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FDIC Federal Register Citations

ShoreBank

From: Frances Grossman
Sent: Wednesday, September 08, 2004 3:54 PM
To: Comments
Subject: RIN number 3064-AC50

September 8, 2004


Donald E. Powell
Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429


Re: RIN Number 3064-AC50

Dear Mr. Powell:

As I indicated in my letter of August 18 , 2004 (see below), ShoreBank believes that the FDIC’s proposal to quadruple the asset threshold for the ”streamlined” CRA exam to $1 billion will harm affordable housing and community and economic development in LMI communities, particularly in rural areas, and we urge you not to adopt it.


Sincerely,

Frances Grossman
Executive Vice President


ShoreBank


August 18, 2004

Mr. Donald E. Powell
Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Dear Chairman Powell:

ShoreBank is the first and leading community development and environmental financial institution in the U.S. With $1.6 billion in assets and three regulated financial institutions around the county – in Illinois/ Michigan (ShoreBank in Chicago/Detroit), Washington (ShoreBank Pacific) and Ohio (ShoreBank Cleveland) – a number of nonprofits in those same states plus Oregon as well as a national and international consulting company, we are concerned about the impact of the proposal to reduce the number of CRA lenders.

Since 1973, ShoreBank in Chicago has provided more than $905 million in funds for mortgages and rehabbing of walk-up apartment buildings that provide 38,654 units of unsubsidized affordable housing. In addition, we provide financial services to approximately 1,500 faith based organizations and small nonprofits. We are also an important source of credit and financial services to small businesses critical to the neighborhoods we serve on the south mid-south and west sides of the city.

Many regulated institutions are “motivated” to increase their lending and investments in low- and moderate-income (LMI) communities and institutions because of CRA. We are concerned that changes in the threshold will have a serious negative impact on the work that is being done to provide credit in and to communities and individuals who require more complicated and therefore, more time consuming and consequently, less profitable services.

These small but complex customers are the ones that do not often fit in a standardized and easily replicable program, but they are responsible borrowers. They can and should be able to access the great American banking system. It is in part because of CRA that institutions like ours can and do provide them with needed and good service. We urge you to not reduce the number of CRA lenders in order to allow us and others to continue to serve this vital segment of the marketplace.

I would be happy to discuss this further with you or any of your staff. Please contact me at 773-420-4903 or fran_grossman@sbk.com.

Sincerely,
Fran Grossman
Executive Vice President

Last Updated 09/09/2004 regs@fdic.gov

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