ATLANTA
NEIGHBORHOOD DEVELOPMENT PARTNERSHIP
August 30, 2004
Donald E. Powell
Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
John M. Reich
Vice Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Thomas J. Curry
Director
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
John D. Hawke,
Jr.
Comptroller of the Currency
Office of the Comptroller of the Currency
250 E Street, SW
Washington, DC 20219
Re: Community Reinvestment Act
Dear. Sirs:
The
Community Reinvestment Act (CRA) of 1977 has been, the largest-contributor
over time other than the Low Income Housing Tax Credit, to the
revitalization of America's cities and rural areas. In the world
of changing economics and reduced Federal funding things that
require investments in our lowest income neighborhoods are even
more necessary than before. The progress that has been made in improving
our communities could not have been possible without the banks and
thrift institutions that provided loans and investments to build
new homes, businesses and community facilities.
The idea of raising
the CRA exam threshold will erase the need for small banks (under
$1 billion in assets) to invest in all of
the communities that they receive deposits from. Experience shows
us that lending institutions need incentives to make loans
arnd investments inunderserved areas.These areas became underservedwhen
there were no incentives such as CRA. The proposed change will
have a devastating effect on affordable housing investment in our state
and throughout the nation particularly in rural areas. This
comes at a time when the number two concern for most Americans affordable
housing
behind health care.
The Atlanta Neighborhood Development Partnership has been In business
since 1991 and has either built or invested in over 7,500 units of
affordable housing. Financial Institutions have been an integral
part of this work. We believe that the regulating authorities should
be strengthening incentives for financial institutions to invest
in communities that have been overlooked in the past. Please do not
raise the CRA exam threshold.
Sincerely
Raymond L. Kuniansky, Jr.
Chief Operating Officer
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