From: Lawrence Broadwell [mailto:bakpacker1@earthlink.net]
Sent: Tuesday, April 06, 2004 11:05 AM
To: regs.comments@occ.treas.gov; regs.comments@federalreserve.gov;
Comments; regs.comments@ots.treas.gov
Subject: Proposed CRA Regulations
To: Officials
of Federal Bank & Thrift Regulatory Agencies
As a concerned citizen familiar with the sad history of race-based "redlining" by
financial institutions and with the enormous good the Community
Reinvestment Act (CRA) has done for the entire U.S. economy, I
urge you to withdraw the currently proposed changes to CRA regulations.
Under the present regulations, CRA provides strong inducements
for banks to serve ALL parts of the area from which they draw deposits.
This increases access to homeownership, strengthens economic development
in hard-hit neighborhoods, and encourages entrepreneurship in minority,
immigrant, and low- and moderate-income communities. The proposed
changes threaten to halt and even reverse CRA's beneficial effects.
By empowering local groups of citizens to monitor and work with
their banks, CRA makes thousands and thousands aware of their rights
as consumers of financial services. This minimizes the need for
expensive regulatory oversight at the same time it encourages diverse
elements of communities to collaborate for more development. It
also spurs banks to build branches in communities that would otherwise
be served, if that is the proper word, by check cashers, payday
lenders, and outright predators.
I have read that the current proposal would block citizen oversight
of more than one thousand banks with nearly $400 billion in assets.
This would be an extraordinary affront to the communities -- especially
rural communities -- served by the so-called "small" banks.
In light of the extraordinary support we taxpayers have given financial
institutions in the form of deposit insurance, low-interest federal
funding and periodic bailouts, CRA is a small burden for ALL financial
institutions to assume in exchange.
Your proposed regulations threaten efforts to expand fair access
to financial products and services. They threaten to kill the dreams
of minorities and low-income Americans who are striving to improve
their lives and their communities. By feeding the perception of
a return to the old "insider" control of depositors'
funds and the bad old days of redlining, they even threaten to
tear the social fabric that links Americans with one another.
CRA contributes far too much to economic development and to the
bonds in our communities to be gutted. The proposed regulations
are badly conceived and must be withdrawn.
Sincerely,
Lawrence C. Broadwell
5306 Saratoga Avenue
Chevy Chase, MD 20815
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