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FDIC Federal Register Citations
BankUnited
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
I am writing as Community Development Officer for BankUnited in South
Florida. Our organization opposes watering down the Community Reinvestment
Act (CRA) requirements for mid-sized banks. CRA is vital for increasing
homeownership and economic development in lower-income communities. However,
your proposed changes will halt the progress that has been made.
We understand that banks with over $250 million in assets must be tested
on their number of loans, investments, and services to low and moderate-income
communities. The current FDIC proposal would eliminate the investment and
service requirements for all banks with under $1 billion in assets. This
will result in significantly fewer loans and investments in affordable rental
housing, health clinics, community centers, and economic development projects.
In the watered-down exam, the FDIC would allow mid-sized banks to choose
which community development activities they will undertake. Right now, these
same banks must make community development loans, investments, and services.
Your proposed test allows banks to choose only one of the three activities.
The result will be less community development activity.
The FDIC also proposes that community development activities in rural
areas should benefit any group of individuals instead of only low and moderate-income
individuals. This will allow banks to cherry-pick and focus on affluent
residents of rural areas rather than the lower income consumers. Finally,
the proposed changes would also eliminate publicly available data on the
small business lending of mid-sized banks. Without data, community groups
and citizens cannot hold banks accountable for lending to small businesses
in their neighborhoods.
The FDIC’s changes directly oppose CRA’s mandate to require
lenders to meet community needs. CRA is too important to be gutted. Please
drop this proposal like the two other federal agencies that recognized
the harm these changes would inflict on underserved communities.
Sincerely,
Simona Niculescu
Assistant Vice President – Community Development Officer
BankUnited
2201 West Hillsboro Blvd.
Deerfield Beach, FL
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