FDIC Federal Register Citations

Northwestern Ohio Community Action Commission

From: Deb Gerken [mailto:dagerken@nocac.org]
Sent: Monday, October 04, 2004 2:34 PM
To: Comments
Subject:

To Whom It May Concern:

I am writing to urge you not to change the current CRA regulations and thresholds. This would leave rural areas with no regulated financial facilities.

Because of CRA regulatory pressure, we have been successful in partnering with local banks on a number of projects benefitting low-income residents of northwest Ohio. We have received link deposit mortgages on buildings used for Head Start as well as a building that houses emergency shelter rooms, Single Room Occupancy apartments, a soup kitchen and case management offices.

In addition, we have partnered with three area banks to hold and service accounts for our Individual Development Account customers. They are saving money which is matched by some of the area banks, for assets including new homes, starting a business or continuing their education.

It is highly probable that without the current CRA requirements and thresholds, most of these "partners" would no longer see any advantage to helping the low-income residents in the geographical areas from which they draw their customers and the programs that I have outlined for you would no longer be viable in our very rural area of Ohio.

Please retain the current regulations/thresholds in order to preserve one of the few funding conduits available to low-income people in our area.

Thank you.

Deborah A. Gerken
Executive Director
Northwestern Ohio Community Action Commission
Defiance, Ohio