FDIC Federal Register Citations

Lexington-Fayette Urban County Government

Robert Feldman
Executive Secretary
Attention: Comments/Legal ISS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429-9990

RE: RIN 3604-AC50

Dear Mr. Feldman:

I am opposed to the watering down of CRA (Community Reinvestment Act) requirements for mid-sized banks. CRA is vital for increasing homeownership and economic development in lower-income communities. However, your proposed changes will halt the progress that has been made.

I understand that banks with over $250 million in assets must be tested on their number of loans, investments and services to low and moderate communities. But your proposal would eliminate the investment and service requirements for all banks with under $1 billion in assets. This will result in significantly fewer loans and investments in affordable rental housing, health clinics, community centers and economic development projects.

In the watered-down exam, you would allow mid-sized banks to choose which community development activities they will undertake. Right now, these banks must make community development loans, investments and services. Your proposed test allows banks to choose only one of the three activities. The result will be less community development activity.

Finally, you would also eliminate publicly available data on the small business !ending of mid-sized banks. Without date, community groups and citizens cannot hold banks accountable for lending to small businesses in their neighborhoods. I regularly review that data now.

Your changes directly oppose CRA's mandate to require lenders to meet community needs. CRA is too important to be gutted. Please drop your proposal like the two other federal agencies that recognized its harm to underserved communities.

Sincerely
Teresa Ann Isaac
Mayor