From:
Rangan Ravi (DNREC) [mailto:Ravi.Rangan@state.de.us]
Sent: Monday, September 20, 2004 7:46 AM
To: Comments
Cc: Rashmi Rangan
Subject:
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429
Washington, DC 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.
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. Seven additional banks in Delaware, bringing
up the total to 20 banks, will lower their involvement in community
economic development.
Right now, mid sized banks must make community development loans,
investments, and services. Your proposed test allows banks to choose
only one of the three activities.
You also propose that community development activities in rural
areas should benefit any group of individuals instead of only low-
and moderate-income individuals. Lower income consumers need CRA
loans, services and investments.
You would also eliminate publicly available data on the small business
lending of mid-sized banks. Without data, banks cannot be held accountable
for lending to small businesses in their neighborhoods.
Sincerely,
Ravi Rangan
114 Cardiff Court West
Newark, DE 19711
