From: Laura Junglas [mailto:NPOrgDoc@earthlink.net]
Sent: Monday, September 27, 2004 8:12 PM
To: Comments
Cc: nmelton@ncrc.org
Subject: CRA regs
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 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. CRA is vital for
increasing homeownership and economic development in low and
moderate-income communities. However, your proposed changes will halt
the tremendous progress that has been made.
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. This will result in significantly fewer loans and investments
in affordable rental housing, health clinics, community centers, and
economic development projects.
In the watered-down exam, you would allow mid-sized banks to choose
which community development activities they will undertake. Right now,
these banks must make community development loans, investments, and
services. Your proposed test allows banks to choose only one of the
three activities. In my opinion, as a former banker, the combination of
loans, investments and services greatly benefits the community. CRA is
good business for banks. Our commercial loan department made money at
this activity!! The watered down version will allow banks to choose the
easiest option which is not always beneficial to the community.
Finally, you would also eliminate publicly available data on the
small business lending of mid-sized banks. Without data, community
groups and citizens cannot hold banks accountable for lending to small
businesses in their neighborhoods.
Your changes directly oppose CRA’s mandate to require lenders to meet
community needs. CRA is too important to be gutted. Please drop your
proposal like the two other federal agencies that recognized its harm to
underserved communities.
Sincerely,
Laura Junglas
2623 Kingston Rd.
Cleveland Hts., OH 44118
Cc: National Community Reinvestment Coalition
