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FDIC Federal Register Citations National
Federation of Community Development Credit Unions The National Federation of Community Development Credit Unions (the "Federation") represents 225 credit unions dedicated to serving low-income communities in 46 states, the District of Columbia, and Puerto Rico. CRA has been vital in helping our credit unions to better serve their low-income members, by encouraging banks to invest in our institutions. We would like to register our opposition to the adoption of the proposed CRA regulations on the grounds that the changes would hinder growth and expansion of financial services and accessibility to capital in low and moderate-income communities. The change in the community development test criterion, the increase in the asset limit of a .small bank, and the new definition of community development activities in rural areas all serve to diminish the effectiveness of the CRA for the CDFI industry and the communities CDFIs serve. We are most concerned with the proposed change in the criterion for banks with assets between $250 million and $ l billion, which will effectively reduce the incentives for hundreds of banks to carry out fruitful CRA activity. It is essential that these banks continue to be required to meet the community development lending, investment, and service tests. We also wish to register our opposition to the expansion of the definition
of community development to include all individuals in rural areas. In
our view, this contradicts the expressed original intent of the CRA to
prioritize serving the credit and deposit service needs of low- and moderate-income
areas. Sincerely yours
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| Last Updated 11/08/2004 | regs@fdic.gov | |