| SELECT MILWAUKEE, INC.
September 16, 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429
RE: MN 3064-AC50, Community Reinvestment Dear Mr. Feldman:
As Executive Director of Select Milwaukee, Inc., a nonprofit
homeownership organization that assists low and moderate income families
achieve homeownership, I am writing to express my opposition to scaling
back Community Reinvestment Act (CRA) requirements for mid-sized banks.
CRA has been vital to increasing housing and homeownership opportunities
in Milwaukee for modest-income families. The changes to CRA proposed by
the Federal Deposit Insurance Corporation will create yet another
obstacle to homeownership for these families.
Currently, banks with over $250 million in assets are tested on their
number of loans, investments, and services to low and moderate income
communities. The FDIC's proposal would eliminate the investment and
service requirements for all banks with under $1 billion in assets. As a
result, significantly fewer purchase mortgages, rehab loans and
investments in new affordable housing would be available to our
customers and the Milwaukee neighborhood housing market. The FDIC
proposes that exams no longer evaluate the number of branches mid-size
banks maintain in low-and moderate-income communities. This can only
fuel the explosion of predatory and payday lending in lower income
neighborhoods in Milwaukee.
In the scaled-back CRA exam, the FDIC would allow mid-sized banks to
choose which community development activities they will undertake.
Currently, these banks must make community development loans,
investments, and services. The proposed test would allow these banks to
choose only one of the three activities. The certain result will be less
community development activity and less housing opportunity for
modest-income families.
The proposed changes undermine CRA's mandate to lenders to meet
community needs. CRA has been instrumental in helping low- and
moderate-income families achieve the American Dream of homeownership. It
has critical in the redevelopment of many neighborhoods in Milwaukee.
I urge you to drop the FDIC, proposed CRA changes.
Sincerely,
Raymond Schmidt
Executive Director
Select Milwaukee, Inc.
2209 N. Dr. Martin Luther King, Jr. Drive
Milwaukee, Wisconsin 53212
(414) 562-5070 Telephone • (414) 562-5072 Facsimile
cc: National Community Reinvestment Coalition
President George W. Bush
Senators John Kerry and John Edwards
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