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September 15, 2004
Mr. Robert E. Feldman Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
As a concerned Maine citizen, I urge you to withdraw your proposed
chang'to tt Community Reinvestment Act (CRA) regulations. CRA has been
instrumental in increasing homeownership and economic development.
Your proposed changes are contrary to the CRA because they will slow
down the progress made in community reinvestment.
I understand that CRA exams look at the number of loans, investments,
and services that banks with more than $250 million in assets make to
low- and moderate-income communities. Your proposal will eliminate the
investment and service parts of the CRA exam for banks with assets
between $250 million and $1 billion.
To replace the investment and service parts of the CRA exam, the FDIC
proposes to add an inadequate community development criterion. Mid-size
banks with assets between $250 million and $1 billion would only have to
engage in one of three activities: community development lending,
investing or services. Currently, mid-size banks must engage in all
three activities. I believe that the end result will be significantly
fewer loans and investments in affordable rental housing, health
clinics, community centers, and economic development projects.
The elimination of the service test will also have harmful
consequences for low- and moderate-income communities. CRA examiners
will no longer expect mid-size banks to place bank branches in low- and
moderate-income communities. Mid-size banks will no longer make efforts
to provide affordable checking and savings accounts to consumers with
modest incomes. In addition, your proposal eliminates small business
lending data reporting for mid-size banks. Without data on lending to
small businesses, the public cannot hold mid-size banks accountable for
responding to the credit needs of small businesses.
You propose that community development activities in rural areas can
benefit any group of individuals instead of only low- and
moderate-income individuals. Since a large number of rural residents are
rich, your proposal threatens to divert community development activities
away from the low- and moderate-income communities and consumers that is
the focus of CRA.
In conclusion, your proposal is directly the opposite of CRA's
mandate of imposing an obligation to meet community needs. Two other
federal agencies did not embark upon the path you are taking because
they recognized the harm it would cause. CRA is too vital to be gutted
by regulators. If you do not reverse your proposed course of action, I
will ask that Congress halt your efforts before the damage is done.
Sincerely
Michael Brawn
Cc: National Community Reinvestment Coalition
President George W. Bush
Senators John Kerry and John Edwards |
