SECRETARIAT FOR CATHOLIC HUMAN SERVICES
OFFICE FOR COMMUNITY DEVELOPMENT
ARCHDIOCESE OF PHILADELPHIA
222 North Seventeenth Street
Philadelphia, PA 19103-1299
September 20, 2004
Thomas J. Curry Director
Federal Deposit Insurance Corporation
550 17th Street, NW Washington, DC 20429
Dear Mr. Curry:
I write to you on behalf of the Office for Community Development of
the Archdiocese of Philadelphia, a 501(c)(3) community development
corporation, to express my sincere concerns regarding proposed changes
to Community Reinvestment Act exam thresholds. Setting a lower CRA
standard for institutions with under $1 billion in assets by not
considering their investments and services will weaken the CRA
overall—and negatively impact community development efforts.
The Office for Community Development of the Archdiocese of
Philadelphia has looked to the CRA as a significant part of the
blueprint for establishing partnerships with banking institutions. These
partnerships have been critical to our work in distressed neighborhoods
throughout Philadelphia: transitional housing for homeless families;
community center; vacant housing rehabilitation for low and
moderate-income homeownership; senior housing; et al. The work of
neighborhood revitalization and serving special needs communities
remains quite challenging even with the current CRA standards. Please do
not create new obstacles to this important work.
Please take this opportunity to reinforce the role of banking
institutions in serving our communities by not changing the current CRA
standards. Thank you.
