FDIC Federal Register Citations
Housing Authority of the City of Alameda
From: Eileen DUFFY [mailto:EDUFFY@alamedahsg.org]
Sent: Monday, October 18, 2004 6:04 PM
To: Comments
Cc: Mike PUCCI; cra@nahro.org
Subject: RIN 3064-AC50
This message is sent on behalf of Michael T. Pucci, Executive Director
of the Housing Authority of the City of Alameda.
We understand that a proposal from the FDIC threatens to undermine the
Community Reinvestment Act (CRA). The proposed new rule would make
modifications that would decrease the number of banks that would face
the comprehensive compliance exams and also would affect the examination
itself by removing the requirements on the investment and service
elements, instead making them options under the lending test. The
proposed rule would do this by raising the asset threshold from $250
million to $1 billion of financial institutions that have to undergo
the
comprehensive CRA examination. It would also add language allowing banks
to "balance their community lionding investing and service activities
based on opportunities in the market and the banks own strategic
strengths."
The FDIC proposal will harm low and moderate-income communities by
removing CRA obligations from as many as 1,300 insured depository
institutions. We rely upon bank partnerships for affordable housing,
and
we believe that more private sector partners, not fewer, are needed.
Our Housing Authority has been successful in partnering with three local
banks which provided financing for affordable housing in our City. We
feel that they would not have participated without the provisions in
the
current rule. We strongly encourage you to reject the proposed new
rule.
Eileen Duffy, Administrative Operations Manager
Housing Authority of the City of Alameda
701 Atlantic Avenue
Alameda, CA
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