FDIC Federal Register Citations

From: Delores Riggins [mailto:ddriggins@bnkst.edu]
Sent: Monday, September 20, 2004 1:47 PM
To: Comments
Subject: Please Leave the CRA (Community Re-Investment Act) Alone

September 20, 2004

Mr. Robert E. Feldman, Executive Secretary\
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
RE: RIN 3064-AC50

Dear Mr. Feldman,

As a woman, a minority, and a community servant I know from personal experience and over twenty years of observation that the CommunityReinvestment Act has enabled many community groups and service projects access fundsotherwise unavailable to them. With the changes proposed this small pool of funds will be taken from the needy and least protected and be made available to the greedy and well connected. This is not speculative, we've seen it already with Corporate welfare. Where grants are made available to businesses with multi-million dollar profit margins.

I am very concerned, and a citizen opposed to watering down CRA (Community Reinvestment Act) requirements for mid-sized banks. CRA is vital for increasing home ownership and economic development in lower-income communities.

However, the proposed changes will halt the progress that has been made. I understand that banks with over $250 million in assets must be tested on their number of loans, investments, and services to low- and moderate-income communities. But your proposal would eliminate the investment and service requirements for all banks with under $1 billion in assets. This will result in significantly fewer loans and investments in affordable rental housing, health clinics, community centers, and economic development projects.

The watered-down exam, would allow mid-sized banks to choose which community development activities they will undertake. Right now, these banks must make community development loans, investments, and services. Your proposed test allows banks to choose only one of the three activities. The result will be less community development activity.

The proposal that community development activities in rural areas should benefit any group of individuals instead of only low- and moderate-income individuals. But this will allow banks to cherry-pick and focus on affluent residents of rural areas rather than the lower income consumers CRA targets. Finally, you would also eliminate publicly available data on the small business lending of mid-sized banks. Without data, community groups and citizens cannot hold banks accountable for lending to small businesses in their neighborhoods.

These changes directly oppose CRA's mandate to require lenders to meet community needs. CRA is too important to be gutted. Please drop your proposal like the two other federal agencies that recognized its harm to under served communities.

Sincerely,
Ms. Delores D. Riggins
Baldwin, NY 11510