SOUTHERN MUTUAL HELP ASSOCIATION
August 25, 2004
Robert E. Feldman, Executive Secretary
Attention: Comments/Legal
ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, D.C. 20429
Dear Sir or Madam:
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 one billion
dollars. The proposed rule would adversely impact our work with poor
families in rural areas 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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