FDIC Federal Register Citations

October 20, 2004

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

Re: RIN3064-AC50

Dear Mr. Feldman:

The Coalition for Affordable Housing and the Environment is comprised of approximately forty environmental, planning and housing organizations. Our mission is to promote affordable housing opportunities, environmental protection, and sound planning.

We urge you to withdraw the proposal of the Federal Deposit Insurance Corporation to quadruple (to $1 billion) the minimum asset size for applying the full Community Reinvestment Act (CRA) exam to state chartered non-member banks. We make this request because implementing this proposal would undermine all of our goals.

Most obvious, of course, is the impact this proposal would have on low- and moderate-income communities. New Jersey has an affordable housing crisis, and minimizing the review of mortgage lending for more than one-third of New Jersey’s banks will exacerbate rather then reduce this crisis. In addition, the changes to the community development criterion will likely result in a significant drop-off in lending, investments and services for affordable housing development, Low Income Housing Tax Credits, and community service facilities.

Less obvious, but no less important, is the impact these changes will have on New Jersey’s environment. New Jersey, through its State Development and Redevelopment Plan, is working to revitalize its small cities and older suburbs, the communities that will be disproportionately affected by these changes. Without the capital needed for community development corporations and small businesses to jump start revitalization, New Jersey’s trend of developing on greenfields will continue, and the state’s air and water quality, already degraded by decades of sprawl, will worsen.

Because of this proposal’s negative impact on urban and older suburban communities, on low- and moderate-income families, and on New Jersey’s air and water quality, we urge you to withdraw this proposal.

Sincerely,
Paul D. Chrystie
Executive Director

COALITION FOR AFFORDABLE HOUSING AND THE ENVIRONMENT
145 WEST HANOVER STREET, TRENTON, NJ 08618
Phone: (609) 278-5656 Fax: (609) 393-9016
E-mail: info@cahenj.org
Web: www.cahenj.org