09/17/04
1:00 PM EDT
FDIC
Washington, D. C.
To Whom It May Concern:
I have been involved with Community Reinvestment for years. I began
serving as an aide/analyst for the Michigan Legislature in 1976,
just as the Michigan Coalition Against Redlining was getting started.
I was on staff for the Legislature though 1993, when I became a
Real Estate Appraiser. I have been both an independent fee appraiser,
and a staff appraiser for one of the larger single family mortgage
companies in Michigan, and today I am again an independent fee appraiser.
I also serve on the board of the local fair housing program.
It is absolute essential for the proposal NOT be adopted. If only
the biggest of the big banks have to report, the reports will become
meaningless. Most of the area banks in Michigan would never have
to report anything. The reason we required them to report this information
was so that we, as the public, could be assured that the banks serving
a local community were reinvesting in those communities. If this
rule is adopted, agencies like our fair housing center, will not
able to assure that our local lending institution are complying with
the law.
And if they don't have to report, do you think they will do it?
Of course not. If we hadn't this reporting position for the last
few years, we would not have the community reinvestment that has
been going on.
I think I have a unique perspective on this issue, as a former employee
of the government, a former bank employee, and now as an independent
fee appraiser. Let me assure you that if the institutions don't have
to report what they do, in a short while they will not be making
significant basic community reinvestments.
I am urging you to not adopt this new rule
As always, if you have any questions or concerns, please contact
me at the above addresses.
Sincerely,
Gregory L. Mann
Gregory L. Mann, AGA, MAREA
Owner, Manager, Senior Appraiser
Michigan Licensed Appraiser
Appraisal Professionals of West Michigan, LLC
Board Member, PFHC of Southwest Michigan
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