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Federal Register Publications

FDIC Federal Register Citations



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FDIC Federal Register Citations

VIA EMAIL

From: Arthi Varma

Sent: Tuesday, February 25, 2003 2:21 PM

To: Comments

Subject: RE: Proposed Rule Part 303

February 25, 2003

Robert E. Feldman

Executive Secretary

Attention: Comments/ES

Federal Deposit Insurance Corporation

550 17th St. NW

Washington DC 20429

RE: Proposed Rule Part 303

Dear Mr. Feldman:

The California Reinvestment Committee (CRC) opposes the FDIC's proposal

to waiveregulatory procedures on a case-by-case basis that are not required

by statute. CRC is a nonprofit membership organization of more than two

hundred nonprofit organizations and public agencies across California.

Working with community-based organizations, CRC advocates for the economic

revitalization of California's low-income communities and communities

of color. CRC promotes increased access to credit for affordable housing

and community economic development, and to financial services

for these communities.

If the FDIC waived regulations not required by statute, it is likely

that the agency will waive public comment, public notice requirements,

and other vital parts of the merger application process. Consequently,

important public input on bank mergers and the effects on local

communities will be limited. The public would have no recourse to a

federal agency when a merger affects the well-being of their community.

Public comments have motivated banks and federal agencies to address

weaknesses in lender community reinvestment and fair lending performance.

Therefore, eliminating public comment eliminates the chance to increase

bank lending and investing after mergers.

In order for a regulatory process to be fair to all parties, the federal

agency cannot waive a process for some banks and not others. Waivers on

a case-by-case basis are arbitrary and result in uneven regulatory

enforcement. CRC urges the FDIC to withdraw this proposal.

Sincerely,

Alan Fisher

Arthi Varma

Executive Director Policy Advocate

Last Updated 02/26/2003 regs@fdic.gov

Last Updated: August 4, 2024