ShoreBank
From: Frances Grossman
Sent: Wednesday, September 08, 2004 3:54 PM
To: Comments
Subject: RIN number 3064-AC50
September 8, 2004
Donald E. Powell
Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re: RIN Number 3064-AC50
Dear Mr. Powell:
As I indicated
in my letter of August 18 , 2004 (see below), ShoreBank
believes that the FDIC’s proposal to quadruple the asset
threshold for the ”streamlined” CRA exam to $1 billion
will harm affordable housing and community and economic development
in LMI
communities, particularly in rural areas, and we urge you not to
adopt it.
Sincerely,
Frances Grossman
Executive Vice President
ShoreBank
August 18, 2004
Mr. Donald E. Powell
Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Dear Chairman Powell:
ShoreBank is the first and leading community development and environmental
financial institution in the
U.S. With $1.6 billion in assets and three regulated financial
institutions around the county – in Illinois/
Michigan (ShoreBank in Chicago/Detroit), Washington (ShoreBank Pacific)
and Ohio (ShoreBank Cleveland) – a number of nonprofits
in those same states plus Oregon as well as a national and international
consulting company, we are concerned about the impact of the proposal
to reduce
the number of CRA lenders.
Since 1973, ShoreBank in Chicago has provided more than $905 million
in funds for mortgages and rehabbing of walk-up apartment
buildings that provide 38,654 units of unsubsidized affordable housing.
In addition, we provide financial services to approximately
1,500 faith based organizations and small
nonprofits. We are also an important source of credit and financial
services to small businesses critical to the neighborhoods we serve on the south mid-south and west sides of the
city.
Many regulated institutions are “motivated” to increase
their lending and investments in low- and moderate-income
(LMI) communities and institutions because of CRA. We are concerned
that changes in the threshold will have a serious negative
impact on the work that is being done to provide credit in and
to communities and individuals who require more complicated and
therefore, more
time consuming and
consequently, less profitable services.
These small but complex customers are the ones that do not often
fit in a standardized and easily replicable program, but
they are responsible borrowers. They can and should be able to access
the great American banking system. It is in part because
of CRA that institutions like ours can and do provide them with
needed and good service. We urge you to not reduce the number of
CRA lenders in order to allow us and others to continue to serve this vital segment of the marketplace.
I would be happy to discuss this further with you or any of your
staff. Please contact me at 773-420-4903 or fran_grossman@sbk.com.
Sincerely,
Fran Grossman
Executive Vice President
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