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FDIC Federal Register Citations City
of Dover (DE) Mr. Robert E. Feldman I am opposed to the watering down of the CRA (Community Reinvestment Act) requirements for mid-sized banks. The CRA is vital for increasing homeownership and economic development in lower-income communities. However, your proposed changes will halt the progress that has been made to date. I understand that banks with over $250 million in assets must be tested on their number of loans, investments and services to low-and-moderate income communities. But your proposal would eliminate the investment and service requirements for all banks with under $1 billion in assets. This will result in significantly fewer loans and investments in affordable rental housing, health clinics, community centers and economic development projects. In the watered-down exam, you would allow mid-size banks to choose which community development activities they will undertake. Right now, these banks must make community development loans, investments and services. Your proposed test allows banks to choose only one of the three activities. The result will be less community development activity. You also propose that community development activities in rural areas should
benefit any group of individuals instead of only low and moderate income
individuals. But this will allow banks to cherry-pick and focus on affluent
residents of rural areas rather than the lower income consumers CRA targets.
Finally, you would also eliminate publicly available data on the small business
lending of mid-sized banks. Without data, community groups and citizens
cannot hold banks accountable for lending to small businesses in their neighborhoods. Sincerely,
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| Last Updated 11/18/2004 | regs@fdic.gov | |