From: Noelle Melton [mailto:nemelton@yahoo.com]
Sent: Wednesday, September 15, 2004 4:31 PM
To: Comments
Subject: Stop Picking Apart CRA! RIN 3064-AC50
September 15, 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
I am a concerned citizen opposed to your proposal to water-down CRA
requirements for mid-sized banks. CRA
is vital for increasing homeownership and economic development in
lower-income communities. But your proposed changes will halt all of
this progress.
First of all, your proposal would eliminate the investment and
service requirements for all banks with under $1 billion in assets. Do
you guys really understand how many institutions and assets would be
impacted? Ninety-six percent of the banks you regulate! And these banks
have over $754 billion in assets. Ultimately, it will mean significantly
fewer loans and investments in affordable rental housing, health
clinics, community centers, and economic development projects, just to
name a few.
Then there’s the issue of you trying to throw a "community
development criterion" bone. In the watered-down exam you want to offer
to more banks, mid-sized banks will choose which one community
development activity they will undertake. Right now, these banks must
participate in three community development activities: loans,
investments, and services. Congress enacted CRA to say that banks had an
obligation to meet the credit needs of the communities they served. It
did not enact CRA so banks could decide what needs those might be and
then cherry pick which one is best for them. But your
proposed test would allow this to happen and it would be the cause for a
reduction in community development activity in neighborhoods.
You also want community development activities in rural areas to go
to anyone at all, rather than the low- and moderate-income individuals
that deserve them. Do you have something against poor rural people or do
you just want your wealthy friends in the country to get more golf
courses?
Let’s face it. Your changes directly oppose CRA’s mandate to require
lenders to meet community needs. As a law enacted by Congress, CRA is
too important to be picked apart to pieces by regulators. Please
recognize the harm your proposal will do to underserved communities and
drop it as the OCC and the Fed did.
Sincerely,
Noelle Melton
Washington, DC
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