From: Beadsie
Woo [mailto:bwoo@mindspring.com]
Sent: Thursday, September 30, 2004 11:55 PM
To: Comments
Subject: Comments Community Reinvestment 12 CFR Part 345
I write to object
to the proposed rulemaking to increase the size level of the "small banks" eligible to use the "small
bank" test for CRA compliance.
The proposed change would exempt as many as 94% of depository institutions
from service and investment requirements. It could result in as much as $5
billion less community investment over the next few years.
The proposed change would particularly hurt rural communities, that are often
served primarily, or exclusively, by financial institutions who would no longer
be subject to the CRA tests of "large banks." The new rule would
essentially allow these institutions to relax their attention to investing
in and serving disadvantaged members of their communities.
CRA has been an enormously successful and effective vehicle for improving investment
in disadvantaged communities, resulting in benefits not only to members of
those communities, but to our economy and society as a whole. Please do not
make this rule change that would be so harmful to so many consumers and their
communities.