From: Ladd Van Tol [mailto:ladd@spiny.com]
Sent: Wednesday, March 31, 2004 10:39 AM
To: Comments
Subject: Attention: Comments
Robert E. Feldman; Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th St NW
Washington DC 20429
March 31, 2004
Dear Mr. Feldman:
As a banking customer I would like to urge you to change your proposed
Community Reinvestment Act (CRA) regulation before finalizing it.
I
believe you need a stronger predatory lending standard and I believe
you should keep the small bank definition as it is at $250 million
in
assets.
I hate rip-off
lenders who do what you call “asset-based lending” and
try to force borrowers into foreclosure so they can take over their
homes. However, there are a whole bunch of other ways that seemingly
good banks take advantage of customers who don’t understand
the loan
process. I think the regulators should use the CRA exams to penalize
lenders who push high cost loans with high fees and those who get
you
into a bad loan and then try to flip you into an even worse loan.
I
hate prepayment penalties that keep you from getting out of a bad
loan
and single premium credit insurance policies that cost a lot and
don’t
really help the customer. Lower a bank’s CRA rating when they
do stuff
like that.
The big banks are getting so big that to think they would actually
do
much for regular folks is a joke, so I hope you will pay more attention
to the smaller banks. They can do more if the regulators would only
encourage the larger of the small banks to support community
development lending and investments in smaller communities. Keeping
them on the large bank CRA exam will do more to encourage reinvestment
in the community than letting them take the small bank exam does.
I’m
asking you not to raise the asset threshold definition of a small
bank.
I believe that it is important for the larger small banks, which
have
more reason to pay attention to rural communities, to continue to
be
examined under the CRA large bank exam.
Thank you very much for paying attention to my concerns.
Sincerely,
Ladd Van Tol
Portland, OR 97209
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