From: David S White [mailto:ccswhite@juno.com]
Sent: Friday, September 17, 2004 3:16 PM
To: Comments
Subject: RIN 3064-AC50
Dear Mr. Feldman,
I'm a concerned citizen who volunteered in Utica, NY's, central
city area called Corn Hill for a decade in the late 70s and early
80s. A major problem then
was a tendency for financial institutions to "redline" certain
areas, so that credit, investment, economic development, and vital services
were unavailable to those that needed them most.
When innovative solutions were devised, such as the Neighborhood Housing Services
and the CRA, neighborhoods began noticeable improvement. Public-private partnerships
bloomed, people became more educated and concerned with the general good of
large sections of the city, and spreading blight was replaced by constructive
progress both materially and in good relationships among many segments of the
community.
Your proposed changes will hinder this movement toward a society that works
for all people, that we all want. The Ownership Society must apply to all our
citizens in all areas. People who become informed and work cooperatively with
city officials, lending institutions, and established groups like NHS, become
contributors to society rather than drags on it. Working together we can solve
inner-city problems in a constructive way. We need more innovation and creativity,
not a pulling back to the days when good, intelligent, trustworthy people of
all income groups and races were marginalized due to where they lived. A sound
society will encourage all these people to participate, prosper, learn, and
live together in harmony. An integral part of this forward movement is the
full participation of lending institutions, especially in underserved low and
moderate income areas.
I personally live in a modest suburban town, but made it my business to learn
about the plight of the poor in the inner-city. I learned a great deal about
practical solutions and the wonderful people of all income levels and races
who want only the best for themselves, their neighbors, their society, and
who work hard if given the chance. They need what all of us need - health care
in the form of neighborhood clinics for those without a vehicle, supermarkets
with reasonably-priced food, home ownership or affordable rental housing, recreation
centers, small business loans, clean streets, repaired sidewalks, police presence
-basic services we all pay taxes for.
I sincerely hope FDIC will keep the investment and service requirements for
banks at the current $250 million in assets, keep the current requirement that
these banks must make community development loans, investments, and services,
and that community development activities must be directed to low and moderate
income individuals in rural areas. We live in central New York where full-time,
year round workers (male) earn $32,194 in Oneida County and $29,908 in Herkimer
County. Females earn two-thirds of that. (Utica Observer-Dispatch 9/14/04.)
Our area is desperately in need of innovative public-private partnerships and
increased involvement of banks and financial institutions. We need publicly-available
data on the small-business lending of mid-sized banks.
Two other federal agencies recognized the harm to underserved communities of
the proposed changes and dropped them, and I hope you will do the same.
Thank you very much for considering these comments.
Sincerely,
Carol S. White
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