FDIC Federal Register Citations

Society of Jesus, N.Y. Province

From: Hallinan, Rev. Mark, S.J.
Sent: Monday, August 23, 2004 11:33 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

I am writing to urge the FDIC to withdraw its proposed rule raising the asset threshold for “small banks” from $250 million to $1 billion and thus exempting these banks from the more stringent requirements of the Community Reinvestment Act (CRA).

This change would have a devastating impact on investments in low and moderate income communities, particularly in rural areas where institutions with assets of $250 million to $1 billion hold the principal market share. At a time when affordable housing is vitally needed, and financing for community development proposals is critical, this is not the time to exempt banking institutions from compliance with the terms of the CRA.

Please withdraw this proposed rule change.

Mark Hallinan, S.J.
Asst. for Social Ministries
Society of Jesus, N.Y. Province