Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
I am a concerned citizen opposed to watering down CRA (Community
Reinvestment Act)
requirements for mid-sized banks. CRA is vital for increasing homeownership
and economic
development in lower-income communities. However, your proposed changes
will halt the
progress that has been made.
I understand that banks with over $250 million in assets must be
tested on their number of loans,
investments, and services to low- and moderate-income communities.
But your proposal would
eliminate the investment and service requirements for all banks with
under $1 billion in assets.
This will result in significantly fewer loans and investments in
affordable rental housing, health
clinics, community centers, and economic development projects.
In the watered-down exam, you would allow mid-sized banks to choose
which community
development activities they will undertake. Right now, these banks
must make community
development loans, investments, and services. Your proposed test
allows banks to choose only
one of the three activities. The result will be less community development
activity.
You also propose that community development activities in rural
areas should benefit any group
of individuals instead of only low- and moderate-income individuals.
But this will allow banks to
cherry-pick and focus on affluent residents of rural areas rather
than the lower income consumers
CRA targets.
Finally, you would also eliminate publicly available data on the
small business
lending of mid-sized banks. Without data, community groups and citizens
cannot hold banks
accountable for lending to small businesses in their neighborhoods.
Your changes
directly oppose CRA’s mandate to require lenders
to meet community needs. CRA
is too important to be gutted. Please drop your proposal like the
two other federal agencies that
recognized its harm to underserved communities.
Sincerely,
Roseann Mary Koskie
111 East Deming Street
Roswell, NM 88203
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