FDIC Federal Register Citations

From: Barb Clint [mailto:bclint@parkworks.org]
Sent: Thursday, October 14, 2004 3:19 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

To whom this may concern:

I am a fifty year old community planner who is old enough to remember the days prior to our Community Reinvestment Act legislation. When I first became involved in community building work, bank and insurance red-lining were the rule rather than the exception in many of the low income--and African American--neighborhoods in Cleveland, Ohio. I recall with pride my tangential involvement in some of the earlier efforts to bring the banks and insurance companies to the table in Cleveland and know, first hand, that the threat of CRA challenges served to move many dialogs along in my town.

What has transpired in Cleveland's neighborhoods over the past 30 years is nothing short of miraculous. Thousands of housing units have been renovated and hundreds of others built. Storefronts along key commercial corridors have been improved and entirely new shopping centers developed. But even more significant are the true partnership relationships that have developed between locally-based community development organizations and our bankers. Or at least with the Community Reinvestment arms of Cleveland's major banks.

Community Reinvestment bankers have demonstrated themselves to be very adept deal makers...recognizing good opportunities for their respective institutions that might very well have been by-passed without their involvement. My concern is that, in this highly competitive bank environment, once the "teeth" of the CRA exam is removed from the program, cost-cutting of CRA personnel will follow. As it remains largely within the CRA offices of our local banks that the important neighborhood deals are being structured, this would be a tremendous set-back to local community revitalization efforts.

I implore you to hold the line on this program's existing asset limit of $ 250 million or above triggering a full CRA audit. The future viability of many urban neighborhoods and small communities across the country depend on it.

I thank you for your consideration of my remarks.

Sincerely,
Barb Clint