Faith Community United
Credit Union April 7, 2004
Dear Officials of Federal Bank and Thrift Agencies:
I serve as an elected board member of the National Federation of
Community Development Credit Unions. In that capacity, and as a
concerned citizen and active community developer, I write to urge you to
WITHDRAW the proposed changes to the Community Reinvestment Act (CRA)
regulations.
For more than 25 years, the CRA has encouraged banks to better serve
U.S. communities, resulting in increased access to homeownership,
strengthened economic development in stagnant local economies, and
expansion of small businesses in the nation's minority, immigrant, and
low- and moderate-income communities. Your proposed changes promise only
to halt and even reverse that economic progress.
By empowering citizens with the tools for close oversight of their
local banks, the CRA has "completed the market" - it has added millions
of community residents to the "eyes and ears" that the regulatory
agencies need for responsible oversight; it has added stakeholders to
stockholders and regulators in the ongoing work of fine-tuning
"financial intermediation" to best serve the convenience, needs and
advancement of the country's local, regional and national economies.
Yet now, you propose to block that citizen oversight of 1,111 banks
that account for more than $387 billion in assets! Those not-so-small
banks may seem small in comparison with the mega banks, but
they are HUGE to the communities they serve, and those communities
deserve the right to watchdog and, if necessary, to discipline their
banks to fulfill every bank's public obligation to serve ALL of their
community, without unfair exclusion and without predatory practices.
You already have many letters detailing the serious drawbacks of the
proposed Interagency Regulations - drawbacks that promise to undermine
and even cripple efforts to expand fair access to high-quality financial
products and services. I won't reiterate them here, but instead I will
urge you to keep your eye on the goal, a goal that CRA has served with
increasing effectiveness over the past two-and-a-half decades: To make
fair access to capital, credit and banking services available to
everyone, in order to help individuals, families and communities build
assets toward a more prosperous and resilient economic future. CRA is a
law that makes capitalism work for all Americans. It is far too vital to
be gutted by harmful regulatory changes and neglect.
Thank you for your attention to this critical matter.
Sincerely,
Rita L. Haynes, Chairwoman
BOARD OF DIRECTORS
Cc: National Community Reinvestment Coalition
President George W. Bush
Treasury Secretary John W. Snow |