FDIC Federal Register Citations

Abyssinian Development Corporation

October 19, 2004

Mr. Donald E. Powell
Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Mr. John M. Reich
Vice Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Mr. Thomas J. Curry
Director
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Mr. John D. Hawke, Jr.
Comptroller of the Currency
Office of the Comptroller of the Currency
250 E Street SW
Washington, DC 20219

Gentlemen:

Despite the successes locally and nationally of community investment, the banks and thrift institutions that provided the loans and investments to build new homes, businesses, and community facilities may no longer have the impetus to do so if you change the Community Reinvestment Act exam threshold.

It is understood that the Federal Deposit Insurance Corporation (FDIC) is considering changes to weaken the Community Reinvestment Act. Abyssinian Development Corporation (ADC) is a non-profit, comprehensive, community development organization dedicated to building the human, social and physical capital in Harlem, NY. With our partners in the private sector, ADC has created over 700 jobs, 1,000 units of affordable housing, over 100 homeownership opportunities, and has over 300 units in the pipeline for development, thereby, increasing property values and the quality of life for thousands of residents in our community. To lower the CRA threshold would have a detrimental effect on our economic revitalization initiatives and organizational capacity to continue to preserve, rehabilitate and revitalize affordable housing projects in the Harlem community.

It is estimated that 2,000 financial institutions would no longer be evaluated on their investment or services to low- and moderate-income communities. These banks have assets of nearly $ i trillion, and an estimated $5 billion of private capital for affordable housing and community development over the next few years.

These proposed rule changes would have a devastating effect on affordable housing investment in our community, city, state and throughout the nation.

We are very concerned that this step is being taken without Congressional action. Our legislators know that without financial partners, our efforts to revitalize our community would be nearly impossible.

The FDIC should be strengthening incentives for financial institutions to invest in the communities that provide homes, jobs, and economic opportunities to working families, and not taking them away:

Please do not raise the CRA exam threshold.

Sincerely
Sheena Wright
President & CEO