FDIC Federal Register Citations
From:
Ruth.Anne.Norris@cityofmesa.org [mailto:Ruth.Anne.Norris@cityofmesa.org]
Sent: Wednesday, October 20, 2004 1:33 PM
To: Comments
Subject: RIN 3064-AC50
I am writing to oppose the FDIC-proposed rule that would alter requirements
under the CRA. These modifications not only decrease the number of banks
that would face comprehensive compliance exams, but would also affect
the
examination itself by removing the requirements on the investment and
service elements and instead making them options under the lending test.
With government funding shrinking, eliminating regulatory incentives
for
private capital to leverage public dollars is inappropriate. We should
be
encouraging more community reinvestment, not reducing incentives.
The CRA has proven its worth by requiring banks to reinvest in local
communities through community development loans, investments and services,
benefiting low- and moderate-income households and communities. A recent
workshop I attended had participation from a number of local financial
institutions; it is very doubtful they would find a reason to participate
with reduced CRA requirements. The FDIC's proposed rule will therefore
impair affordable housing, and community & economic development,
particularly in rural areas.
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