The purpose of this letter is to voice the strong opposition of the
Texas Mezzanine Fund, Inc. (TMF) regarding changes that the Federal
Deposit Insurance Corporation (FDIC) is considering that would allow
all banks with assets under one billion dollars to have a limited
Community Reinvestment Act (CRA) exam that focuses on basic lending
activities and not fully evaluate investments and services.
TMF is a statewide community development financial institution that
provides financing for businesses located in distressed areas, women-
or minority-owned businesses, and small businesses that create jobs
for low-and-moderate income people. TMF also provides financing to
for-profit and nonprofit developers of single-and multifamily affordable
housing for families, senior citizens and households with special
needs. The Fund was capitalized by a consortium of financial institutions
in Texas.
Earlier this year, the Federal Reserve Bank of Dallas and TMF co-sponsored
Momentum Texas – The Texas Community Development Finance Summit.
The summit was held in cooperation with FannieMae, the FDIC, the
Federal Home Loan Bank, the Office of Comptroller of the Currency,
and the Office of Thrift Supervision. By undertaking this summit,
TMF has a deep understanding of the community development finance
needs throughout the State of Texas. It would be tragic to adopt
rules that undercut the ability to finance beneficial community development
initiatives in Texas.
If you have questions regarding our opposition, please contact me
at 214.943.5900, extension 101.
