From: Stephanie Bast [mailto:SRBast@nyc.rr.com]
Sent: Tuesday, April 06, 2004 11:06 AM
To: Comments
Subject: CRA
Dear Officials of Federal Bank and Thrift Agencies:
As a concerned citizen and
active community developer, I write to urge you to WITHDRAW the proposed
changes to the Community Reinvestment Act (CRA) regulations.
For more than 25 years, the CRA has encouraged banks to better
serve U.S. communities, resulting in increased access to homeownership,
strengthened economic development in stagnant local economies, and
expansion of small businesses in the nation's minority, immigrant, and low-
and moderate-income communities. Your proposed changes promise only to
halt and even reverse that economic progress.
By empowering citizens with the tools for close oversight of their
local banks, the CRA has "completed the market" - it has added millions
of
community residents to the "eyes and ears" that the regulatory agencies
need for responsible oversight; it has added stakeholders to stockholders
and regulators in the ongoing work of fine-tuning "financial
intermediation" to best serve the convenience, needs and advancement of
the
country's local, regional and national economies.
Yet now, you propose to block that citizen oversight of 1,111
banks that account for more than $387 billion in assets! Those
not-so-small banks may seem small in comparison with the megabanks, but
they are HUGE to the communities they serve, and those communities deserve
the right to watchdog and, if necessary, to discipline their banks to
fulfill every bank's public obligation to serve ALL of their community,
without unfair exclusion and without predatory practices.
You already have many letters detailing the serious drawbacks of
the proposed Interagency Regulations - drawbacks that promise to undermine
and even cripple efforts to expand fair access to high-quality financial
products and services. I won't reiterate them here, but instead I will
urge you to keep your eye on the goal, a goal that CRA has served with
increasing effectiveness over the past two-and-a-half decades: To make
fair access to capital, credit and banking services available to everyone,
in order to help individuals, families and communities build assets toward
a more prosperous and resilient economic future.
CRA is a law that makes capitalism work for all Americans. It is
far too vital to be gutted by harmful regulatory changes and neglect.
Thank you for your attention to this critical matter.
Sincerely,
Stephanie Bast
NY, NY
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