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FDIC Federal Register Citations



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FDIC Federal Register Citations

Community Development Corporation of Long Island, Inc.

From: Teresa Arellano
Sent: Monday, August 30, 2004 2:56 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

TO: FDIC

My name is Wilbur Klatsky and I am the President of Community Development Corporation of Long Island, Inc. (“CDC”), a not-for-profit with over 35 years of a track record. We serve a population of approximately 3 million and the corporation has a broad mission responding to the housing needs of the underserved and providing capital to small businesses who are being declined by the traditional banking community. We continue to maintain a strong relationship with all of the money center banks as well as the regional “small” banks.

The not-for-profit industry is doing the heavy lifting that traditional banks both small and large find not within their strategic plans. We fully understand that the banking community must report to their investors and they are required to provide a satisfactory return. This profit is critical to their livelihood. The not-for-profit industry devotes its resources to these market niches, i.e. housing and small businesses, which do not meet the banking community’s financial goals. CDC and other not-for-profits, both locally and nationally, have secured much of these needed resources from our banking partners. This has been a partnership of material interest. Our banking partners within our region include money center banks such as Citibank, JPMorgan Chase, Bank of New York, HSBC, Bank of America as well as local, regional banks such as Bank of Smithtown, Astoria Federal Savings, New York Community Bank, Ridgewood Savings Bank and First Bank of Long Island to name but a few.

While it is difficult to ascertain how much of this on going financial support is a direct result of the Community Reinvestment Act, it is certainly clear that it has been a major influence meeting the Community Reinvestment Act services or investment test. From our perspective, the trend of gutting the Community Reinvestment Act by the proposed FDIC and OTC changes is a race to the bottom. If these regulations are approved, it is only a matter of time that the Federal Reserve and the OCC follow. What makes this all the more critical is the most recent information from the recent census reports which reveal that those in poverty are growing astronomically in our country.

The safety net we are all speaking about is in the process of being withdrawn. We are categorically recommending that the current Community Reinvestment Act not be revised to permit the so called smaller banks to be relieved of their obligations.

I am available for any additional comments, if required.

Wilbur Klatsky
Community Development Corporation of Long Island, Inc.
2100 Middle Country Road - Suite 300
Centereach, New York 11720


 

Last Updated 08/31/2004 regs@fdic.gov

Last Updated: August 4, 2024