FDIC Federal Register Citations

Dear FDIC,

Mr. Feldman:

As an officer of the Needmor Fund, whose mission it is to invest in the communities of low income people across America, I know first hand how devastating the proposed FDIC rule change would be. CRA is one of the last resources available to these people to fund housing intiatives and facilitate small business lending. Indeed, in this elections cycle, with all of its talk of helping small businsses, the removal of CRA lending from these communities would be the height of hypocrisy.

CRA is vital for increasing homeownership, promoting minority business ownership, meeting the community development needs of struggling communities and support the capital requirements of nonprofits.

I am very concerned that the proposed Federal Deposit Insurance Corporation (FDIC) rule would be harmful to the community in which I live and hundreds of town, cities and rural areas across the United States.

In the new watered-down process for mid-size banks, FDIC would allow these financial institutions to pick and 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 were I live. That will mean fewer jobs, fewer homes and fewer community services.

As I understand it, the Community Reinvestment Act was made law to require lenders to meet community needs. Your rule proposal flies directly in the face of this requirement. It would harm my community, the quality of my life and tens of thousands of Americans like me. I urge you in the strongest possible terms to drop this hurtful rule proposal.

Daniel Stranahan

Seattle, WA