RURAL COMMUNITIES
From: Lorna Bourg
[mailto:smha@southernmutualhelp.org]
Sent: Monday, April 05, 2004 4:40 PM
To: Comments
Subject: CRA Proposed Changes
RURAL COMMUNITIES
3602 Old Jeanerette Road
New Iberia, LA 70563
April 4th, 2004
Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Company
550 17th Street, NW
Washington D.C. 20429
Dear Mr. Feldman:
We are writing against the proposed change to rules governing the
Community Reinvestment Act (CRA). In particular, we are opposed to
changing the definition of a “small bank” from a bank with assets of 250
million dollars to a bank having assets of 500 million dollars. The
proposed rule would adversely impact the rural communities in which we
work by removing incentives for local, community banks to invest in the
future prosperity and health of the communities that they serve.
Instead, we urge you to maintain the current “small bank” definition
so that local, smaller banks are provided with the same incentives for
community investment as larger banks. This is especially important for
rural communities, since many larger national banks do not serve, and do
not invest, in rural areas. In addition, we encourage federal bank and
thrift agencies to institute a comprehensive predatory lending policy to
protect the assets of all families, whether rural or urban. Banks should
be provided with a disincentive to engage in predatory practices by
insuring that abusive lending count against an institution’s CRA rating.
Sincerely,
Lorna Bourg
Executive Director
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