LUMBEE REVITALIZATION & COMMUNITY DEVELOPMENT CORPORATION
September 9, 2004
Mr. Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429
Dear Mr. Feldman:
The members of the Board of Directors and staff of the Lumbee
Revitalization and Community Development Corporation urge you to
withdraw your proposed changes to the Community Reinvestment Act (CRA)
Regulations that would reduce the requirement of medium sized banks to
provide credit to low-income communities and clients. Our organization
is in the process of organizing and developing a Community Development
Financial Institution (CDFI) and we will be relying on local banks to
assist in funding our loan pool under the provisions of CRA. A CDFI or
similar organization is needed in our rural southeastern North Carolina
county that has a poverty level almost twice that of the nation as
whole, and an unemployment rate of 9.7 percent. Access to capital was
noted in a recent market study as one of the deterrents to expanding
businesses or starting new ones.
During this period of economic distress in many rural areas, we are
convinced that if anything, financing tools such as CRA should be
strengthened rather than weakened so we can
provide the tools to revitalize our economics and provide new jobs. Our
area, Robeson County has
lost over 8000 manufacturing jobs in the past six years. These are jobs
that will never return as they
have been outsourced to foreign countries where low wages prevail. This
number of jobs is very difficult to replace, even over a long period of
time. These moves have not only cost people their income, but also their
health insurance, which has become a national issue with an increase of
over one million people now without healthcare benefits in the past
year.
We would like to see your agency increase the banks obligation to
meet the credit needs of
low and moderate-income clients. It is through the creation of small
community based business enterprises that our local and national job
shortage crisis can be alleviated. Therefore, we urge you and other
policy makers withdraw these proposed changes and continue the CRA
mandate to provide credit and access to capital to low income
communities. Your favorable consideration of this request will be
appreciated.
