| HOUSING RESOURCES OF
COLUMBIA COUNTY, INC.
September 16, 2004
Mr. Robert Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550
17th Street NW
Washington, DC 20429
RE: RIN Number 3064-AC50
Mr. Feldman:
I am writing on behalf of Housing Resources of Columbia County, Inc
to voice strong opposition to the FDIC's proposed changes to the
regulations governing the Community Reinvestment Act (CRA). Raising the
asset threshold for small banks to $1 billion would severely weaken the
CRA and undermine partnerships that community development organizations
such as ours has developed with local banks.
Housing Resources of Columbia County, Inc. is a non-profit organization
that advocates for better neighborhoods and housing for low and moderate
income individuals and families. We are a NeighborWorks organization
that uses Neighborhood Reinvestment funds to leverage private dollars in
order to create new homeowners, revitalize distressed communities, and
build single family and multi-family housing for low to moderate income
families.
Since 1996 the NeighborWorks Campaign for Home Ownership has assisted
70,000 households to become homeowners, 89% of whom were low or
moderate income. Additionally, the network provided homeownership
counseling to more than 420,000 individuals: None of this could have
been achieved without the significant participation of local bank
partners, as investors, lenders
and service providers.
A major issue that many of the rural NWOs struggle with is the loss
of small and medium sized, locally controlled banks as that industry is
consolidated through mergers. This trend has a significant impact on low
and moderate income communities – the very communities that we serve. A
result of these mergers is the reduction of community lending programs
and local loan officers; the transfer of grant making and lending
decision making goes to central bank headquarters that are more often
than not, far away from the applicant community. Bank centralization is
particularly difficult for rural areas; most bank headquarters are
located in urban centers where decision makers have little knowledge of
rural communities.
CRA provides one of the few tools which Housing Resources and other
community based organizations can influence the merger process. Again,
we express our opposition to regulatory changes designed to allow more
institutions to bypass the full CRA exam process.
Sincerely,
Kevin O'Neill Executive Director
Housing Resources of Columbia County, Inc,
605 State Street
Hudson, NY 12534
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