From: Jamie Stubbs [mailto:jstubbs78@aol.com]
Sent: Friday, October 01, 2004 10:51 AM
To: Comments
Subject: Do Not Weaken the CRA
Jamie Stubbs
1630 Florida Avenue, NW
Washington, DC 20009
October 1, 2004
Robert E. Feldman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
To Robert Feldman:
I am a child care advocate opposed to watering down CRA (Community
Reinvestment Act) requirements for mid-sized banks. CRA is vital for
economic development in lower-income communities, and investing in child
care is a highly effective community development strategy. However, your
proposed changes will halt the progress that has been made.
Under the proposals, the community investment requirements for banks
with assets between $250 million and $1 billion will be greatly
weakened. These banks would no longer be tested on the number of
investments and services to low- and moderate-income communities. In
addition, these banks would be allowed to choose which one development
activity – among lending, investment, and services – they will
undertake; today they must engage in all three. These watered down
requirements will result in significantly fewer loans and investments in
child care centers, family child care homes, and other economic
development projects.
The proposal also would allow community development activities in
rural areas to benefit any group of individuals instead of specifically
low- and moderate-income individuals. But this will allow banks to
cherry-pick and focus on affluent residents of rural areas rather than
the lower-income consumers CRA targets.
Your changes directly conflict with CRA’s mandate to require lenders
to meet a community’s needs for services such as child care, health
clinics, and housing. CRA is too important to be gutted. Please withdraw
your proposal like the two other federal agencies that recognized its
harm to underserved communities.
Sincerely,
Jamie L. Stubbs
