I write as president of Progressive Redevelopment, the largest nonprofit
developer of affordable housing in the state of Georgia, to strongly
urge you not to eviscerate the CRA regulation by exempting banks
with under $1 billion in assets from its requirements.
Community development
as we know it can be divided into the “pre-CRA” and “post-CRA” eras.
As a 15-year veteran of community development and affordable housing
deals, I can attest that pre-CRA, it was an enormous struggle to
get the attention of banks to make safe and sound loans. An entire
industry has now evolved that is proficient in the cumbersome process
of multi-layered financing. As bad as this system is, it works to
some degree, by providing capital for housing for thousands of low-income
families that need it and investment in low-income communities that
otherwise would not have access to mainstream capital.
The CRA is arguably the most important legislation pertaining to
community development and affordable housing that we have. Public
subsidies are in scarce supply and appear to be diminishing. This
would be the worst possible time to eliminate regulatory incentives
to induce private capital to participate in community development
activities.
With wages not
keeping pace with rents in the lower quintile of incomes and with
public
subsidy programs under assault, the “least
of these” will be forced to endure worst housing and worsening
communities if this regulation is allowed to be gutted.
Thank you for this consideration. I would be pleased to provide
more information if that would be of any help in your deliberations.
