Skip Header

Federal Deposit
Insurance Corporation

Each depositor insured to at least $250,000 per insured bank



Home > Regulation & Examinations > Laws & Regulations > FDIC Federal Register Citations




FDIC Federal Register Citations

YERINGTON PAIUTE TRIBE

September 20, 2004

Mr. Robert E. Feldman Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street NW Washington, DC 20429

RE: RIN 3064-AC50

Dear Mr. Feldman:

I am a concerned citizen opposed to watering down CRA (Community Reinvestment Act) requirements for mid-sized banks. CRA is vital for increasing homeownership and economic development in lower-income communities. Your proposed changes will halt the progress that has been made.

I understand that banks with over $250 million in assets must be tested on their number of loans, investments, and services to low- and moderate-income communities. But your proposal would eliminate the investment and service requirements for all banks with under $1 billion in assets. This will result in significantly fewer loans and investments in affordable rental housing, health clinics, community centers, and economic development projects.

The proposed changes, which would make smaller banks less accountable for their community reinvestment activity, alarm us, as banks are finally waking up to the investment opportunities in Indian country. Indian country has made strides with the help of banks in the mortgage arena—we saw conventional mortgage activity increase for Native Americans in 2003. We believe that the strength of the current law has been instrumental to this development.

You propose that community development activities in rural areas can benefit any group of individuals instead of only low- and moderate-income individuals. Since banks will be able to focus on affluent residents of rural areas, your proposal threatens to divert community development activities away from the low- and moderate-income communities and consumers that CRA targets. In our rural community, that reduction amount of community development activity would earn CRA points even if it benefits affluent consumers and communities. What's left over for the low- and moderate-income rural residents are the crumbs of a shrinking CRA pie of community development activity.

Your proposed changes directly oppose CRA's mandate of imposing a continuing and affirmative obligation to meet community needs. Your proposal will dramatically reduce community development lending, investing and services. You compound the damage of your proposal in rural areas, which are least able to afford reduction in credit and capital. You also eliminate critical data on small business lending.

If your agency is serious about CRA's continuing and affirmative obligation to meet credit needs, you would be proposing additional community development and data reporting requirements for more banks instead of reducing existing obligations. A mandate of affirmative and continuing obligations implies expanding and enlarging community reinvestment, not significantly reducing the level of community reinvestment.

CRA is too vital to be gutted by regulatory fiat and neglect. We hope that the FDIC, which earlier this year had the vision to hold a conference on the "unbanked," will not now introduce changes detrimental to the most "unbanked" population of all.

Sincerely,

Wayne M. Garcia, Tribal Chairman
Yerington Paiute Tribe

Cc: National American Indian Housing Council (fax: 202-789-1754)
National Community Reinvestment Coalition (fax: 202-628-9800)
President George W. Bush (White House fax: 202-456-2461)
Senators John Kerry (fax: 202-224-8525)
Senator John Edwards (fax: 202-228-1374)

Last Updated 10/20/2004 regs@fdic.gov

Skip Footer back to content