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Oregon Housing & Community Services
From: Jack Kenny [mailto:jack.kenny@hcs.state.or.us]
Sent: Tuesday, April 06, 2004 1:52 PM
To: Comments
Subject: Interagency Notice of Proposed Rulemaking, Community Reinvestment
Act
Jack Kenny
PO Box 14508
Salem, OR 97309
April 6, 2004
Federal Deposit Insurance Corp
Robert Feldman, Executive Secretary
550 17th Street NW
Washington, DC 20429
Dear Insurance Corp:
Docket No. 04-06
Office of the Comptroller of the Currency
Docket No. R-1181
Board of Governors of the Federal Reserve System
Attention: Comments
Federal Deposit Insurance Corporation
Regulation Comments
Office of Thrift Supervision
To Whom it May Concern:
Oregon Housing & Community
Services (OHCS) appreciates the opportunity to
comment on the Joint Notice of Proposed Rulemaking regarding the Community
Reinvestment Act (CRA) [69 FR 5729].
While we commend your efforts regarding the expansion of data collection,
the proposal to change the definition of "small banks" will
undermine the
intent of the law in providing equitable lending in underserved
communities. We cannot support this proposal and we urge you to withdraw
the proposed definition of small banks.
Change in the Definition
of "Small Banks"
The agencies propose to make approximately 1,100 banks subject to
less
rigorous CRA exams by changing the "small bank" limit from
$250 million to
$500 million. The long history of partnership between banks and CDFIs
indicates that investment opportunities are available to banks of all
sizes and in all regions. The proposal would particularly impact rural
communities, where the number of institutions subject to complete CRA
exams would decline by an estimated 73%, according to the National
Community Capital Association.
We strongly urge you to withdraw this proposed change from consideration
to ensure continued inclusion of "investment" and "service" tests
in the
CRA exams of a maximum number of banks.
Conclusion
The Community Reinvestment Act has channeled billions of dollars into
underserved markets and fostered new, productive partnerships between
banks and community organizations. The regulators must not roll back
these gains in providing access to capital. Improved and enhanced data
disclosure is an important step, but other aspects of the proposal
threaten the expansion of capital and credit in underserved communities.
We urge you to:
* Maintain an investment test as part of banks' CRA performance by
maintaining the current "small bank" definition. * Continue
to hold banks
that are part of large holding companies to the "large institution"
standards. * Expand CRA so that it better reflects changes in the
financial services industry brought about by market shifts, technology
advances, and financial modernization legislation.
Thank you for the opportunity to comment.
Sincerely,
Jack Kenny
Deputy Director
Oregon Housing & Community Services
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