Robert E. Feldman
Executive Secretary
FDIC
550 17th Street Northwest
Washington DC 20429
RE: Proposed Amendments to CRA Regulations
Dear Mr. Feldman:
I have two comments:
First, I believe that the definition of "Small Institution" should be
changed to less than $1 billion.
Second, I totally agree with your effort to address abusive lending
practices. A pattern of extending secured loans based on foreclosure
value where the borrower could not be expected to repay is despicable.
Further, I would expand the definition to include those Holding
Company's who have subsidiaries who offer "Pay Day" loans. These loans
often have APR's of 300% to 500% and should be considered in the same
realm as sub-par real estate financing.
Very truly yours,
W. Gerard Huiskamp
President
Blackhawk State Bank
Milan, IL 61264
