Federal Deposit
Insurance Corporation

Lehigh Valley Coalition

From: Lilly Weaver, Sharol [mailto:slillyweaver@caclv.org]
Sent: Wednesday, October 20, 2004 4:41 PM
To: Comments
Subject: changes to CRA

The Lehigh Valley Coalition on Affordable Housing is an organization of local government officials, lawyers, lenders, developers, social service workers, clergy, and other civic leaders whose mission is to ensure that every household in the Lehigh Valley is secure in affordable, safe, sanitary, and appropriate housing. The Lehigh Valley consists of the cities of Allentown, Bethlehem, and Easton, whose total population is 579,156. The poverty rates for the cities are as follows: Allentown - 18.5% (a 43% increase since 1990), Bethlehem - 15% (a 50% increase in poverty since 1990), and Easton  16% (a 17% increase since 1990). Almost 3,000 men, women, and children seek shelter every year and the shelters are always full. The Fair Market Rent is $12.44 an hour  a person would have to work 97 hours a week to afford a two-bedroom apartment if they earned minimum wage. Over 11,000 persons have lost jobs during the last three years. The Coalition has a history of working collaboratively with lenders to address the housing needs of low-income persons as a result of the CRA requirements. Lenders and non-profit housing organizations work hand-in-hand to bring affordable housing, home ownership counseling services, tenant/landlord education, family savings accounts, a predatory lending hotline, business entrepreneurship activities, and micro-lending to our inner-city neighborhoods. A weakening of CRA requirements will have a devastating impact on the provision of these critical services to low-income persons and will slow the progress that has been made to redevelop communities and build personal and community wealth. We strongly request that the proposed FDIC rules be abandoned and instead, continue the rules and requirements that have led to the progress that exists today in the Lehigh Valley and other communities across the country.

Sincerely,

John D. Rohal
Chair