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SHOREBANK
September 23, 2004
Mr. Robert Feldman
Executive Secretary
Federal Deposit Insurance Corporation
Comments/Legal ESS
550 17th Street NW
Washington, DC 20429
Dear Mr. Feldman:
ShoreBank is the first and leading community development and
environmental financial institution in
the U.S. With $1.6 billion in assets and three regulated financial
institutions around the county – in
Illinois/ Michigan (ShoreBank in Chicago/Detroit), Washington (ShoreBank
Pacific) and Ohio
(ShoreBank Cleveland) – a number of nonprofits in those same states plus
Oregon as well as a national
and international consulting company, we are concerned about the impact
of the proposal to reduce the
number of CRA lenders.
Since 1973, ShoreBank in Chicago has provided more than $905 million in
funds for mortgages and
rehabbing of walk-up apartment buildings that provide 38,654 units of
unsubsidized affordable
housing. In addition, we provide financial services to approximately
1,500 faith based organizations
and small nonprofits. We are also an important source of credit and
financial services to small
businesses critical to the neighborhoods we serve on the south mid-south
and west sides of the city.
Many regulated institutions are “motivated” to increase their lending
and investments in low- and
moderate-income (LMI) communities and institutions because of CRA. We
are concerned that changes
in the threshold will have a serious negative impact on the work that is
being done to provide credit in
and to communities and individuals who require more complicated and
therefore, more time
consuming and consequently, less profitable services.
These small but complex customers are the ones that do not often fit in
a standardized and easily
replicable program, but they are responsible borrowers. They can and
should be able to access the great
American banking system. It is in part because of CRA that institutions
like ours can and do provide
them with needed and good service. We urge you to not reduce the number
of CRA lenders in order to
allow us and others to continue to serve this vital segment of the
marketplace.
I would be happy to discuss this further with you or any of your staff.
Please contact me at 773-420-
4903 or fran_grossman@sbk.com.
Sincerely,
Fran Grossman
Executive Vice President
ShoreBank |
