Unified
Vailsburg Services Organization
September 8, 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429
RE: RIN 3064-AC-50
Dear Mr. Feldman:
As a member of the National Community Reinvestment Coalition Unified
Vailsburg Services Organization (UVSO) urges you to withdraw your
proposed changes to the Community Reinvestment Act (CRA) regulations.
CRA has been instrumental
in increasing homeownership, boosting economic development, and
expanding small businesses in the nation’s
urban and rural, minority, immigrant, and low and moderate income
communities. The proposed changes are contrary to the CRA statute
and Congress’ intent because they will slow down, if not halt,
the progress made in community investment.
UVSO humbly submits that it is a mistake to hold banks of different
sizes to different CRA criteria, and to give banks community development
options instead of requiring all banks to create, promulgate and
measure useful loan, service and investment products in low and moderate
income, urban and rural minority communities like Vailsburg.
Sincerely,
Robert M. Farley
Executive Director
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