WEST VIRGINIA A VISION SHAREDSeptember 27, 2004
Mr. Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429
Dear Mr. Feldman:
Re: RIN 3064-AC50, FDIC proposed rule to increase the small
institution threshold by changing the definition of "Small Bank" for
Community Reinvestment Act (CRA) purposes
We write on behalf of the West Virginia Vision Shared Implementation
Leadership Team to express our concerns over the proposed increase to
the asset threshold for determining what is considered to be a "small
bank" under the Community Reinvestment Act ("CRA").
West Virginia: A Vision Shared! is a volunteer initiative involving
hundreds of leaders, elected officials, business people, labor,
citizens, and organizations from across West Virginia who are working on
a non-partisan, cooperative basis to execute a comprehensive economic
development strategy for West Virginia.
The CRA is a critical component of every state's affordable housing
and other community development solutions. As a rural state with
relatively scarce resources, West Virginia must look to many types of
financial and other institutions to help assure that its communities can
establish and maintain the infrastructure necessary to achieve economic
and social success. The CRA has historically helped assure that
resources are in place in West Virginia for such success.
While we are cognizant of the administrative burdens that small banks
face with regard to the CRA, we believe that the FDIC should carefully
consider the very important purposes and policies served by the CRA in
rural states like West Virginia. Banks play a critical role in
establishing and maintaining community infrastructure, both business and
non-profit, and the CRA is therefore critical to assuring that basic
community infrastructure is in place. We are concerned that changes such
as those proposed might weaken the impetus for banks to invest in
affordable housing and other community infrastructure across West
Virginia in the years ahead.
CRA has been instrumental in increasing home ownership, boosting
economic development, and expanding small businesses in the nation's
minority, immigrant, and low- and moderate- income communities. We are
delighted with the positive results that have been achieved to date as a
result of the implementation of the CRA, and believe that the important
public policy goals and objectives of the CRA are as vital and important
today as when the CRA was first enacted.
For these reasons, we express our concern over the proposed changes,
and urge the FDIC to carefully consider the proposed revisions and their
likely effects on investment in community infrastructure in West
Virginia and across the nation.
Sincerely,
Michael J. Basile
Spilman Thomas & Battle, PLLC
Kenneth M. Perdue
WV AFL-CIO
