From: Martha Mendez [mailto:martha.mendez@cvhc.org]
Sent: Monday, October 04, 2004 1:20 PM
To: Comments
Subject: RIN 3064-AC50
Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, D.C. 20429
Re: The FDIC’s proposed change to the Community Reinvestment
Act’s definition of a “small bank.”
Dear Sir:
As a concerned citizen and as an employee of the Coachella Valley Housing Coalition
(CVHC), I am writing to express my adamant opposition of any changes to the
Community Reinvestment Act.
The Coachella Valley Housing Coalition has committed 22 years to helping low
income people improve their living conditions through advocacy, research, and
the construction and operation of housing and community development projects.
These efforts have meant the construction of more than 2,500 single family
homes and apartment units for farmworkers, migrant farmworkers, seniors, and
individuals with special needs, HIV/Aids and other chronic illnesses.
Small banks have always been an integral part of the communities they serve—they
are more familiar with their surroundings and clientele, and their banking
needs—CRA forces all banks to get out and serve the neighborhoods in
which they operate. When banks infuse their services into a community that
community thrives, businesses thrive, people purchase homes, etc. To reduce
CRA’s mandate for “small” banks will cause banks to focus
on easy and more profitable avenues of business rather than working towards
a broader lending portfolio. Because government subsidies for housing are shrinking,
now is not the time to decrease regulations for private capital to leverage
scarce subsidy dollars.
CVHC has benefited greatly from CRA’s mandate on both large and small
banks, through various loans and grants over the years. Communities will lose
with less stringent CRA standards. I urge FDIC not to move forward with the
OTS proposed rule.
I appreciate the opportunity to share with you my impressions on any changes
proposed for the Community Reinvestment Act as it serves as a great tool for
all our housing and community building efforts. Thank you for your consideration
of my comments.
Sincerely,
Martha Mendez
Self-Help Program Specialist
Coachella Valley Housing Coalition
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