FDIC Federal Register Citations

San Diego Affordable Housing Coalition

From: Richard A. Lawrence [mailto:ral1015@juno.com]
Sent: Saturday, October 09, 2004 12:18 PM
To: Comments
Cc: Jim.Bliesner@sdcounty.ca.gov
Subject: Community Reinvestment Act

Mr. Robert Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corp.
550 17th Street NW
Washington DC, 20429-9990
Re: RIN 3064-AC50

Dear Mr. Feldman;

The purpose of this letter is to express opposition to your proposal to
significantly weaken the Community Reinvestment Act. You are proposing
reduced CRA obligations for banks between $250million and $1 billion in
assets. The reduced requirements would include modification of testing
requirements on the number of investments and services in low and
moderate-income areas. The second would allow mid sized banks to reduce
their community development activities.

There is precious little impact a local community can affect upon the
banking community as matters stand now, and to make this situation worse
by exempting smaller banks is unthinkable.

This ruling would apply to all locally headquartered banks in San Diego
and would create an unequal playing field in the banking industry in this
region. It would allow for market domination in major geographical areas
of the County for specific products and services. It would exclude ethnic
and lower income residents from basic banking services and thereby
directly violate the federal Community Reinvestment Act and quite
possibly the Fair Housing Act.

We urge you to rescind your proposal to reduce CRA related policies
toward smaller banks.

Sincerely,
Richard Lawrence, Coordinator
S. D. Affordable Housing Coalition