FDIC Federal Register Citations

April 21, 2004

Jennifer J. Johnson
Board of Governors-Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, DC 20551
comments@fdic.gov
Re: Docket No. R-1181

I am writing to voice my opposition to the proposed changes to the Community Reinvestment Act because these changes will most harmfully affect low- and moderate-income communities in the New York metropolitan area.

CRA has been the single most significant factor in this locality in the successful production of affordable housing, particularly during the decline of federal rental housing production and rental subsidy programs over the past twenty years. Had it not been for CRA, lending in affordable housing
communities would have been significantly reduced and today's homeless problem would be significantly greater. In addition, CRA has provided a most profitable line of business for the money center banks and thrift institutions in the New York metropolitan area.

Therefore, I urge you not to allow for any increase in minimum bank size for regulation compliance and to not narrow the definition of predatory lending. Further, I believe that a lender shall be obligated to report knowledge of all activities of abusive lending, whether or not CRA ratings will be hurt. Finally, the proposed CRA disclosure of retail and business loans by census tract will assist our efforts in planning new housing and economic developments, so that I urge you to support this improved reporting
requirement.

Thank you for your attention.

Claire Haaga Altman
Housing & Services, Inc.
461 Park Avenue South, 6th floor
New York, NY 10016
(212) 252-9377, ext. 110
(212) 252-9319 fax
CLAIREHAAGA@aol.com
http:\\www.hsi-ny.org