FDIC Federal Register Citations

Vermont Affordable Housing Coalition

From: Erhard Mahnke [mailto:erhardm@VTAffordableHousing.org]
Sent: Wednesday, October 20, 2004 1:46 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

On behalf of the Vermont Affordable Housing Coalition, a statewide membership organization representing over 70 non-profit developers, housing agencies, homeless service providers and low-income advocacy groups, I am writing to oppose the FDIC's proposal to allow banks with assets above $250 million to be examined as small banks under the Community Reinvestment Act. This policy would reduce lending, investments and services in low-income communities throughout the nation, but especially in rural states like Vermont.

The Community Reinvestment Act is a critical component to our state’s affordable housing and community development solutions. The proposed FDIC rule would exempt seven Vermont banks from full CRA review. Exempting many of our state’s critical partners from the effective and productive requirements currently in place will make them far less likely to invest in affordable housing and community development, for instance through the purchase of federal low income housing tax credits.

Because of its rural nature, Vermont is far more dependent on small, community banks to support affordable housing and community development. The proposed regulations will seriously undermine our small state’s efforts to provide decent, safe and affordable housing for all its citizens. We urge FDIC to withdraw its proposed rule.

Sincerely,

Erhard Mahnke
Coordinator

Vermont Affordable Housing Coalition
294 N. Winooski Ave., Suite 109
Burlington, VT