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From: Betty Folliard
[mailto:bfolliard@strategypartners.biz]
Sent: Friday, April 02, 2004 10:01 AM
To: Comments
Subject: CRA Regulations
Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th St NW
Washington DC 20429
Dear Officials of Federal Bank and Thrift Agencies:
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.
Rip-off lenders who do what you call "asset-based lending" 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.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
keep you from getting out of a bad loan and single premium credit
insurance policies that cost a lot but don't really help the customer
are simply wrong. Lower a bank's CRA rating when they partake in illegal
practices.
Please pay more attention to smaller banks. They can do more if the
regulators will 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 also support the position of the National Community Reinvestment
Coalition. Please help communities help themselves.
Thank you very much for paying attention to my concerns.
Sincerely,
Betty Folliard
Former MN State Representative
4220 Woodland Trail
Golden Valley MN 55422
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