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YERINGTON PAIUTE TRIBE
September 20, 2004
Mr. Robert E. Feldman Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street NW Washington, DC 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
I am a concerned citizen opposed to watering down CRA (Community
Reinvestment Act) requirements for mid-sized banks. CRA is vital for
increasing homeownership and economic development in lower-income
communities. Your proposed changes will halt the progress that has been
made.
I understand that banks with over $250 million in assets must be
tested on their number of loans, investments, and services to low- and
moderate-income communities. But your proposal would eliminate the
investment and service requirements for all banks with under $1 billion
in assets. This will result in significantly fewer loans and investments
in affordable rental housing, health clinics, community centers, and
economic development projects.
The proposed changes, which would make smaller banks less accountable
for their community reinvestment activity, alarm us, as banks are
finally waking up to the investment opportunities in Indian country.
Indian country has made strides with the help of banks in the mortgage
arena—we saw conventional mortgage activity increase for Native
Americans in 2003. We believe that the strength of the current law has
been instrumental to this development.
You propose that community development activities in rural areas can
benefit any group of individuals instead of only low- and
moderate-income individuals. Since banks will be able to focus on
affluent residents of rural areas, your proposal threatens to divert
community development activities away from the low- and moderate-income
communities and consumers that CRA targets. In our rural community, that
reduction amount of community development activity would earn CRA points
even if it benefits
affluent consumers and communities. What's left over for the low- and
moderate-income rural residents are the crumbs of a shrinking CRA pie of
community development activity.
Your proposed changes directly oppose CRA's mandate of imposing a
continuing and affirmative obligation to meet community needs. Your
proposal will dramatically reduce community development lending,
investing and services. You compound the damage of your proposal in
rural areas, which are least able to afford reduction in credit and
capital. You also eliminate critical data on small business lending.
If your agency is serious about CRA's continuing and affirmative
obligation to meet credit needs, you would be proposing additional
community development and data reporting requirements for more banks
instead of reducing existing obligations. A mandate of affirmative and
continuing obligations implies expanding and enlarging community
reinvestment, not significantly reducing the level of community
reinvestment.
CRA is too vital to be gutted by regulatory fiat and neglect. We hope
that the FDIC, which earlier this year had the vision to hold a
conference on the "unbanked," will not now introduce changes detrimental
to the most "unbanked" population of all.
Sincerely,
Wayne M. Garcia, Tribal Chairman
Yerington Paiute Tribe
Cc: National American Indian Housing Council (fax: 202-789-1754)
National Community Reinvestment Coalition (fax: 202-628-9800)
President George W. Bush (White House fax: 202-456-2461)
Senators John Kerry (fax: 202-224-8525)
Senator John Edwards (fax: 202-228-1374) |
