UNIVERSITY NEIGHBORHOOD HOUSING PROGRAM
From: JBucUNHP@aol.com [mailto:JBucUNHP@aol.com]
Sent: Tuesday, April 06, 2004 12:57 PM
To: regs.comments@occ.treas.gov; regs.comments@federalreserve.gov;
Comments; regscomments@ots.treas.gov
Subject: Comments on Regulations University Neighborhood Housing Program
2751 Grand Concourse
Bronx, NY 10468
(718)933-3101
fax (718)933-3624
www.unhp.org
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:
UNHP is a Bronx-based non-profit organization that has worked closely
with non-profit housing organizations, financial institutions and
government agencies to bring reinvestment money back into our neighborhoods
in the Bronx. Since our beginning in l983, we have worked closely
with a number of financial institutions and their community reinvestment
programs.
The importance of the Community Reinvestment Act and its accompanying
regulations has always been clear to us in our work. It is based
on that history that we make the following comments on the proposed
regulatory changes.
We do not feel that the expansion of the streamlined CRA processes
to banks with assets between $250 million and $500 million is justified.
We understand that the proposed changes will eliminate the investment
and service pieces of the CRA exam for those banks. Removing those
requirements from so many institutions cannot be justified. For
example, these banks would no longer have as clear an inducement
to invest in Low Income Housing Tax Credits, which have played a
tremendous role in the reclamation of so much housing in our neighborhoods
in the Bronx.
The revised regulations on predatory lending do not go far enough
to protect homeowners and homebuyers. The proposed standard states
that loans based on the foreclosure value of the property can negatively
impact CRA ratings. We have seen many other types of predatory practices
that should be included in the regulatory review. Excessive fees
and rates should also be taken into accout.
Finally, some of the proposed changes on data disclosure and collection
would be very useful in our analysis of bank practices. For instance
separately reporting originations and high cost lending will be very
useful in monitoring lending activities.
We urge you to look seriously at revising the proposed regulations
to take into consideration our first two points. Thanks for your
attention.
Jim Buckley
Director
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