From: Jamison Williams [mailto:cheezerj7@yahoo.com]
Sent: Tuesday, April 06, 2004 4:08 PM
To: regs.comments@occ.treas.gov; regs.comments@federalreserve.gov; Comments;
regs.comments@ots.treas.gov
Cc: president@whitehouse.gov; linda.figura@do.treas.gov
Subject: Withdraw CRA Changes
>April 6,
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 Officials of Federal Bank and Thrift Agencies:
>
> I am a concerned citizen writing to urge you to WITHDRAW the currently
> proposed changes to the Community Reinvestment Act (CRA) regulations.
>
> CRA has been instrumental in increasing access to homeownership,
boosting
> economic development, and expanding small businesses in the nation's
> minority, immigrant, and low- and moderate-income communities.
However,
> the proposed changes are contrary to the CRA statute because they
will
> halt the progress made in community reinvestment and undermine
its
purpose.
>
> The proposed changes will eliminate the investment and service
parts
of
> the CRA exam for banks and thrifts with assets between $250 and
$500
> million. This would reduce the rigor of CRA exams for 1,111 banks
that
> account for more than $387 billion in assets. These not-so-small
banks
> may seem insignificant in the comparison with prominent megabanks,
but
> they have a huge impact on the communities they serve. In turn,
> communities deserve the right to have those banks monitored and,
if
> necessary, disciplined for neglectful and harmful behavior. It
is
> imperative that banks fulfill their public obligation to serve
ALL of
> their community, without fair exclusion and without predatory
practices.
> Limiting the means by which you can monitor this is unacceptable
and
> contradictory to the original purpose of CRA.
>
>
The changes also contain an "anti"-predatory lending
standard that
will
> actually perpetuate abusive lending. In this proposal, the new
definition
>
of "predatory" is very narrow and, ultimately, CRA exams
will allow
> abusive lending as packing fees into mortgage loans, high prepayment
> penalties, loan flipping, mandatory arbitration, and other numerous
abuses
>
won't be considered "predatory". Rigorous fair lending
audits and
severe
> penalties on
> CRA exams for abusive lending are NECESSARY in order to ensure
that
the
> new minority homeowners served by the Administration are protected.
Yet,
> the proposed predatory lending standard will NOT provide these
necessary
> protections.
>
> CRA is too vital to be gutted by harmful regulatory changes and
> neglect. Please help save our communities by withdrawing these
harmful
> proposed changes. I thank you for your attention to this critical
matter.
>
> Sincerely,
Jamison Williams
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