Federal Deposit
Insurance Corporation

From: Tanya Collins [mailto:tcbooks8@hotmail.com]
Sent: Wednesday, October 20, 2004 2:16 AM
To: Comments
Subject: Oppose Efforts to Weaken CRA RIN number 3064-AC50

Tanya Collins
Mesa, AZ 85201

October 20, 2004

Federal Deposit Insurance Commission

Dear Federal Deposit Insurance Commission:

I have lived in Mesa, AZ for nearly 40 years, and in my current home and neighborhood for nearly three decades. I am committed to supporting my community because I am proud of where I live. I have made a substantial investment of time, money, community service and pride in my neighborhood. As with all neighborhoods, it has gone through several cycles of decline and rebirth -- and each time it has come away better because local residents and businesses have chosen to 'stick it out' rather than run from problems; they have chosen to reinvest their faith, hope and hard dollars to help our area change productively while still preserving the quality of life we all came here for in the first place.

Now I learn that despite the successes of such community development and revitalization efforts locally, the banks and thrift institutions that provided the loans, services, and investments to build new homes, businesses, and community facilities may no longer have the impetus to do so if the FDIC raises the comprehensive CRA exam threshold.

I agree with the National Congress for Community Economic Development that this proposed change would have a devastating effect on affordable housing and community development investment throughout the nation, particularly in older urban areas like the one where I live, and in rural areas.

Rural areas would be especially disenfranchised, as the FDIC apparently is proposing that the community development loans and investments in those rural areas can benefit any group of individuals, not just low- and moderate-income individuals. Currently, banks have to finance affordable housing and economic development projects that target low- and moderate-income borrowers and neighborhoods. Under the proposed changes, nothing in the CRA regulations would prevent banks from earning CRA points for financing developments with no community development benefit whatsoever. Moreover, the one-part exams would cover 99 percent of all FDIC-supervised banks located in rural areas.

President Bush’s recent comments promoting an "Ownership Society" ring so true, and bring hope and initiative to those in our neighborhoods who want to move from transiency to permanence and commitment to their communities via home and business ownership. If now the actions of officials he appointed are undermining proven laws that revitalize communities, increase minority homeownership, and increase small business ownership for women and minorities. I urge you not to breach the integrity of a good program by weakening it to the point of uselessness.

Please rescind your proposal.

Sincerely,
Tanya Collins