarsen@fastmail.fm]
Sent: Friday, September 17, 2004 4:45 PM
To: Comments
Subject: Community Reinvestment 12 CFR Part 345
I oppose the FDIC's proposal to allow banks with assets above $250
million to be examined as small banks under the Community Reinvestment
Act. This policy would reduce lending, investments and services in
low-income communities. The full CRA exam is necessary to incentivize
large banks to continue to support initiatives in the communities
in
which they do business through lending, investments,
and services. There is still such a long way to go to make sure low
income communities have fair, equal access to lending and investment
resources within their communities. Due to their size and influence,
banks with assets above $250 million are leaders in the industry,
setting standards for lending and investment practices and leading
the
way in developing innovative ways to meet the needs of low-income
residents and achieving an appropriate risk-adjusted return. The
Community Reinvestment Act is a catalyst and ongoing mechanism for
ensuring that this activity continues and increases over time. To
drastically pull back the CRA exam for banks above $250 million would
seriously compromise our country's progress in lending and investment
activity in low-income communities.
Please do not approve the Federal Deposit Insurance Corporation's
proposal to allow all banks with assets under $1 billion to have
the
limited CRA exam.
