From: Janet Harry [mailto:janetaer@nls.net]
Sent: Thursday, September 02, 2004 11:23 AM
To: Comments
Cc: cford@ncrc.org; nmelton@ncrc.org
Subject: RIN 3064-AC50
Dear Mr. Feldman:
I am a concerned citizen opposed to decreasing CRA (Community
Reinvestment Act) requirements for mid-sized banks. CRA is a vital
ingredient in the struggle to increase homeownership and economic
development in lower-income communities. Your proposal will halt the
progress that has been made.
Currently, banks with over $250 million in assets must be tested on
the number of loans, investments and services to low and moderate income
communities. Your proposal would eliminate the investment and service
requirements for all banks with under $1 billion in assets. This will
ultimately result in fewer loans and investments in affordable rental
housing, health clinics, community centers and economic development
projects in areas that are severely depressed.
The adulterated exam would allow mid-sized banks to choose which
community development activities they will undertake. Right now, these
banks must make community development loans, investments and services.
Your proposed test allows banks to choose only one of the three
activities. The result will be decreased community development activity
and increased asset loss to the community.
The proposal would also allow community development activities in
rural areas that benefit any group of individuals, instead of targeting
low-moderate income families, to qualify. This will allow banks to
cherry-pick and focus on affluent residents in rural areas rather than
the lower income consumers CRA was designed for. The proposal would also
eliminate publicly available data on small business lending of mid-sized
banks. Without data, community groups and citizens cannot hold banks
accountable for lending to small businesses in their neighborhoods.
The proposed changes directly oppose CRA's mandate to require lenders
to meet community needs. CRA is too important to the communities to
allow it to be gutted. Please withdraw the proposal and thereby
eliminate the harm that would result to underserved communities.
Sincerely,
Jan Harry
70 East Columbia Street
Alliance, OH 44601
PH: 330-829-9104
Fax: 330-829-0247
E-mail: janetaer@nls.net
CC: National Community Resinvestment Coalition
President George W. Bush
Senators John Kerry and John Edwards
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