Henry
K. Holsman Institute for Advanced Affordable Family Housing Studies
From: J. Peter Holsman [mailto:j.peter.holsman@comcast.net]
Sent: Monday, October 04, 2004 2:32 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
I am a third
generation affordable housing and remodeling design-build architect –builder
of 42 years (64 years old) and I think the proposed changes in
the CRA are COMPLETELY BACKWARDS !
It is the smaller
institutions that should get more of a “push” from
the system since they are closest to the local neighborhoods where
the best community redevelopment and more human and family-oriented
affordable working and living environments are financed and thus
actually built.
Thus the small
institutions have a greater potential for improvement and change.
However, the
local branches of the bigger financial institutions
should be treated as if they are smaller institutions by auditing
the share of their larger parent company’s total business that
is attributable to their local neighborhoods! If the main office
or the branch is in a urban downtown, then THAT portion of their
business related to THAT neighborhood should be THE determining factor.
But if their BRANCH office is in a slum neighborhood or a rich suburb
then THAT neighborhood should govern as far as CRA regulations and
requirements for intensity of focus is concerned.
In other words; “It’s the neighborhood, stupid!” -
Duhh !
J. Peter Holsman, founder
The Henry K. Holsman Institute for Advanced Affordable Family Housing
Studies
