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LOCAL ECONOMIC & EMPLOYMENT DEVELOPMENT COUNCIL
From:
Ted Wysocki [mailto:tedwysocki@prodigy.net]
Sent: Thursday, September 02, 2004 9:00 PM
To: Comments
Subject: RIN 3064-AC50
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:
As a member of the National Community Reinvestment Coalition, the
Local Economic & Employment Development Council urges you to withdraw
your proposed changes to the Community Reinvestment Act (CRA)
regulations which will significantly water down CRA requirements for
mid-sized banks. Over 60 banks and thrifts in Illinois will no longer be
subject to the large bank CRA exam under the FDIC's proposed changes to
CRA regulation.
CRA has been instrumental in increasing homeownership, boosting
economic development, and expanding small businesses in our nation’s
minority, immigrant, and low- and moderate-income communities. Your
proposed changes are contrary to the CRA statute and Congressional
intent because they will slow down, if not halt, the progress made in
community reinvestment.
Your proposal to eliminate the investment and service requirements
for all banks with under $1 billion in assets will result in
significantly fewer loans and investments in affordable rental housing,
health clinics, community centers, and economic development projects.
You should not allow mid-sized banks to choose which community
development activities they will undertake. At present, these banks must
make community development loans, investments, and services. Your
proposed test allows banks to choose only one of these three activities.
Community reinvestment should not be a multiple choice. Our communities
require comprehensive development financing.
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 to the neglect of other
rural credit needs. Finally, you would eliminate publicly available data
on the small business lending of mid-sized banks. Data is essential for
holding banks accountable for lending to small businesses.
The FDIC is directly dismantling CRA’s Congressional mandate to
require lenders to meet community needs. CRA is too important for the
American economy to be gutted. Cease and desist on this proposal like
the Federal Reserve Board and the Office of the Comptroller of the
Currency, which recognized the harm that this proposal would do to
underserved communities.
Sincerely,
Ted Wysocki, President & CEO
Local Economic & Employment Development Council
1866 N. Marcey Chicago, IL 60614
Cc:
National Community Reinvestment Coalition
President George W. Bush
Senators John Kerry and John Edwards
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