To: Federal Deposit Insurance Corporation
(FDIC)
Email: comments@fdic.gov
Fax: 202-898-8788
Date: 9/17/04
Re: 8/20/04 Proposed Amendments to CRA Regulations: 12 CFR Part 345
I represent tenants in San Francisco in their various disputes with landlords.
As you probably already know, affordable rental units are very scarce in San
Francisco for low income and middle income tenants. And long-term tenants (say,
with tenancies over five years long) with low or affordable rents due to rent
control are very vulnerable to eviction by speculators who buy their buildings
and evict them in order to obtain empty rental units and cause the market values
of their buildings to increase by $100,000 or more. One of the ways that speculators
try to evict these vulnerable tenants, many of whom are elderly or disabled,
is to allow the buildings to fall into disrepair or slumlike conditions. Good
landlords are sometimes forced to sell their buildings to these speculators because
it is difficult for them to afford to maintain their affordable-rent buildings.
Of course, housing conditions are a vital factor in the health of occupants,
and older, low-income properties in substandard condition typically present the
greatest health risks.
I understand that you have published for public comment on August 20, 2004 a
proposed a new rule, 12 CFR Part 345, that would exempt banks with assets between
$250 million and $1 billion (apparently about 96% of the banks regulated by you)
from many of the requirements of the Community Reinvestment Act (CRA). This change
most likely would have a very adverse impact on affordable housing rehabilitation
and to healthy housing.
Over the last quarter of a century, the CRA has helped leverage billions of dollars
in resources for decent and affordable housing. Your proposed rule will undermine
the ability of advocates for healthy homes to convince banks to address healthy
housing conditions and affordability in low-income communities.
For this reason, I oppose the new rule and urge you not to adopt it.
J. Wallace Oman
Attorney at Law
___________________________________
J. Wallace Oman
Law Offices of J. Wallace Oman
240 Stockton Street, Suite 400
San Francisco, CA
