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FDIC Federal Register Citations
Housing Authority of
the City of Lamar, Colorado
From: JD Bennett [mailto:executivedirector@lamarhousing.org]
Sent: Monday, October 18, 2004 7:48 PM
To: Comments
Cc: cra@nahro.org
Subject: "RIN 3064-AC50"
The Housing Authority of the City of Lamar, Colorado wishes to provide
comment on the proposed rule changes.
As a provider of housing, and therefore, an advocate for elderly, disabled
and working poor populations in a multi-county area - it is our position that
the proposed new rule would have a significant impact on the people we serve.
Over 70% of our area housing stock is pre-1940s and these homes are predominately
inhabited by lower-income families. Our future ability to rehab and stabilize
the homes here is seriously compromised by the proposed rule changes. CRA creates
partnerships. Its elimination, as a motivator, takes community service back
to the days of begging hat-in-hand. I don't wish to move backwards to the days
when investment in unmarketable areas or projects was non-existent. Redlining
has not disappeared - it has simply become covert and more sophisticated.
As the Executive Director for various low-income housing organizations and/or
nonprofit community agencies - I have found compliance to the CRA requirements
a serious encouragement tool to get buy-in for projects that have public merit
but minimal "profitability" incentives for banks. The difference
between the before/after mention of CRA, in seeking of partnerships, is night-to-day.
I would encourage the FDIC to reconsider its weakening of this valuable tool
used by those of us who serve the public interests.
As regards the changing of the dollar amounts; in our rural area, to raise
the asset threshold from $250 million to $1 billion of financial institutions
that have to undergo the comprehensive CRA examination, would eliminate every
bank in a six county area from the requirement. This, combined with allowing
banks to "balance their community lending investing and service activities
based on opportunities in the market and the banks own strategic strengths",
would make the CRA non-existent in the worst case scenario, or available upon
the whim or interests of the moment in the best case scenario. While the higher
limits and squishy commitment criteria will make your compliance issues simpler
- it will compromise the commitment to those most needy in our communities.
We agree with most of the housing and community investment professionals in
requesting these changes be abandoned.
JD Bennett, Executive Director
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