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FDIC Federal Register Citations

National Black Chamber of Commerce

From: Harry Alford [mailto:halford@nationalbcc.org]
Sent: Wednesday, October 20, 2004 11:57 AM
To: Comments
Subject: FDIC Rule to Decrease CRA Obligations to Banks

While this rule may not affect markets that are comprised solely of major regional and national banks, there are many communities that capital access evolves around smaller banks. Despite the successes of community development locally and nationally, the banks and thrift institutions that provided the loans, services, and investments to build new homes, businesses, and community facilities may no longer have the impetus to do so if the FDIC raises the comprehensive CRA exam threshold.

President Bush's comments on promoting an "Ownership Society" will be truly threatened if the actions of officials seek to undermine proven laws that revitalize communities, increase minority homeownership, and increase small business ownership for women and minorities.

We agree that this proposed change would have a devastating effect on affordable housing and community development investment throughout the nation, particularly in urban and rural areas. Small communities who are not fortunate enough to have corporate banks will lose support for local projects that reinvest in urban and rural centers across the nation.

The FDIC proposes that the community development loans and investments in rural areas can benefit any group of individuals, not just low and moderate income individuals. Currently, banks have to finance affordable housing and economic development projects that target low and moderate income borrowers and neighborhoods. Under the proposed changes, nothing in the CRA regulations would prevent banks from earning CRA points for financing developments with no community development benefit whatsoever.

Moreover, the one part exams would cover 99 percent of all FDIC supervised banks located in rural areas. Minorities significantly populate rural areas throughout the United States.

Please rescind your proposal. CRA works, it is not broken - so why mess with it.

Harry C. Alford
President/CEO
National Black Chamber of Commerce
Washington, DC 20036

 


Last Updated 11/16/2004 regs@fdic.gov

Last Updated: August 4, 2024