From: Cindy Tidball [mailto:ctidball@blacklightning.net]
Sent: Friday, September 24, 2004 12:36 PM
To: Comments
Subject: RIN 3064-AC50 - proposed changes to CRA
It is difficult for an average citizen to comment on regulation
changes. Often we get confused in the technicalities of language.
Nevertheless, I did wade through the entire posting on the FDIC website
regarding the above mentioned proposed rule change. I have one general
comment.
Err on the side of protecting the financial lives and futures of
lower income individuals and rural communities. It particularly concerns
me, with respect to the comments made regarding the change in asset
threshold to $1 billion "regardless of holding company affiliation" that
the assertion that these larger holding companies, at least as yet, have
not moved to legally structure themselves so that subsidiaries fit under
the less stringent rules for smaller institutions is taken at face
value, without any level of suspicion or caution. Evaluating the
potential gain in exploiting such loopholes is a primary reason for
large organizations to have large and competent legal staffs. It is a
disservice to all of us that FDIC, having such a loophole brought to its
attention, would not propose regulations to guard against abuses.
So, I remain suspicious, believing that the proposed changes amount
mostly to a smokescreen for lending agencies to avoid their
responsibilities to the overall health and welfare of the communities
that they serve in their pursuit of greater profit for themselves. I
urge you again to err on the side of those whose economic weakness
already puts them at a substantial disadvantage.
David Tidball
1650 W. Hwy. 36, #165
Roseville, MN 55113
