From: Robert Zort [mailto:r.zort@comcast.net]
Sent: Tuesday, September 14, 2004 3:52 PM
To: Comments
Subject: Contact FDIC Today to Oppose Changes to CRA
Robert Zort
1014 S. Scoville Ave.
Oak park, IL 60304
September 14, 2004
Robert Feldman
FDIC
550 17th St NW
Washington, DC 20429
Dear Robert Feldman:
RE: RIN 3064-AC50
I urge you to support the current structure of the Community
Reinvestment Act by withdrawing your proposal to raise the “small bank”
definition from $250 million to $1 billion in assets. Any changes to CRA
and especially the definition of a “small bank” will adversely impact
community development investments in low-income and underserved areas.
Under the FDIC proposal to raise the “small bank” standard from $250
million to $1 billion, in Illinois only 13 of 467 FDIC regulated banks
would be subject to the full CRA Exam, including the investment and
services tests. The 467 banks in Illinois regulated by the FDIC have
combined assets of over $83.4 billion. 97.2% of these banks have assets
under $1 billion. With this change, an additional $31.1 billion in banks
assets would only be subject to a streamlined CRA Exam. This combined
with the already $33.1 billion in assets already subject to a
streamlined CRA Exam, results in over $66.6 billion—or 79.8%--in assets
of FDIC regulated Illinois banks not subject to the full CRA
regulations.
This would eliminate the most important incentive for financial
institutions to partner with CDFIs, CDCs and others engaged in community
development. Without this incentive, it will be increasingly difficult
for community development organizations to obtain the resources and
investments to fund essential development projects, especially at a time
when the national poverty rate is increasing.
In order to ensure the continued growth and sustainability of
community development and its ability to provide services to
traditionally underserved communities throughout the country, it is
essential for FDIC to withdraw its proposal and maintain the small bank
definition at $250 million.
Sincerely,
Robert Zort
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