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FDIC Federal Register Citations The Council of The City of New York October 20, 2004 Mr. Robert E. Feldman, Executive Secretary Dear Mr. Feldman: We wish to declare our opposition to the proposed revisions to 12CFRpart 345 implementing the Community Reinvestment Act (CRA) (69FR 51611 August 20, 2004). It is our understanding that these revisions would, in effect, change the definition of “small banks” by raising the asset threshold for these banks from $250.0 million to $1.0 billion, regardless of the bank’s affiliation with another financial institution. Presently, “small banks” with assets under $250.0 million are exempt from strict compliance with regulations of the Act. With the proposed revisions, a larger number of so- called “small banks” would fall under weaker regulations. These changes would result in a less stringent examination of these smaller banks’ participation in the Community Reinvestment Act; thus reducing their effective contributions to the development of the communities they serve. It is also our understanding that broader criteria for community development would be established for these “small banks” that could also reduce their role in aiding vitally needed projects. We are asking, therefore, that our comments are given every positive consideration before the F.D.I.C. makes its decision. Sincerely, LEROY COMRIE MIGUEL MARTINEZ DAVID I. WEPRIN MELINDA KATZ ROBERT JACKSON ALAN GERSON JOHN C. LIU LARRY B.SEABROOK YVETTE D. CLARKE DIANA REYNA JAMES GENNARO THE COUNCIL
Of
The City of New York |
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| Last Updated 11/11/2004 | regs@fdic.gov | |