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NEW YORK HOUSING CONFERENCE
From: Clara Fox [mailto:cfox@shfinc.org]
Sent: Tuesday, September 28, 2004 3:06 PM
To: Comments
Subject: RIN number 3064-AC50 CRA Regulations
New York Housing Conference
1780 Broadway, Suite 600
New York, NY 10010
(212) 265-6530
September 29, 2004
Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW, Washington, DC 20429
RE: RIN 3064-AC50 Community Reinvestment Act proposed rule revision
Dear Mr. Feldman:
We are writing on behalf of the New York Housing Conference to urge
FDIC towithdraw its proposed changes to the Community Reinvestment Act (CRA)regulations.
Established in 1973, the conference is a broad-based coalition of the
major not-for-profit and for-profit developers, owners and managers of
affordable housing in New York City. Our board members include leaders
in the financial, legal and investment fields as well as noted technical
housing consultants, architects and policy analysts who are actively
involved in the affordable housing community.
As currently administered, CRA has been the key to providing
affordable housing, revitalizing distressed communities, and fostering
economic development in New York City and State. We concur with the
assessment in Congressman James Walsh’s September 15th letter to
Chairman Powell that FDIC ’s proposed changes in the CRA regulations
will cause grave harm to our communities.
We are particularly concerned that, as Congressman Walsh wrote, “if
this proposal were to be adopted, CRA reviews would not hold banks
accountable for investing in Low Income Housing Tax Credits, a major
source of affordable rental housing for low-income working families.”
Indeed, 24,146 apartments in projects financed with investments
generated by the Low Income Housing Tax Credit accounted for fully
one-fourth of New York City’s increase in renter-occupied housing during
the last decade.
Raising the small bank threshold from $250 million to $1 billion
would exempt thousands of FDIC-insured banks from meeting the current
CRA standard that requires them to demonstrate investments and services
in low- to moderate-income areas.
As Congressman Walsh noted, “under the FDIC’s proposal, only two
rural New York FDIC-regulated banks would continue to be subject to the
three-part CRA examination” creating a “serious threat to much-needed
community development efforts in rural areas.” And, as he concluded,
FDIC’s proposal “to allow any community development activities in rural
areas - regardless of scope or populations served - to fulfill CRA
requirements ... undermines the statutory intent of CRA to require banks
to engage in community development activities that benefit low- and
moderate-income families in the areas they
serve.”
Thank you for considering our comments.
Sincerely yours,
Clara Fox John Kelly Carol Lamberg
Co-Chair Co-Chair Staff Director
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