FDIC Federal Register Citations

From: Lani Matthews [mailto:lmatthews@tetonwyo.org]
Sent: Wednesday, October 13, 2004 4:42 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

Thank you for the opportunity to comment on this proposed revision to the Community Reinvestment Act. As an employee of a local government housing authority program in a rural high cost resort community I believe the proposed reduced requirements would hurt the low and moderate income citizens we continuously strive to serve. In other areas of Wyoming and Idaho that we are familiar with, I would anticipate even a greater community impact due to the type of smaller institutions serving this customer and citizen base.

Jackson Hole has a typical resort community character with many lending institutions of all sizes. In addition, we have the state income tax shelter and high non-resident population. Most of the banks are owned by local investors. Due to the dynamics of the environment personal incomes are reported as some of the highest median incomes of the nation. Disparity is extreme with many middle and low income wage earners in the service and other sectors. Minimum CRA requirements are easily met just by the shear numbers of low to moderate incomes and their need to acquire mortgage product.

Example 1: Recently the competitive interest market over a longer term has created an interest in participation with low income buyers purchasing deed restricted product or building deed restricted product. In past years, most of these loans were handled SOLELY by the State Housing Finance Agency loan program (Wyoming Community Development Authority) and the few locally servicing lenders. Even today, with the competitive market, many of the smaller credit unions and others will not consider low income deed restricted product. We know underwriting requirements and service time is required to meet all of these standards and simply is not attractive to them.

Example 2: Homebuyer education is provided to our community through a progressive compressed video teleconference program through a partnership with Fannie Mae, Wyoming Community Development Authority and others. This is effective with the rural nature of the state and is taught on a monthly basis. Many communities are noticeably absent for lack of facility sites and local area hosts. Typically the hosts change each month and include real estate agents, lenders, and others. In Jackson Hole, this program was not offered until 2 years ago when our government staff began hosting this for overtime pay. While we have attempted to bring area lenders and others to assist and participate, reception has been lukewarm and to date, only one lender has participated on two occasions. Many other communities report similar problems despite the advancement of technology and important opportunity.

While these examples might be small, I believe there are many additional examples and believe any reduction in the requirement will bring greater challenges for the low and middle income consumers particularly in the rural area of our country. Our community and rural population as a whole would benefit from increased standards for CRA credit far greater than any reduction.

Thank you for your consideration.
Lani Matthews
Teton County Housing Authority
Jackson, WY