From: Deb Gerken [mailto:dagerken@nocac.org]
Sent: Monday, October 04, 2004 2:34 PM
To: Comments
Subject:
To Whom It May Concern:
I am writing to urge you not to change the current CRA regulations
and thresholds. This would leave rural areas with no regulated
financial facilities.
Because of CRA regulatory pressure, we have been successful in
partnering with local banks on a number of projects benefitting
low-income residents of northwest Ohio. We have received link deposit
mortgages on buildings used for Head Start as well as a building
that houses emergency shelter rooms, Single Room Occupancy apartments,
a soup kitchen and case management offices.
In addition, we have partnered with three area banks to hold and
service accounts for our Individual Development Account customers.
They are saving money which is matched by some of the area banks,
for assets including new homes, starting a business or continuing
their education.
It is highly probable that without the current CRA requirements
and thresholds, most of these "partners" would no longer
see any advantage to helping the low-income residents in the geographical
areas from which they draw their customers and the programs that
I have outlined for you would no longer be viable in our very rural
area of Ohio.
Please retain the current regulations/thresholds in order to preserve
one of the few funding conduits available to low-income people
in our area.
Thank you.
Deborah A. Gerken
Executive Director
Northwestern Ohio Community Action Commission
Defiance, Ohio
