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FDIC Federal Register Citations Urban League of Greater Columbus, Inc. October 19, 2004 Mr. Robert E. Feldon RE: RIN 3064-AC50 Dear Mr. Feldman: As President and CEO of the Urban League of Greater Columbus, I am writing to urge you to withdraw the proposal of the Federal Deposit Insurance Corporation (FDIC) to quadruple (to $1 billion) the minimum asset size for applying the full Community Reinvestment Act (CRA) exam to state chartered non-member banks. The proposed change in the CRA regulations would have a devastating impact on lending, housing, and access to financial services in urban and rural communities across America. The CRA has been instrumental in increasing homeownership, boosting economic development, and expanding small businesses in the nation’s minority, immigrant, and low-and moderate-income communities. The FDIC proposal would dramatically diminish banks’ obligation to reinvest in their communities. It revises the CRA rules to make the less rigorous CRA exam applicable to an additional 900 banks with assets totaling $401 billion. Adoption of the FDIC measure is likely to mean the loss of hundreds of millions of dollars in loans, investments, and services for local communities and would disproportionately impact rural areas and small cities where the market presence of these mid-sized banks is often great. A key concern about the proposed FDIC rule is that it would greatly weaken or eliminate extremely important standards necessary to ensure that CRA is effective. The proposed change would weaken the lending test and also eliminate the investment and service parts of the CRA exam for FDIC supervised banks that have assets between $250 million and $1 billion. Another key concern is the FDIC plan to add a weak and trivial community development criterion in lieu of the investment and service tests applicable today (that collectively count for 50% of a bank’s CRA grade. This is a wholly inadequate substitute for the present exam standards). The new factor permits these banks to satisfy the community development criterion by choosing whether to provide community development loans, investments or services instead of assessing their performances for all three categories, as is currently required. This change is likely to result in a significant drop-off of lending, investments and services for affordable housing development, Low Income Housing Tax Credits, community service facilities such as clinics, and economic development projects. Other harmful elements of the FDIC proposal include the dramatic weakening of the lending test for midsize banks which could decrease access to credit for many Americans. We also fear that g development, Low Income Housing Tax Credits, community service facilities such as harmful elements of the FDIC proposal the elimination of the service test will have harmful consequences for low- and moderate-income consumers. According to the FDIC data, the rule change would mean that only 223 of 5,291 (about 4%) of all FDIC-supervised banks would continue to receive the full CRA exam. And finally, the FDIC proposal and the rule recently adopted by the OTS diminish the CRA requirements for midsize banks and work at cross-purposes with the Act’s statutory mandate. As you know, this mandate requires that banks, regardless of their asset size, have a continuing and affirmative obligation to serve the credit and deposit services needs of their local communities, including low- and moderate-income areas. The Urban League of Greater Columbus believes that growing small and medium-sized minority owned businesses is one of the best ways to close the wealth gap in America and provide real economic empowerment to our communities. The proposed FDIC rule would seriously undermine these efforts especially needed in our community. We should be strengthening the CRA, not weakening it! Therefore, I urge you to withdraw the FDIC proposal. Sincerely,
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| Last Updated 11/09/2004 | regs@fdic.gov | |