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From: Amy Davidson
[mailto:amy_list@pacbell.net]
Sent: Friday, April 02, 2004 3:52 PM
To: Comments
Subject: CRA proposed legislation
Dear Officials of Federal Bank and Thrift Agencies:
I urge you to withdraw the proposed changes to the Community
Reinvestment Act (CRA) regulations. CRA has been instrumental in
increasing access to homeownership, boosting economic development, and
expanding small businesses in the nation's minority, immigrant, and low-
and moderate-income communities. Your proposed changes are contrary to
the CRA statute because they will halt the progress made in community
reinvestment.
The proposed CRA changes will thwart the Administration's goals of
improving the economic status of immigrants and creating 5.5 million new
minority homeowners by the end of the decade. Instead, the proposed CRA
changes would facilitate predatory lending and reduce the ability of the
general public to hold financial institutions accountable for compliance
with consumer protection laws.
The proposed changes include three major elements: 1) provide
streamlined and cursory exams for banks with assets between $250 million
and $500 million; 2) establish a weak predatory lending compliance
standard under CRA; and 3) expand data collection and reporting for
small business and home lending. The beneficial impacts of the third
proposal are overwhelmed by the damage imposed by the first two
proposals. In addition, the federal banking agencies did not update
procedures regarding affiliates and assessment areas in their proposal,
and thus missed a vital opportunity to continue CRA's effectiveness.
The proposed changes to CRA will directly undercut the
Administration's emphasis on minority homeownership and immigrant access
to jobs and banking services. The proposals regarding streamlined exams
and the anti-predatory lending standard threaten CRA's statutory purpose
of the safe and sound provision of credit and deposit services. The
proposed data enhancements would become much more meaningful if the
agencies update procedures regarding assessment areas, affiliates, and
the treatment of high cost loans and purchases on CRA exams. CRA is
simply a law that makes capitalism work for all Americans. CRA is too
vital to be gutted by harmful regulatory changes and neglect.
Thank you for your attention to this critical matter.
Sincerely,
Amy M. Davidson
479 Potrero Ave.
Apt. B
San Francisco, CA 94110
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