From: Kori Schneider [mailto:korischneider@mcleodusa.net]
Sent: Tuesday, April 06, 2004 2:47 PM
To: regs.comments@occ.treas.gov; regs.comments@federalreserve.gov;
regs.comments@fdic.gov; Comments; regs.comments@ots.treas.gov;
Josh Silver
Subject: Proposed CRA changes
April 6, 2004
Communications Division
Public Information Room, Mailstop 1-5
Office of the Comptroller of the Currency
250 E St. SW,
Washington 20219
Docket No. R-1181
Jennifer J. Johnson
Secretary, Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington DC 20551
Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th St NW
Washington DC 20429
Regulation Comments, Attention: No. 2004-04
Chief Counsel's Office
Office of Thrift Supervision
1700 G Street NW
Washington DC 20552
Dear Officials of Federal Bank and Thrift Regulatory Agencies:
I am very concerned about the proposed changes to CRA. As a resident
of a low and moderate income community, a banking customer, and
a borrower, I am writing to urge you to rethink your proposed Community
Reinvestment Act (CRA) regulation before it is finalized. I believe
you should keep the small bank definition as it is at $250 million
in assets and I believe you need a stronger predatory lending standard.
Wisconsin would be hard-hit by the proposed changes in requirements
for small banks. Over 10% of our state’s banks would be exempted
from most CRA regulations if the changes are enacted.
I am also very concerned about the proposed standard regarding
predatory loans. I am very aware of rip-off lenders who do what
you call "asset-based lending" and try to force borrowers
into foreclosure so they can take over their homes. However, there
are many other ways that seemingly good banks take advantage of
customers who don't understand the loan process. I think the regulators
should use the CRA exams to penalize lenders who push high cost
loans with high fees and those who get you into a bad loan and
then try to flip you into an even worse loan. I also oppose prepayment
penalties that keep you from getting out of a bad loan, loans with
balloon payments, and single premium credit insurance policies
that cost a lot but don't really help the customer. Regulators
should lower a bank's CRA rating when they include loan “features” like
that.
I hope that instead of exempting the smaller banks from CRA regulations,
you will pay more attention to the smaller banks. They would do
more in lower income communities if the regulators would encourage
them to support community development lending and investments in
smaller communities. I'm asking you not to raise the asset threshold
definition of a small bank.
I am familiar with the National Community Reinvestment Coalition,
which has submitted more detailed comments than mine. I feel confident
that they understand the complexities of CRA better than I do,
and I support their comments.
Thank you very much for paying attention to my concerns.
Sincerely,
Kori A. Schneider
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