Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/ Legal ESS
Federal Deposit Insurance Corporation
550 17th St. N.W. 20429
Washington D.C.
RE: Changes to Community Reinvestment Act
RIN AC50
Dear Mr. Feldman,
Mountainlands Community Housing Trust is a 501 (c) (3) non-profit
corporation doing business in Summit County, Utah. Our mission is to
promote, preserve and develop affordable housing and to provide services
to low income residents of our community. It has come to my attention
that the FDIC is considering changes to the National Community
Reinvestment Act (“CRA”) to limit the requirements for banks with assets
between $250 million and $1 billion dollars.
CRA has been critical in our rural area in, not only supporting our
organization, but providing loans and assistance to low and moderate
income residents. We have found that the mid-size banks not only take
the obligations of CRA seriously, but they are the ones assisting their
local communities by providing the time of employees and other resources
to make their communities better for those in need. The larger banks
have national policies that have proven to be inflexible in many
situations. The mid-sized banks provide flexibility in meeting the needs
for development, preservation and financing for affordable housing and
other community needs. Although, never specifically mentioned, it is
clear that CRA requirements are the motivating factor in implementing
this flexibility and support.
I urge you to re-consider this limitation and to maintain status quo
for the present CRA requirements affecting mid-size banks. Thank you for
your consideration of this matter.
Sincerely,
Scott Loomis
Executive Director
Mountainlands Community Housing Trust
1960 Sidewinder Drive Suite 107
Park City, Utah 84060
(435) 647-9719
