From: Klsomic@aol.com [mailto:Klsomic@aol.com]
Sent: Monday, September 20, 2004 8:57 AM
To: Comments
Cc: Klsomic@aol.com
Subject: Please leave the CRA (Community Reinvestment Act) alone.
Septembe 20, 2004
Mr. Robert E.
Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
RE: RIN 3064-AC50
Dear Mr. Feldman,
As a woman, a minority, and a community servant I know from personal
experience and over twenty years of observation that the Community
Reinvestment Act has enabled many community groups and service projects
access funds otherwise unavailable to them. With the changes proposed
this small pool of funds will be taken from the needy and least protected
and be made available to the greedy and well connected. This is not
speculative, we've seen it already with Corporate wellfare.
Where grants are made available to businesses with multi-million
dollar profit margins.
I am very concerned, and a 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, the 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.
The watered-down exam, 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.
The proposal 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.
These 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,
Rev. Kim L. Singletary
P.O. Box 453
Hudson, New York
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