FDIC Federal Register Citations

Lancaster Housing Opportunity Partnership

From: Dan Basehoar [mailto:dbasehoar@lancasterhousing.org]
Sent: Monday, September 20, 2004 11:13 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

To whom it may concern:

This is to advise that the Lancaster Housing Opportunity Partnership (LHOP) strongly opposes the proposal by the Federal Deposit Insurance Corporation (FDIC) to allow banks with assets above $250,000 million to be examined as small banks under the Community Reinvestment Act (CRA).

We similarly oppose any similar effort by the other government regulatory bodies like Office of Thrift Supervision (OTS), the Federal Reserve Board, and the Office of the Comptroller of the Currency.

LHOP was incorporated in 1995 to promote expansion of affordable housing opportunities for both renters and first time buyers in Lancaster City and County, Pennsylvania. In that capacity, in 9 years, we have worked with area banks and mortgage companies to help 1200 new homebuyers and develop more than 300 additional affordable housing units.

We have found the current CRA requirements to be a strong ally in our efforts to develop collaborative lending and investment programs working with local banks. We find that, with all the mergers/acquisitions of the “super regional” banks, the focus of larger banks now seems to be on the larger urban markets of Philadelphia and Pittsburgh, not the smaller markets of central Pennsylvania.

As a result, smaller local “home town” banks, often with assets under the $1 billion limit proposed, now need to play a much larger role as our local partners. We are very concerned that the rule change proposed will eliminate current incentives to their participation in local housing and community development programs.

In consideration, we strongly urge FDIC and other regulating bodies not to reduce the current thresholds.

Daniel E. Basehoar
Lancaster Housing Opportunity Partnership
30 West Orange Street, Suite 150
Lancaster, PA