FDIC Federal Register Citations

From: Dominic Melone [mailto:dmelone@CHIVENTURES.org]
Sent: Thursday, September 16, 2004 2:29 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

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. Very few banks are reinvesting in low and moderate income neighborhoods. This proposal would only serve to decrease these activities. In fact, I believe that they should be forced to make more of an effort at investing in businesses located in Low to Moderate income neighborhoods. In my review of banks in the Chicago region many are passing there exams by only making mortgages in qualifying neighborhoods. While this is important this doesn’t qualify as reinvestment in my mind. Banks are happy to do these deals as they are full collateralized and would be doing these deals none the less. I don’t see any banks in our region making mortgages to people or business loans to candidates with a low credit score or less than 100 percent collateral. That’s where the rub lies, because I thought that CRA was supposed to address these systemic problems in our financial system. Don’t lower the standard now, raise it!

Thank you,
Dominic Melone
Director of Economic Development Initiatives
Chicago Community Ventures
700 N. Sacramento Ave.
Chicago, Illinois 60612
773-822-0319
773-822-0310 fax