FDIC Federal Register Citations

From: Franklin Lee [mailto:fmlee@shapirosher.com]
Sent: Thursday, September 16, 2004 2:15 PM
To: Comments
Cc: fmlee@shapirosher.com
Subject: Community Reinvestment -- RIN 3064-AC50

To Whom It May Concern:

I oppose the FDIC's proposal to allow banks with assets above $250 million to be examined as small banks under the Community Reinvestment Act. This policy would reduce lending, investments and services in low-income communities. It would also undermine efforts to encourage more equitable lending to small and minority-owned businesses that tend to be located in urban communities.

For the past 18 years, I have been an advocate on behalf of small and minority owned businesses. In my work, I have seen countless examples of commercial lending discrimination by banks of various sizes, including those that have less than $1 billion in assets. Increasingly, research by well-respected economists and academicians has been confirming the pervasiveness of this problem of unequal access to capital caused by discriminatory lending practices. If anything, the oversight and review of financial institutions' compliance with CRA in this regard needs to be strengthened, not watered down.

I urge you to reject any rule that would raise the threshold for full CRA audits and reviews of financial institutions.

Very truly yours,

Franklin M. Lee, Esquire
4295 Mary Ridge Drive
Randallstown, MD 21133
(410) 385-4239