URBAN ECONOMIC DEVELOPMENT ASSOCIATION OF WISCONSIN
September 10, 2004
Thomas J. Curry, Director
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Mr. Curry:
Systemic, substantial and grave are words that describe my concern
over OTS's announcement to reduce three-part CRA examinations. The
chilling effect this choice may impose on services and financial support
for community development work in distressed areas will be deepened if
you elect to follow this course.
This proposed lower CRA standard will diminish the innovation, asset
base and scope of services built in reliance of CRA standards. Removing
tests and their resulting obligations within CRA will stifle the growth
of CDFI's and CDC's working to serve low income people who build and
provide affordable homes. This systemic change will stifle the streams
of incentives which support revitalization in distressed urban centers
and within faltering rural economies.
Combined with the effects of weakened government support for
revitalization, we see deepening divides between the asset poor and the
asset rich. Some non-profits report that as many as 75-80% of their bank
investors will be de-regulated as a result of OTS's choice.
Deregulation has its place and purpose; it is not here and not now!
Sincerely,
Carol N. Maria
Executive Director
Urban Economic Development Assoc of Wisconsin
Milwaukee, WI
