National
Federation of Community Development Credit Unions
From: Cliff Rosenthal [mailto:crosenthal@natfed.org]
Sent: Tuesday, April 06, 2004 1:22 PM
To: regs.comments@federalreserve.gov; Comments; regs.comments@ots.treas.gov;
regs.coments@occ.treas.gov
Subject: CRA Comments from National Federation of Community Development
Credit Unions
Docket No. 04-06
Communications Division
Public Information Room - Mailstop 1-5
Office of the Comptroller of the Currency
250 E Street, SW
Washington, DC 20219
Docket No. R-1181
Ms. Jennifer Johnson, Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, DC 20551
Attention: Comments
Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Regulation Comments
Chief Counsel’s Office
Office of Thrift Supervision
1700 G Street, NW
Washington, DC 20552
April 6, 2004
Dear Regulators:
The National Federation of Community Development Credit Unions (the “Federation”)
represents 225 credit unions serving low-income communities in 43 states,
the District of Columbia, and Puerto Rico. The Community Reinvestment
Act (CRA) has played a major role in bringing resources to support
the provision of financial services in low-income communities by our
members. It is vital to our communities that CRA remains broadly applicable
and effective.
Toward this end, we oppose the proposed changes raising the threshold
for “small” banks from $250 million to $500 million, regardless
of the size of a bank holding company, because this may diminish resources
and incentives for hundreds of banks to support CDCUs and other community
development financial institutions (CDFIs).
Regarding the proposed predatory lending standard, we do not find this
adequate to protect consumers from abusive lending. We are especially
concerned with practices that permit banks to circumvent state law
and fund predatory payday loans. Such practices should absolutely be
reflected in bank CRA ratings.
In addition, we would urge the regulatory agencies to address the need
to update assessment areas to include geographical areas beyond bank
branches. We believe that such an updating would facilitate bank partnerships
with CDFIs in all communities where banks do business and expand the
availability of capital and credit to more underserved Americans.
Finally, we support the proposed measures to require additional data
disclosure on CRA exams.
Thank you again for the opportunity to submit comments on the proposed
revisions to CRA regulations. Please feel free to contact me at crosenthal@cdcu.coop
or 212-809-1850 ext. 216 if further explanation of our comments is
required.
Sincerely yours,
Clifford N. Rosenthal, Executive Director
National Federation of Community Development Credit Unions
120 Wall Street, 10th Floor
New York, NY 10005
|
