Federal Deposit
Insurance Corporation

Inner City Christian Federation

October 19, 2001

Donald E. Powell
Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

John M. Reich
Vice Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Thomas J. Curry
Director
Federal Deposit Insurance Corporation
55017th Street, NW
Washington, DC 20429

John D. Hawke, Jr.
Comptroller of the Currency
Office of the Comptroller of the Currency
250 E Street SW
Washington, DC 20219

Gentlemen:

Despite the successes locally and nationally of community investment, the banks and thrift institutions that provided the loans and investments to build new homes, businesses, and community facilities may no longer have the impetus to do so if you change the CPA exam threshold.

The National Congress for Community Economic Development has informed me that the Federal Deposit Insurance Corporation is considering changes to weaken the Community Reinvestment Act. I am writing to urge that you not do so.

It is estimated that 2,000 financial institutions would no longer be evaluated on their investment or services to low- and moderate-income communities. These banks have assets of nearly $1 trillion, and an estimated $5 billion of private capital for affordable housing and community development over the next few years.

These proposed rule changes would have a devastating effect on affordable housing investment in our state and elsewhere throughout the nation, particularly in rural areas.

In the past 30 years the Inner City Christian Federation has reconstructed or newly constructed 460 units of housing and created in excess of 500 jobs. We have increased property values and the quality of life for hundreds of residents of our community. For example in the Madison and Hall neighborhood on Grand Rapids' southeast side, we have built 62 single family houses over the last five years. Since we started real estate assessed valuations have increased more than 40% on both the new houses and nearby existing houses. just as importantly, calls to the Grand Rapids Police Department for serious crimes have fallen by 90%.

Please note that every housing unit we have produced since 1990 has had a loan or a grant from a local lending institution. Further, it is highly probable that the Community Reinvestment Act provided substantial motivation for them in doing so.

I am very concerned that this step is being taken without Congressional action. My legislators know that without financial partners, our efforts to revitalize our community would be nearly impossible.

The FDIC should be strengthening incentives for financial institutions to invest in the communities that provide homes, jobs, and economic opportunities to working families. Please do not raise the CR,A, exam threshold.

Sincerely
Jonathan Bradford
Executive Director