From: jonathan burr [mailto:jp@phishtail.com]
Sent: Tuesday, April 06, 2004 3:37 PM
To: regs.comments@occ.treas.gov; regs.comments@federalreserve.gov;
Comments; regs.comments@ots.treas.gov
Cc: president@whitehouse.gov; linda.figura@do.treas.gov
Subject: Withdraw CRA Changes
April 6, 2004
Docket No. 04-06
Communications Division
Public Information Room, Mailstop 1-5
Office of the Comptroller of the Currency
250 E St. SW,
Washington 20219
Docket No. R-1181
Jennifer J. Johnson
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington DC 20551
Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th St NW
Washington DC 20429
Regulation Comments, Attention: No. 2004-04
Chief Counsel?s Office
Office of Thrift Supervision
1700 G Street NW
Washington DC 20552
Dear Officials of Federal Bank and Thrift Agencies:
I am a concerned citizen writing to urge you to WITHDRAW the currently
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. However,
the proposed changes are contrary to the CRA statute because they
will halt
the progress made in community reinvestment and undermine its purpose.
The proposed changes will eliminate the investment and service parts
of the
CRA exam for banks and thrifts with assets between $250 and $500
million.
This would reduce the rigor of CRA exams for 1,111 banks that account
for
more than $387 billion in assets. These not-so-small banks may seem
insignificant in the comparison with prominent megabanks, but they
have a
huge impact on the communities they serve. In turn, communities deserve
the
right to have those banks monitored and, if necessary, disciplined
for
neglectful and harmful behavior. It is imperative that banks fulfill
their
public obligation to serve ALL of their community, without fair exclusion
and without predatory practices. Limiting the means by which you
can
monitor this is unacceptable and contradictory to the original purpose
of CRA.
The changes also
contain an "anti"-predatory lending standard
that will
actually perpetuate abusive lending. In this proposal, the new definition
of "predatory" is very narrow and, ultimately, CRA exams
will allow abusive
lending as packing fees into mortgage loans, high prepayment penalties,
loan flipping, mandatory arbitration, and other numerous abuses won't
be
considered "predatory". Rigorous fair lending audits and
severe penalties on
CRA exams for abusive lending are NECESSARY in order to ensure that
the new
minority homeowners served by the Administration are protected. Yet,
the
proposed predatory lending standard will NOT provide these necessary
protections.
CRA is too vital to be gutted by harmful regulatory changes and
neglect. Please help save our communities by withdrawing these harmful
proposed changes. I thank you for your attention to this critical
matter.
Sincerely,
Jonathan P. Burr
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