FDIC Federal Register Citations

From: Chris Oakley [mailto:COAKLEY@carolstream.org]
Sent: Tuesday, October 19, 2004 4:42 PM
To: Comments
Cc: Ross Ferraro
Subject: RIN 3064-AC50

Dear Mr. Feldman:

I am adamantly opposed to the weakening of the Community Reinvestment Act requirement for medium-sized banks. The CRA has been a critical force in helping to promote homeownership and economic stimulus through investment in low-income communities and neighborhoods. The changes you propose to CRA will halt and in some ways reverse economic progress made in fragile communities throughout our great nation. Your proposal to eliminate the investment ans service requirement for ALL banks with assets under $1Billion will no doubt reduce the number of laons and investments for afforadable housing initiatives, community health clinics, neighborhood centers as well as sorely needed economic development projects in areas in need of financial stimulus.

Amending the CRA to allow mid-sized banks to be able to choose which community development activities they will undertake is unwise. Communities know what they need best and shifting the assessment of need from the community leaders to the banks will surely result in less community development loans made, investment undertaken and services provided. Additionally, the proposed changes to the CRA to allow banks in rural areas to undertake community development projects that no longer target low and moderate income individuals exclusively is an abberation to the intent and spirit of the original legislation. Also, your proposal to eliminate the requirement to allow the investment activity of mid-sized banks to small business to be available for public review is regrettable. In essence, your changes would allow banks to choose whether they want to be a integral to the vitality of the community where they have a business presence.

Please follow the admonitions of the two federal agencies that stated your proposed changes to the CRA will harm residents, businesses and institutions from low-income communities. Please withdraw your proposal.

Mayor Ross Ferraro
Carol Stream, Illinois