Home > Regulation & Examinations > Laws & Regulations > FDIC Federal Register Citations |
|||
FDIC Federal Register Citations From: BARBARA GREEN [mailto:cgbg@clatskanie.com] BARBARA GREEN October 13, 2004 Robert E. Feldman To Robert Feldman: I am a child care advocate opposed to watering down CRA (Community
Reinvestment Act) requirements for mid-sized banks. CRA is vital for
economic development in lower-income communities, and investing in child
care is a highly effective community development strategy. However, your
proposed changes will halt the progress that has been made. Under the proposals, the community investment requirements for banks with
assets between $250 million and $1 billion will be greatly weakened. These
banks would no longer be tested on the number of investments and services to
low- and moderate-income communities. In addition, these banks would be
allowed to choose which one development activity – among lending,
investment, and services – they will undertake; today they must engage in
all three. These watered down requirements will result in significantly
fewer loans and investments in child care centers, family child care homes,
and other economic development projects. The proposal also would allow community development activities in rural
areas to benefit any group of individuals instead of specifically low- and
moderate-income individuals. But this will allow banks to cherry-pick and
focus on affluent residents of rural areas rather than the lower-income
consumers CRA targets. Your changes directly conflict with CRA’s mandate to require lenders to meet a community’s needs for services such as child care, health clinics, and housing. CRA is too important to be gutted. Please withdraw your proposal like the two other federal agencies that recognized its harm to underserved communities. Sincerely, BARBARA GREEN
|
||
Last Updated 10/30/2004 | regs@fdic.gov |