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Community Economic Development Association of Michigan From:
Tony Lentych
[mailto:TLentych@msn.com]
Sent: Monday, April 05, 2004 6:12 PM
To: regs.comments@occ.treas.gov; regs.comments@federalreserve.gov;
Comments;
regs.comments@ots.treas.gov
Cc: jsilver@ncrc.org
Subject: Changes to CRA
April 2, 2004
Docket No. 04-06
Communications Division
Public Information Room, Mailstop 1-5
Office of the Comptroller of the Currency
250 E St. SW,
Washington 20219
Docket No. R-1181
Jennifer J. Johnson
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington DC 20551
Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th St NW
Washington DC 20429
Regulation Comments, Attention: No. 2004-04
Chief Counsel’s Office
Office of Thrift Supervision
1700 G Street NW
Washington DC 20552
Dear Officials of Federal Bank and Thrift Agencies:
The Community Economic Development Association of Michigan (a
coalition of 240 members who work to rebuild neighborhoods and
communities) stands with the National Community Reinvestment Coalition
in opposition to the proposed changes to the Community Reinvestment Act
(CRA) regulations. I am sure that by now you have received the detailed
analysis from NCRC that supports this decision. We concur on all points.
It is my hope that you will realize that these proposed changes may
halt the progress that we have made in many communities throughout
Michigan and around the country. We could have not accomplished much of
anything without the help of several financial institution partners. And
to be perfectly clear, most of those financial institutions were, in
fact, “motivated” to be involved in these communities through CRA. Any
changes to these regulations should be weighed against the possible loss
in community or external benefit in addition to any benefit (internal)
claimed by those being regulated.
Thank you for your careful consideration on this matter – there has
to be a better way to compromise.
Respectfully submitted,
Tony Lentych,
Executive Director
Tony Lentych, CEDAM
Community Economic Development Association of Michigan
1000 South Washington Avenue, Suite 101
Lansing, Michigan 48910-1647
517-485-3588, ext. 140
www.cedam.info
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