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VIA EMAIL
From: Arthi Varma Sent: Tuesday, February 25, 2003 2:21 PM To: Comments Subject: RE: Proposed Rule Part 303 February 25, 2003 Robert E. Feldman Executive Secretary Attention: Comments/ES Federal Deposit Insurance Corporation 550 17th St. NW Washington DC 20429 RE: Proposed Rule Part 303 Dear Mr. Feldman: The California Reinvestment Committee (CRC) opposes the FDIC's proposal to waive regulatory procedures on a case-by-case basis that are not required by statute. CRC is a nonprofit membership organization of more than two hundred nonprofit organizations and public agencies across California. Working with community-based organizations, CRC advocates for the economic revitalization of California's low-income communities and communities of color. CRC promotes increased access to credit for affordable housing and community economic development, and to financial services for these communities. If the FDIC waived regulations not required by statute, it is likely that the agency will waive public comment, public notice requirements, and other vital parts of the merger application process. Consequently, important public input on bank mergers and the effects on local communities will be limited. The public would have no recourse to a federal agency when a merger affects the well-being of their community. Public comments have motivated banks and federal agencies to address weaknesses in lender community reinvestment and fair lending performance. Therefore, eliminating public comment eliminates the chance to increase bank lending and investing after mergers. In order for a regulatory process to be fair to all parties, the federal agency cannot waive a process for some banks and not others. Waivers on a case-by-case basis are arbitrary and result in uneven regulatory enforcement. CRC urges the FDIC to withdraw this proposal. Sincerely, Alan Fisher Arthi Varma Executive Director Policy Advocate
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