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EASTERN DAKOTA HOUSING ALLIANCE
From: Lisa Rotvold [mailto:edha@rrv.net]
Sent: Tuesday, September 07, 2004 11:22 AM
To: Comments
Subject: "RIN 3064-AC50"
Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ISS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429-9990.
Re: RIN 3064-AC50
I am writing to comment on the proposal to increase the floor for
serious CRA exams for banks. I live in North Dakota and work in the
field of affordable housing development. We frequently rely on our local
banks for loans to make our affordable housing projects work. They can
be complex projects and are not always the most appealing opportunities
for these banks. But because of their CRA requirements they have done
our deals and have helped create much needed affordable housing. It is
critical that we have this tool in ND to keep the banks at the table
with the affordable housing developers. They are good people but very
conservative and are very likely to back off of financing deals like
ours without the requirements of CRA in place.
ND is not the only state to be negatively affected by this proposed
change. According to data from the Senate Banking Committee nine states
would be left with no banks subject to CRA. Another 8 states would have
only one bank subject to the act. Over all 24 states would have 2 or
less banks subject to the act. The CRA has been such an effective tool
in bringing the financing sector to the affordable housing table. They
have made a real difference in the lives of so many low and moderate
income Americans. I fear that this change will really slow down
production of affordable housing at a time when more and more families
are living in poverty. I ask that you please leave the floor for the
serious CRA exams at the current level to enable us and other producers
of affordable housing around the country to continue to rely on our
local banks to help us make it happen.
Lisa Rotvold
Director
Eastern Dakota Housing Alliance
PO Box 758
Hillsboro, ND 58045
Phone: 701-636-5860
Fax: 815-642-0846
"Fostering the Development and Preservation of Affordable Housing in
Eastern North Dakota."
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