Cleveland Housing Network
17 September 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
I am writing to request that you to
withdraw your proposed changes
to the
Community Reinvestment Act (CRA) regulations. My organization, the
Cleveland Housing Network, knows first hand that the CRA has been
instrumental in increasing homeownership, boosting economic development,
and expanding small businesses in the nation's low- and moderate-income
communities.
The Cleveland Housing Network, established in 1981, was founded
to create a
citywide production system to achieve comprehensive community development
and cultivate strong, vibrant and economically viable neighborhoods.
CHN's
mission is to develop a continuum of safe, energy efficient and affordable
housing and homeownership options for low and moderate-income Cleveland
families. CHN's housing development programs include the construction
and
rehabilitation of 300 single-family homes each year, transitional
and
permanent housing options for formerly homeless families, and a pilot
initiative to preserve the affordability of expiring, Section-8 assisted
multi-family housing. Over the past 23 years, CHN's programs have
built
more than 3,000 homes, and have generated more than $250 million
of capital
investments in Cleveland's neighborhoods. Simply put, the Community
Reinvestment Act has been the single most important cornerstone of
our
track record. Without the strong support from our financial institution
partners, this work would not have been possible.
The proposed FDIC rule would exempt many of our community's key
financial
partners from the effective and productive requirements currently
in place.
We oppose any increase to the threshold of what is considered to
be a small
bank, and we urge the FDIC to withdraw its proposed rule.
Robert S. Curry
Director
The Cleveland Housing Network
2999 Payne Avenue, #306
Cleveland, OH
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