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FDIC Federal Register Citations
From: Joan Gauer [mailto:joangauer@yahoo.com]
Sent: Tuesday, October 19, 2004 11:09 AM
To: Comments
Subject: RIN 3064-AC50
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 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. However, 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.
In the watered-down exam, you 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.
Your proposed test allows banks to choose only one of the three activities.
The result will be less community development activity.
You also propose that community development activities in rural areas
should benefit any group of individuals instead of only low- and moderate-income
individuals. But this will allow banks to cherry-pick and focus on affluent
residents of rural areas rather than the lower income consumers CRA targets.
Finally, you would also eliminate publicly available data on the small
business lending of mid-sized banks. Without data, community groups and
citizens cannot hold banks accountable for lending to small businesses
in their neighborhoods.
Your changes directly oppose CRA’s mandate to require lenders to
meet community needs. CRA is too important to be gutted. Please drop
your proposal like the two other federal agencies that recognized its
harm to underserved communities.
Sincerely,
Joan Gauer
West Orange, NJ 07052
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