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ASSOCIATION FOR CHILDREN OF NEW JERSEY From: Presser, Sheldon
[mailto:spresser@acnj.org]
Sent: Thursday, April 01, 2004 11:42 AM
To: Comments
Subject: Proposed changes to CRA regulations
Robert Feldman
Executive Secretary, FDIC
Dear Mr. Feldman:
The Association for Children of New Jersey (ACNJ) urges you to
withdraw the proposed changes to the Community Reinvestment Act (CRA)
regulations. CRA has been instrumental in increasing access to
homeownership, boosting economic development, and expanding small
businesses in the nation's minority, immigrant, and low- and
moderate-income communities. Proposed changes would halt the progress
made in community reinvestment, facilitate predatory lending and reduce
the ability of the general public to hold financial institutions
accountable for compliance with consumer protection laws.
Proposed changes will eliminate the investment and service parts of
the CRA exam for banks and thrifts with assets between $250 and $500
million, translating into considerably less access to banking services
and capital for underserved communities. For example, these banks would
no longer be held accountable for investing in Low Income Housing Tax
Credits -- a major source of affordable housing.
Proposed CRA changes will actually perpetuate abusive lending. The
proposed standard states that loans based on the foreclosure value of
the collateral, instead of the ability of the borrower to repay, can
result in downgrades in CRA ratings. This standard would fail to cover
many instances of predatory lending.
These proposed changes regarding streamlined exams and the
anti-predatory lending standard threaten CRA's statutory purpose. CRA is
too vital to be gutted by harmful regulatory changes and neglect. On
behalf of the New Jersey children and families we represent, thank you
for your attention to this critical matter.
Thank you for your consideration.
Sincerely,
Sheldon Presser
Senior Policy Analyst, Budget and Data
Association for Children of New Jersey
35 Halsey Street
Newark, NJ 07102
Voice - 973-643-3876 ext. 213
Fax - 973-643-9153
e-mail: spresser@acnj.org
http://www.acnj.org
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