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NEW HAMPSHIRE HOUSING September 28, 2004
Mr. Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
I am concerned about proposed rule changes which would effect the
application of the Community Reinvestment Act (CRA) to mid-sized bamls.
CRA is vital for increasing homeownership and economic development in
lower-income communities. However, 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 could result in significantly fewer loans and
investments in affordable rental housing, health clinics, community
centers, and economic development projects.
In the modified exam, you would allow mid-sized banks to choose which
community development activities they will undertake. Right now, these
banks must make community development loans, investments, and services.
Your proposed test allows banks to choose only one of the three
activities. The result may be less community development activity.
You also propose that community development activities in rural areas
should benefit any group of individuals instead of only low- and
moderate-income individuals. But this will allow banks to focus on
affluent residents of rural areas rather than the lower income consumers
CRA targets. Finally, you would also eliminate publicly available data
on the small business lending of mid-sized banks. Without such data,
community groups and citizens cannot hold banks accountable for lending
to small businesses in their neighborhoods.
Your changes would undercut CRA's mandate to require lenders to meet
community needs. Please consider your proposal to change the CRA
requirements for smaller institutions.
Sincerely,
Claira P. Monier
Executive Director
New Hampshire Housing
Bedford, NY |
