From: Jay Moolenijzer [mailto:jmoolenijzer@ramahnavajo.net]
Sent: Monday, September 20, 2004 5:08 PM
To: Comments
Subject: RIN 3064-AC50
September 20, 2004
Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ISS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429-9990
REGARDING: RIN 3064-AC50
Gentlemen,
I strongly oppose the proposed rule changing the Community Reinvestment
Act
regulations. Such changes will undermine the efforts of rural communities
to develop “real” economic opportunity and growth. Please,
do not adopt the
proposed rule.
I have been working for small Native American rural communities
for many
years in education, community and economic development. The Community
Reinvestment Act opportunities through our small local banks have
been the
only way these small rural communities have been able to secure leverage
funds for economic development ventures. An example: the Stillaguamish
Tribe of the state of Washington now has a thriving native riparian
restoration nursery serving the entire northwest thanks to the current
rules
under the CRA – we were able to borrow against privately owned
tribal
assets/lands with which to leverage and provide matching funds for
EDA,
USDA, local State and private foundation funding for the project.
This risk
of tribal assets made the very difference in the successful financing
of
this project. In fact, EDA showcases this project on its national
website
as an exemplary economic development program. This is just one example
where the current law nurtures true economic development in rural
America.
Please do not take this valuable tool from us.
Thank you for your considered attention to our request not to adopt
the
proposed rule vis-à-vis RIN 3064-AC50.
Sincerely yours,
Jay Moolenijzer
Community Planning and Development Department
