FDIC Federal Register Citations

From: Herbert J Engman [mailto:hje1@cornell.edu]
Sent: Thursday, October 07, 2004 11:24 AM
To: Comments
Subject: Community Reinvestment Act

As one who has been involved with housing both from a housing board of directors perspective and as a local government official, I am strongly opposed to your proposal to significantly weaken the Community Reinvestment Act (CRA). The proposed much easier CRA requirements for banks with between $500 million to $1 billion in assets will result in many fewer home and small business loans to low- and moderate-income borrowers and many fewer community development loans and investments in low- and moderate-income communities. In addition, you propose that banks can earn CRA points by financing community development projects that benefit affluent residents in rural areas instead of low- and moderate-income consumers and communities in rural America. This is directly contrary to CRA's focus on meeting the credit needs of low- and moderate-income communities. In sum, all of your proposals will result in many fewer loans, investments, and branches in low- and moderate-income communities. Please withdraw your proposal.

Sincerely,
Herbert J. Engman
120 Warren Road
Ithaca, NY 14850