FDIC Federal Register Citations

Linda Castle
519 S. 81
Kansas City, Ks 66111

October 1, 2004

Dear Federal Deposit Insurance Commission:

Despite the successes of community development locally and nationally, the banks and thrift institutions that provided the loans, services, and investments to build new homes, businesses, and community facilities may no longer have the impetus to do so if the FDIC raises the comprehensive CRA exam threshold.

I agree with the National Congress for Community Economic Development that this proposed change would have a devastating effect on affordable housing and community development investment throughout the nation, particularly in rural areas.

The FDIC proposes that the community development loans and investments in rural areas can benefit any group of individuals, not just low- and moderate-income individuals. Currently, banks have to finance affordable housing and economic development projects that target low- and moderate-income borrowers and neighborhoods. Under the proposed changes, nothing in the CRA regulations would prevent banks from earning CRA points for financing developments with no community development benefit whatsoever. Moreover, the one part exams would cover 99 percent of all FDIC-supervised banks located in rural areas.

President Bush’s comments promoting an "Ownership Society" are truly disingenuous if the actions of officials he appointed are undermining proven laws that revitalize communities, increase minority homeownership, and increase small business ownership for women and minorities.

Please rescind your proposal.

Sincerely,
Linda Castle