FDIC Federal Register Citations

Dear Officials of Federal Bank and Thrift Agencies:
Please withdraw the proposed changes to the Community Reinvestment Act
(CRA) regulations. CRA has been instrumental in increasing access to home ownership,
boosting economic development, and expanding small businesses in the nation's rural,
minority, immigrant, and low- and moderate-income communities. Your
proposed changes are contrary to the CRA statute because in our
opinion they will slow, if not reverse, the progress made in community
reinvestment.

The proposed changes include three major elements: 1) provide streamlined
and much weaker CRA exams for banks with assets between
$250 million and $500 million; 2) establish a weak predatory lending
compliance standard under CRA; and 3) expand data collection and
reporting for small business and home lending. The beneficial impacts of
the third proposal are overwhelmed by the damage caused by
the first two proposals.In addition, the federal banking agencies did not
update procedures regarding affiliates and assessment areas in their
proposal, and thus missed a vital opportunity to continue to expand CRA's
effectiveness. Increasingly large financial institutions are doing business
far from their deposit-taking branches and home offices. Thus in a state
with a large number of rural communities like Wisconsin we find some of the
largest financial institutions in the country becoming an increasing part
of our overall financial services market, by pushing high cost loans
through affiliates, but having no CRA obligations to provide services and
investments to communities that are by and large the kind of low and
moderate income communities that CRA was designed to benefited to close
gaping loopholes in the CRA regulation.

God bless you in your work.
Sincerely, Julie McNaughton

David McNaughton
926A Tainter Street
Menomonie, WI 54751-1546