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FDIC Federal Register Citations
From: Ann [mailto:annw828@sbcglobal.net]
Sent: Monday, October 11, 2004 4:11 PM
To: Comments
Subject: Ref: RIN 3064-AC50
October 11, 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington DC 20429
Ref: RIN 3064-AC50
Dear Mr. Feldman,
As concerned citizens and as Christians who care about those who are the
least among us, we urge you to withdraw the FDIC proposed changes to the
Community Reinvestment Act (CRA).
By requiring banks with assets greater than $250 million to comply with
the
³
three point audit test² of lending, investing, and providing banking
services to low- and middle-income communities, the CRA has been one of
the
most successful community development programs. The CRA had provided $1.5
trillion for housing developments, medical clinics, and other community
projects that would never have been completed without the CRA.
Now your proposal will increase the small bank definition to banks with
assets under one billion dollars. Thus, the ³three point audit test² will
no longer apply to most banks throughout the U.S. In my state of Illinois,
this will leave only 13 banks that will still be required to meet the
stricter lending, investing, and services standards. This will result in
fewer loans and investments in affordable housing projects, clinics,
community centers, and economic development projects. Along with the
Section 8 housing voucher changes that result in less housing for poor
residents, I believe the loss of loans and investments in affordable housing
projects will worsen the already difficult low- and middle-income housing
situation.
Your proposed changes do not uphold the purposes of the CRA.
They should be withdrawn.
Sincerely,
Doug and Ann Wagner
440 Middlesex Court
Buffalo Grove, IL 60089
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