FDIC Federal Register Citations

From: Joann Hauger [mailto:joannhauger@communityhousingresources.org]
Sent: Tuesday, October 19, 2004 3:44 PM
To: Comments
Subject: Oppose Efforts to Weaken CRA RIN number 3064-AC50

Joann Hauger
500 E. Thomas Road, Suite 300
Phoenix, Arizona 85012

October 19, 2004

Federal Deposit Insurance Commission

Dear Federal Deposit Insurance Commission:

Despite the successes of community development locally and nationally, the banks and thrift institutions that provide the loans, services, and investments to build new homes, businesses, and community facilities may no longer have the impetus to do so if the FDIC raises the comprehensive CRA exam threshold.

As a HUD-approved housing counseling agency serving low-income, first-time homebuyers, Community Housing Resources of Arizona depends upon the special CRA mortgage loans provided by small banks in the Phoenix metro area. Without CRA requirements, many of the 3,500 low-income families who have achieved homeownership through our programs would not be homeowners today.

I agree with the National Congress for Community Economic Development that this proposed change would have a devastating effect on affordable housing and community development investment throughout the nation, particularly in rural areas. The proposed community development criterion is not a replacement for ensuring adequate services and investment reach low- and moderate-income individuals and communities. Successful development must be targeted to lower income individuals and/or communities, not rural areas generally.

Please rescind your proposal.

Sincerely,
Joann Hauger