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From: Sarah Brennan [mailto:sarahcbrennan@yahoo.com]
Sent: Thursday, September 16, 2004 11:15 AM
To: Comments
Cc: ssiddiqi@ncrc.org
Subject: RIN 3064-AC50, Community Reinvestment
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
I am a concerned citizen writing to express my opposition to your
proposed changes to Community Reinvestment Act requirements for
mid-sized banks. CRA is integral for increasing homeownership and
advancing economic development in low and moderate income communities.
However, your proposed changes will halt the progress that has been
made.
I understand that banks with over $250 million in assets must be
tested on their number of loans, investments, and services to low- and
moderate-income communities. But your proposal would eliminate the
investment and service requirements for all banks with under $1 billion
in assets. This will result in significantly fewer loans and investments
in affordable rental housing, health clinics, community centers, and
economic development projects.
In this 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,
Sarah Brennan
38 Kings Highway North
Westport, CT 06880-3001
Cc: National Community Reinvestment Coalition |
