FDIC Federal Register Citations

RE: RIN 3064-AC50, Community Reinvestment

Dear Mr. Feldman:
I am writing to express my opposition to watering down CRA (Community Reinvestment Act) requirements for mid-sized banks. The proposed changes are in direct opposition to the CRA mandate that requires lenders to meet community needs.
I have had extensive experience working closely with local banks which were fulfilling their CRA requirements within the community, both as an executive director of large non-profit organization in Illinois, and as a community volunteer/leader for many years in Wisconsin. Mid-size banks played an essential role in increasing homeownership, other housing opportunities and economic development in lower-income communities. As you are undoubtedly aware, a great number of persons who benefit from CRA are employed but still have a limited amount of money to spend on housing.
Further, community economic development itself has often been a direct result of CRA requirements, such as the development of health clinics, community centers and other community benefiting structures and services. My observation is that often it is only the mid-sized banks that will move into lower-income communities and provide services there. For all these reasons and more, changes proposed by the FDIC would have a very negative impact on such communities.
The changes proposed would allow mid-sized banks to choose which one of three community development activities they would undertake resulting in less community development activity. One problem with this, of course, is that community problems and needs are multi-faceted and must be approached from a variety of avenues to be effective.
I am also very concerned that community development activities in rural areas would be changed in a way that would allow banks to work with affluent residents of rural areas rather than the lower income consumers CRA targets. One problem that I've observed is that as higher income persons move into rural areas, essentially developing new "suburbs," the needs of lower and moderate income residents are often put at risk in the milieu of rising housing costs.
This proposal would also eliminate publicly available data on the small business lending of mid-sized banks. Such data is essential for enabling community groups and citizens to hold banks accountable for lending to small businesses in their neighborhoods.
As stated above, the proposed changes are in direct opposition to the CRA mandate to require lenders to meet community needs. CRA is an essential tool for the purposes for which it was created – the changes proposed would seriously undermine it. Please drop this proposal.

Donna Ferency
10558 W. Cortez Cr., #15
Franklin, WI 53132

Cc: National Community Reinvestment Coalition
President George W. Bush
Senators John Kerry and John Edwards