From: Susan Kaplan
Sent: Wednesday, September 08, 2004 3:04 PM
To: Comments
Subject: Contact FDIC Today to Oppose Changes to CRA
Susan Kaplan
919 N. Elmwood
Oak Park, Il 60302
September 8, 2004
Robert Feldman
FDIC
550 17th St NW
Washington, DC 20429
Dear Robert Feldman:
RE: RIN 3064-AC50
I urge you to support the current structure of the Community Reinvestment
Act by withdrawing your proposal to raise the “small bank” definition
from
$250 million to $1 billion in assets. Any changes to CRA and especially
the definition of a “small bank” will adversely impact
community
development investments in low-income and underserved areas.
Under the FDIC
proposal to raise the “small bank” standard
from $250
million to $1 billion, in Illinois only 13 of 467 FDIC regulated
banks
would be subject to the full CRA Exam, including the investment and
services tests. The 467 banks in Illinois regulated by the FDIC have
combined assets of over $83.4 billion. 97.2% of these banks have
assets
under $1 billion. With this change, an additional $31.1 billion in
banks
assets would only be subject to a streamlined CRA Exam. This combined
with
the already $33.1 billion in assets already subject to a streamlined
CRA
Exam, results in over $66.6 billion—or 79.8%--in assets of
FDIC regulated
Illinois banks not subject to the full CRA regulations.
This would eliminate the most important incentive for financial
institutions to partner with CDFIs, CDCs and others engaged in community
development. Without this incentive, it will be increasingly difficult
for community development organizations to obtain the resources and
investments to fund essential development projects, especially at
a time
when the national poverty rate is increasing.
In order to ensure the continued growth and sustainability of community
development and its ability to provide services to traditionally
underserved communities throughout the country, it is essential for
FDIC
to withdraw its proposal and maintain the small bank definition at
$250
million.
Sincerely,
Susan Kaplan
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