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FDIC Federal Register Citations

From: Beth LEValley [mailto:srbeth1@juno.com]
Sent: Monday, October 04, 2004 9:04 AM
To: Comments
Subject: In regard to CRA

October 4, 2004

To whom it may concern:

I have long represented the religious community in regard to CRA work. We, the religious community of Greater Rochester, testified both inBuffalo and Syracuse when the then President Clinton was evaluating theCRA regulations and working to make them more effective.

At our Community Development Committee meetings at that time banks who at first did not attend or respond were all of a sudden present. As I reflected why, it struck me it was because of CRA. Then as we worked to assist the community of the city in starting the first community development credit union in our district, Progressive Neighborhood Federal Credit Union, we say so much support, especially through donations and non-member deposits. There was also great collaboration
and good will which lasts until today. I am very clear, however, that it was because of the CRA regulations giving specific credit for non-member deposits in community development credit unions.

Now we find our banks getting larger and larger, mergers happen again and again. We now have a number of small banks assuming a good part of the market and moving to become the next iteration of community banking with staff close to the community.

From this history and from my experience with these emerging institutions that serve underserved people, I am absolutely opposed to any weakening of CRA.

I remember when I started a banker visited the closest community development credit union, putting on his bank pin. He told me that he received credit if he put on his pin. He thought it was a bit ridiculous, ie not because they were investing in anything or actually DOING anything in the low income communities of our city/county - just putting on a pin.

Know that I would be happy to tell this story anywhere. I have further stories not totally related to CRA about how when Progressive started we had a spirit of unprecedented collaboration. I even talked at a national meeting about this as did our manager at another one. I now have stories of competition which is not helping the institutions serving the low income neighborhoods who have an actual track record of doing so. Banks know we are helping the people become bankable where they - banks and people - find failure working with traditional banks.

Sincerely,

Sr. Beth LeValley
Once facilitator of the Community Development Committee of Greater
Rochester Community of Churches (GRCC)
Former President, GRCC which continues to serve as the 501c3 sponsor of
Progressive Neighborhood FCU
VP/Secretary of Progressive
Secretary of Community Microenterprise Center, Inc. - community
development organization
Founder and continuing member of Greater Rochester Community Reinvestment
Coalition

Last Updated 10/09/2004 regs@fdic.gov

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