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Connecticut Housing Coalition
April 5, 2004
Docket No. 04-06
Communications Division
Public Information Room, Mailstop 1-5
Office of the Comptroller of the Currency
250 E St. SW,
Washington 20219
Docket No. R-1181
Jennifer J. Johnson
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington DC 20551
Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th St NW
Washington DC 20429
Regulation Comments, Attention: No. 2004-04
Chief Counsel’s Office
Office of Thrift Supervision
1700 G Street NW
Washington DC 20552
Dear Federal Bank and Thrift Regulators:
The Connecticut Housing Coalition is a network of over 250
community-based, affordable housing organizations from across the state.
Our membership includes nonprofit developers, social service agencies,
resident associations, and diverse other affordable housing
practitioners and advocates.
We urge that the proposed changes to the Community Reinvestment Act (CRA)
regulations be withdrawn. We strongly support and associate ourselves
with the comments of the National Community Reinvestment Coalition (NCRC)
dated April 2, 2004. Rather than repeating the excellent and detailed
analysis provided by NCRC, we wish to incorporate them herein by
reference.
The Connecticut Housing Coalition is particularly concerned about the
proposal to expand the definition of “small institution” to include
institutions with total assets between $250 million and $500 million,
and thus significantly reduce the CRA review to which such institutions
are subject. We respectfully differ with your assessment that the impact
of this change would be “only slightly reducing the portion of the
nation's bank and thrift assets subject to evaluation under the large
retail institution performance standards.”
In Connecticut alone, 10 banks and thrifts with a total of more than
$3.6 billion in assets would be relieved of full CRA examination. This
number is 15.15%, that is more than one in seven, of our state’s lenders
subject to the CRA.
The elimination of the investment and service tests for these banks
and thrifts is especially troubling to us. For example, there would no
longer be CRA accountability for investment in Low Income Housing Tax
Credits or the availability of Individual Development Accounts. These
are vital tools for, respectively, the financing of multi-family rental
housing and helping low-income households to realize homeownership.
In conclusion, we believe that the current CRA regulatory burden upon
institutions with total assets between $250 million and $500 million is
modest and appropriate, and clearly outweighed by the enormous community
benefit of assuring high CRA performance.
Thank you for you consideration of our concerns.
Sincerely,
Jeffrey Freiser
Executive Director
Connecticut Housing Coalition
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