FDIC Federal Register Citations

From: Bargoil, Richard [mailto:RBargoil@ci.charlotte.nc.us]
Sent: Tuesday, October 19, 2004 4:38 PM
To: Comments
Subject: FDIC Rule to Decrease CRA Obligations by Mid-Size Banks

To Whom It May Concern:

Proposed rule changes to increase the asset threshold to $1 billion or the CRA Streamlined Exam would remove from FDIC oversight midsize banks in approximately eight states and decrease oversight of midsize banks in another 36 states to unacceptable levels. This would appear to be contrary to Congress's intent for the FDIC to provide oversight such that sufficient levels of information are provided to accurately reflect lending institutions actions. The fact that banks with assets of $250 million to $1 billion would no longer be required to report lending data on small business and farm loans is an unacceptable proposal and leaves many communities across the country with limited means for accessing the performance of these mid-size lenders.

It is unfortunate that the FDIC may ultimately weigh the pros for changing the rule (orchestrated by the professional lobbyist) against the few speaking out against the proposed rule change. These changes so overwhelmingly affect low to moderate income families across America who has little knowledge of how such rule changes that are oblivious to their daily lives of just trying to stay ahead of next month's bills.

Having spent over 27 years working on behalf of such families it is somewhat embarrassing to see such assaults on many of the programs and protections established over the past 25 years.

Richard Bargoil
City of Charlotte
Economic Development Office
Office: 704.336.2142