From: [mailto:bmoellenbrock@sjfund.com]
Sent: Tuesday, September 28, 2004 11:20 AM
To: action_letter@ncrc.org
Subject: RIN 3064-AC50, Community Reinvestment Act
Dear: Mr. Feldman
Regarding: I am a concerned citizen opposed to watering down CRA
(Community Reinvestment Act) requirements for mid-sized banks. CRA is
vital for increasing homeownership and economic development in
lower-income communities. However, your proposed changes will halt the
progress that has been made.
I understand that banks with over $250 million in assets must be
tested on their number of loans, investments, and services to low- and
moderate-income communities. But your proposal would eliminate the
investment and service requirements for all banks with under $1 billion
in assets. This will result in significantly fewer loans and investments
in affordable rental housing, health clinics, community centers, and
economic development projects.
In the watered-down exam, you would allow mid-sized banks to choose
which community development activities they will undertake. Right now,
these banks must make community development loans, investments, and
services. Your proposed test allows banks to choose only one of the
three activities. The result will be less community development
activity.
You also propose that community development activities in rural areas
should benefit any group of individuals instead of only low- and
moderate-income individuals. But this will allow banks to cherry-pick
and focus on affluent residents of rural areas rather than the lower
income consumers CRA targets. Finally, you would also eliminate publicly
available data on the small business lending of mid-sized banks. Without
data, community groups and citizens cannot hold banks accountable for
lending to small businesses in their neighborhoods.
Your changes directly oppose CRA’s mandate to require lenders to meet
community needs. CRA is too important to be gutted. Please drop your
proposal like the two other federal agencies that recognized its harm to
underserved communities.
Sincerely: Bonny Moellenbrock
Organization: SJF Ventures
Address1: 400 W Main St, Ste 604
City: Durham State: NC zip: 27701 |
