FDIC Federal Register Citations

From: Morris Zimmerman [mailto:mzimmerman@beckerwinston.com]
Sent: Wednesday, October 20, 2004 2:52 PM
To: Comments
Cc: deazim@earthlink.net
Subject: Community Reinvestment Act

FDIC

I would like to state that I am very concerned about the proposed changes to the Community Reinvestment Act. The new definition of “Small Banks” with reserves less than $1bil. is a change that will be very detrimental to most areas of our state (PA) and I assume most other states as well. It will most certainly undermine lending and investment in many of our small cities and towns and rural communities and the ability for people with lesser means to obtain access to financial equality or opportunities. It may even cause larger banks to start breaking down to the threshold limit for the additional benefits that are being offered. Banks have a tremendous ability to make profitable loans and they do not need the additional regulations lifted from them that actually are working to help poorer areas have access.

Years ago, Jane Jacobs revealed practices by banks unknown to most of the American public in a book called the Life and Death of the Great American City. The book identified one major factor in the decline of urban areas that could be easily remedied. This involved making sure that banks were responsible for serving poor communities and eliminating the practice of redlining. There has been great progress in this, but certainly not enough to go back to where we were and this change in definition will certainly lead back to that point where discrimination based on zip code was prevalent.

Please reconsider this proposed change.

Morrie Zimmerman

Anne Deaner

Philadelphia, PA 19104