FDIC Federal Register Citations

CASA of Oregon

From: Peter Hainley [mailto:phainley@casaoforegon.org]
Sent: Monday, October 04, 2004 2:54 PM
To: Comments
Subject: RIN 3064-AC50

CASA of Oregon is a statewide nonprofit community development corporation CASA has been involved with affordable housing development for farmworkers for 16 years . I have seen the positive impact of the Community Reinvestment Act on low income rural communities all across our service area. From access to mortgage and small business capital to financial institution support for critical programs like rental housing, home buyer counseling, IDA programs, financial literacy and foreclosure prevention strategies, CRA has had a dramatic impact in increasing resources for low income communities. CRA is a critical component to our area’s affordable housing and community development solutions. I oppose any increase to the threshold of what is considered to be a small bank. The proposed FDIC rule would exempt many of our community’s critical partners from the effective and productive requirements currently in place. I urge FDIC to withdraw its proposed rule.

Smaller banks have been the mainstay in serving the rural areas. Without some carrots (tax credit programs, investment opportunities) and sticks (CRA, other regulatory institution requirements) we would not be able to convince banks that they need to serve the entire community in the poorer, rural communities in which we work. CRA is an effective tool that needs to be applied to smaller financial institutions as well as the big ones.

Again, I urge the FDIC to withdraw this proposed rule.
Thank you for allowing me to comment on this critical issue.

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Peter Hainley, Director
CASA of Oregon
212 E. 1st Street
Newberg, OR