From: Josie Cuda [mailto:jcuda@rchawv.org]
Sent: Monday, September 20, 2004 6:07 PM
To: Comments
Subject: CRA - RIN 3064-AC50
I am writing
to voice my opposition to raising the threshold requirements for
smaller
banks relieving many of them from the CRA requirements.
I am the co-chair of a national group of non-profits across the country.
Most of these work in the field of affordable housing – multifamily,
single family and preservation. It is abundantly clear that this
will have a serious impact on rural areas. In rural America, most
all the banks are much smaller than the proposed threshold. Our members
are reporting that they have already heard from local banks with
the news that the bank will no longer capitalize their home repair
loan funds as in the past. Rural America’s greatest need when
it comes to housing or economic development, is access to capital.
The CRA incentive is needed to capitalize worthy projects in Rural
America. Rural non-profits face a particularly difficult task in
raising money to capitalize any project. We are told we are too small,
too far for a foundation program officer to visit and many of us
are living in areas where there are no large corporations or large
banks who will invest in community development. The smaller banks
are all we have and many will not help if they don’t get something
in return – like CRA credit. CRA is an essential tool of non-profit
community developers in rural America. Please do not raise the threshold
to excuse many small banks of CRA requirements. Thank you for your
consideration.
