Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St, NW
Washington, DC 20429
September 16, 2004
RE: RIN 3064-AC50
Dear Mr. Feldman;
As the Housing. Program Coordinator of IndependenceFirst, as a
concerned citizen of Wisconsin, as a resident of the metropolitan area
of Milwaukee, and as a person with a disability, I am writing about the
proposed changes to the Community Reinvestment Act that I believe will
be harmful to many communities.
The Community Reinvestment Act was brought about in response to a
need for investment in low-income and moderate-income communities, and
it continues to serve that purpose. I live in a suburb south of
Milwaukee, but work near downtown Milwaukee, and my job brings me to
many different parts of the city. I am a witness to the effects of
racial and economic segregation that lives on in the city. We need more
economic investment in those areas not less! To reduce the effectiveness
of CRA would be to weaken the requirements of some local banks serving
neighborhoods in the city, and to weaken the neighborhoods by denying
them access to the programs, services and funds that CRA encourages
banks to provide.
I am aware that many bankers are calling for those changes to the CRA,
but please remember that one of FDIC's duties is to regulate those banks
and their activities. That should mean that FDIC should require that
banks fulfill their duty to the communities they serve. In the
watered-down exam, FDIC would allow. mid-sized banks to choose which
community development activities they will undertake. Right now, these
banks must make community development loans, investments, and services..
The proposed test allows banks to choose only one of the three
Activities. The result can only be' less community development activity.
I am very disturbed by the proposal that would eliminate publicly
available data on the small business lending of mid-sized banks. As we
have seen again and again, with little or no transparency in business
and government affairs, abuses often occur. Without those data, how are
community groups and advocates to hold banks accountable for meeting
their obligations?
I ask the FDIC to not only reject the proposed changes to the
Community Reinvestment Act, but to explore ways that the CRA can be
strengthened to serve rural communities, minority communities,
low-to-moderate income communities, and people with disabilities.
Sincerely,
Brian Peters
Housing Program Coordinator
IndependenceFirst
Milwaukee, WI
cc: National Community Reinvestment Coalition
President George W Bush
Senator John Kerry
Senator John Edwards
