HOUSING OPPORTUNITIES MADE EQUAL
From: Scott W. Gehl [mailto:sgehl@homeny.org]
Sent: Thursday, September 16, 2004 4:38 PM
To: Comments
Subject: RIN 3064-AC50
Dear Mr. Feldman:
Housing Opportunities Made Equal is a civil rights organization
which, since 1963, has led the struggle for fair housing in Western New
York.
As the executive director of HOME, I must respectfully oppose the
FDIC’s proposed weakening of the Community Reinvestment Act (CRA). The
FDIC’s proposal would lessen CRA requirements for banks between $250
million to $1 billion in assets. This proposal will result in much fewer
home and small business loans to low- and moderate-income borrowers and
much fewer community development loans and investments in low- and
moderate-income communities.
In addition, you propose that all FDIC-supervised banks can earn CRA
points by financing community development projects that benefit affluent
residents in rural areas, instead of low- and moderate-income consumers
and communities in rural America. This is directly contrary to CRA’s
focus on meeting credit needs of low- and moderate-income communities.
In sum, your proposal to change the CRA regulation will result in much
fewer loans, investments, and branches in low- and moderate-income
communities.
We respectfully request that you withdraw this injurious proposal.
Sincerely,
Scott W. Gehl, Executive Director
Housing Opportunities Made Equal, Inc.
700 Main St/ Buffalo, NY/ 14202
(716) 854-1400 FAX: (716) 854-1140
HOME is a civil rights organization which, since 1963, has led the
struggle for fair housing in Western New York. Membership information is
available on the web at www.homeny.org.
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