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From: Promise Partner [mailto:ppartner04@yahoo.com]
Sent: Wednesday, September 15, 2004 12:32 PM
To: Comments
Subject: RIN 3064-AC50
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429
Dear Mr. Feldman,
I am a concerned citizen opposed to watering down CRA (Community
Reinvestment Act) requirements for mid-sized banks. CRA is vital for
increasing homeownership and economic development in lower-income
communities. However, your proposed changes will halt the progress that
has been made.
Your proposal would eliminate the requirements that banks with assets
under $1 billion must provide services and investments to low and
moderate income individuals within the communities they serve. This will
result in significantly fewer loans and investments in affordable rental
housing, health clinics, community centers, and economic development
projects.
In the watered-down exam, you 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 less community development
activity.
You also propose that community development activities in rural areas
should benefit any group of individuals instead of only low- and
moderate-income individuals. But this will allow banks to cherry-pick
and focus on affluent residents of rural areas rather than the lower
income consumers CRA targets. Finally, you would also eliminate publicly
available data on the 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.
Your changes directly oppose CRA’s mandate to require lenders to meet
community needs. CRA is too important to be gutted. Please drop your
proposal like the two other federal agencies that recognized its harm to
underserved communities.
Sincerely,
Promise Partner
74 King Street
Burlington, VT 05401
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