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NORTHWEST REGIONAL FACILITATORS
From: Brian Royer [mailto:broyer@nrf.org]
Sent: Tuesday, September 07, 2004 7:10 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
Please do not further weaken CRA definitions. “The Community
Reinvestment Act is a critical component to our community’s affordable
housing and community development solutions. We oppose any increase to
the threshold of what is considered to be small bank. The proposed FDIC
rule would exempt many of our community’s critical partners from the
effective and productive requirements currently in place. We urge FDIC
to withdraw its proposed rule.”
According to the National Community Reinvestment Coalition, changing
the of the “small bank” definition will allow about 2,000 banks with
total assets of more than $754 billion and branches in more than 18,800
communities (96% of all FDIC-regulated banks) to receive a watered-down
CRA exam. Because institutions with assets of $250 million to $1 billion
comprise substantial market share in rural areas, such a change will
mean that many rural communities and states will not have access to any
institutions required to offer services and investments that benefit low
and moderate income communities. According to FDIC data, the states with
no institutions with more than $1 billion in assets are: District of
Columbia, Hawaii, Idaho and Wyoming. States with four or fewer such
institutions are: Alaska, Arkansas, Iowa, Louisiana, Maine, Minnesota,
Montana, North Dakota, New Hampshire, Oregon, South Dakota, Vermont and
West Virginia. Please do not in any way lessen the role of the Federal
Reserve Board and the Office of the Comptroller of the Currency, which
have thus far kept their commitment to the CRA tol join the FDIC and the
Office of Thrift Supervision (OTS) in significantly scaling back the CRA.
In July, OTS raised its small bank threshold and the Fed and OCC
withdrew their proposal to do so, deferring instead to Congress for any
CRA-related changes.
Brian Royer
Business Development Manager
NRF Northwest Regional Facilitators
315 West Mission Avenue Suite 100
509-484-6733 Extension 119
Fax 509-483-0345
broyer@nrf.org
www/nrf.org
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