FDIC Federal Register Citations

Nils Urman
3019 N. Calle Coronado
Nogales, Arizona 85621

October 15, 2004

Federal Deposit Insurance Commission
,

Dear Federal Deposit Insurance Commission:

Despite the successes of community development locally and nationally, the
banks and thrift institutions that provided the loans, services, and
investments to build new homes, businesses, and community facilities may
no longer have the impetus to do so if the FDIC raises the comprehensive
CRA exam threshold.

I agree with the National Congress for Community Economic Development that
this proposed change would have a devastating effect on affordable housing
and community development investment throughout the nation, particularly
in rural areas.

The FDIC proposes that the community development loans and investments in
rural areas can benefit any group of individuals, not just low- and
moderate-income individuals. Currently, banks have to finance affordable
housing and economic development projects that target low- and
moderate-income borrowers and neighborhoods. Under the proposed changes,
nothing in the CRA regulations would prevent banks from earning CRA points
for financing developments with no community development benefit
whatsoever. Moreover, the one part exams would cover 99 percent of all
FDIC-supervised banks located in rural areas.

President Bush’s comments promoting an "Ownership Society" are truly
disingenuous if the actions of officials he appointed are undermining
proven laws that revitalize communities, increase minority homeownership,
and increase small business ownership for women and minorities.

Please rescind your proposal.

Sincerely,

Nils Urman