From: Adwon, Gerene [mailto:gadwon@sjmc.org]
Sent: Friday, September 17, 2004 2:39 PM
To: Comments
Cc: 'nmelton@ncrc.org'; 'ssmcecile@aol.com'
Subject: Corporate Stance Issue
September 17, 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street N.W.
Washington, D.C. 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
I am a concerned citizen opposed to watering down CRA (Community Reinvestment
Act) requirements for mid-sized banks. CRA is vital for increasing home ownership
and economic development in lower-income communities. However, your 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.
In the watered-down exam, you 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.
You also propose 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 consumer 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.
Your 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 hard to underserved communities.
Sincerely,
Sr. M. Therese Gottschalk, President/CEO
St. John Health System
1923 S. Utica Avenue
Tulsa, OK 74104
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