FDIC Federal Register Citations

From: Dave Chrismon [mailto:habmsla@habitatmsla.org]
Sent: Wednesday, October 20, 2004 2:33 PM
To: Comments
Subject: RIN 3064-AC50 Comments

To Whom It May Concern:

Please do not change the Community Reinvestment Act.

There are wonderful banks and bankers who use the CRA to justify doing what they know is right. Without the CRA to level the field, banks will be just like big retailers – MOST of them don’t give much back.

In our community, Missoula Montana, we are faced with serious affordable housing issues. Local banks have done tremendous things to help many grass-roots organizations make a real difference. So many local lenders are great supporters of community initiatives. Others see the CRA as a drain on profit. As soon as the law is changed economic, political, stockholder issues will cut community reinvestment back to the lowest common denominator. If you take away ANY of the power of the CRA you will force our banking supporters to “lighten their load” to keep up with the competition.

Changing the CRA because the “small” lenders can’t keep up rewards failure of some lenders at the expense of the community needs. If the banks can’t do the paperwork, change the paperwork. If they don’t have the expertise, create a system that makes the process of reporting more efficient.

Arguments that the threshold should be raised because the average size of banks has grown since the law's inception, so that the change does not substantially affect the amount of bank assets covered by the law are insulting. It wasn’t ever about the size of assets in the pool. It is about community need and that has increased with inflation and the widening of the wealth gap.

Please do not change the Community Reinvestment Act.

Thank you for considering my opinion.

Dave Chrismon
435 E. Beckwith
Missoula, MT 59801