FDIC Federal Register Citations

October 14, 2004

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 West 17th Street NW
Washington, DC 20429

Dear Mr. Feldman:

The purpose of this letter is to ask you to withdraw the proposal of The Federal Deposit Insurance Corporation to quadruple the minimum asset size for applying the full Community Reinvestment Act (CRA) exam to state chartered non-member banks.

CRA has been instrumental in the implementation of Utah's first statewide Individual Development Account (IDA) Network. IDAs create opportunities for low-income Utahns to increase their assets through matched savings accounts used for homeownership, post secondary education including vocational training and develop savings habits that will maintain financial security.

The Utah Financial Community has been an integral part of the creation and implementation of UIDAN. They provide match money, financial literacy and are active participants in the Executive Advisory Committee and its subcommittees, This partnership strengthens the ability of low-income people to move into the financial mainstream.

The Utah IDA Network, UIDAN, is a statewide collaborative that allows low-income individuals to access individual development accounts through a variety of non-profit partners. Utah Issues performs and coordinates the program operation functions and thereby makes it possible for other non-profit partners to offer the IDA service to their clients without the expense of developing and staffing a separate program.

IDAs bring new, often unbanked customers to traditional banking. The benefits are limitless. Here are a few benefits of a CRA supported program that will strengthen our. communities and bring new customers to traditional banking providers.

1. Every public dollar invested in IDAs generates $5 dollars-measured in new businesses and jobs, increased earnings, new and improved homes, higher tax receipts, reduced welfare expenditures, and increased educational achievements. Asset accumulation affects individuals' confidence about the future, willingness to defer gratification, avoidance of risky behavior, and investment in their community.
3. In families where assets are owned, children do better in school, voting participation increases, and family stability improves. Reliance on public assistance decreases as families use their assets to access higher education and better jobs, reduce their housing costs through ownership, and create their own job opportunities through entrepreneurship.
4. They promote economic household stability and educational attainment.
5. (DAs decrease the risk of intergenerational poverty transmission, increase health and satisfaction among adults, and increase local civic involvement.
6. IDAs are long-term solutions that go beyond traditional income-maintenance and emergency assistance approaches to poverty.

The following financial institutions have supported the Utah IDA Network through funds for match money, financial literacy training and mentoring, fiscal oversight of Network activity and business expertise. The synergy of private and public entities working together has created a powerful partnership that reaches beyond traditional income-maintenance and emergency assistance approaches to poverty.

Advanta Bank
American Express Center for Community Development
Associates Capital Bank
GE Capital Financial
GMAC Commercial Mortgage Bank
Merrick Bank
Merrill Lynch
Morgan Stanley Bank
Pitney Bowes Bank
Transportation Alliance Bank
UBS
Universal Financial Corporation
U.S. Bank
Wells Fargo
Wright Express Financial Services
Zions Bank

On behalf of the low and moderate income people of Utah, I urge you to withdraw this proposal and maintain the effective relationships that exist between the financial community and the Utah Individual Development Account Network.

Sincerely,
Martha D. Wunderli
Utah Individual Account Network Coordinator
Utah Issues
Salt Lake City, UT

cc: Senator Orrin Hatch
Senator Robert Bennett