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CITY-COUNTY REINVESTMENT TASK FORCE
Mr. Robert Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550
17th Street NW
Washington DC. 20429-9990
Re: RIN 3064-AC50
Dear Mr. Feldman;The City County
Reinvestment Task Force (RTF) is chartered by the City Council and
County Board of Supervisors to monitor lending practices and develop
strategies for reinvestment in the region. It was established by joint
resolution in 1977 and is Co-Chaired by the City Council and the County
Board of Supervisors. It has an extraordinary record of success in
facilitating access to capital in underserved markets generating
billions of home loans, small business loans, affordable housing and
community investments ($1.9B in 2003). Through local attention to the
CRA and long term strategic planning and analysis the CRA has become one
of the primary tools for community stability and revitalization in the
region. These accomplishments occur because of the "partnership' that
has been forged between community, lenders and government. The
partnership depends on each party bringing its full authority and
potential to the work.
Government has provided much protection and risk diversion with
affordable housing, investments and small micro lending efforts. This
was offered with the confidence that the lenders would equally commit.
The RTF has done constant and disciplined assessment of credit access
and through dialogue, face to face, many new and innovative solutions
have been created, so much so that a thriving and profitable "industry"
has emerged in this region focused on economically healthy communities.
Unfortunately one of the least accessible or available players has
not been at the table and has not strategically benefited or been a
player in this twenty-five year initiative. Strangely enough it is banks
under $1Billion that have pushed themselves away from the challenge and
avoided major or vital commitments. Even when efforts were very near
geographically or directly in concert with their primary business plan
the small banks have refused to work in concert with the major lenders,
the community and government.
Why?
Having observed and worked with many financial institutions it is my
assessment that smaller banks tend to be focused on serving the primary
needs of their boards and developing the bottom line for those small
group of key investors. Most of those investors know very little about
the potential markets in low and moderate-income communities. They are
largely focused on suburban depositors and businesses and lack the
resources to look beyond that which is familiar and common to their
personal culture.
That is the reason why they seek exemption. They are iconoclastic,
maybe self-made men who have assets adequate to create a small bank and
micro mange the lending and investment strategies with a myopic eye and
a prejudice against foreign markets and ethnic consumers.
By changing the rules and modifying the deposit standards you are
directly perpetuating a very divisive and exclusionary national banking
policy. I urge you not to do that. All of the research and work that has
been done to validate CRA lending and investments as viable profit
centers for small banks, as well as large, will be violated. Your
decision is based on something other than reality. Please consider the
alternative. Do not exempt nks with assets under $1B from the CRA.
Sincerely,
Jim Bliesner, Reinvestment Director
City and County of San Diego
625 Broadway-Suite 110, MS-A263
San Diego, California 92101 |
