From: Juana Escobedo Teixeira [mailto:CycleRyder_admin@bellsouth.net]
Sent: Tuesday, September 07, 2004 3:45 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
The proposed rules to
revise the definition of a "small bank'' to raise the asset size
threshold to $1 billion is excessive. While I can understand a need to
revise the threshold to reduce the burden on smaller institutions, it is
important to ensure that the spirt of the CRA-- to ensure credit and
banking services to low- and moderate-income (LTM) consumers-- is not
violated.. Based on my experience as a former bank examiner for the OCC,
the OTS, and the Federal Reserve, and who conducted several CRA
examinations under the latest rules, raising the threshold from $250MM
to $1 billion will impact on low- and moderate-income communities in
larger MSAs, as it is likely that under the increased thresholds,
institutions will feel less pressure to demonstrate how they have served
their local communities. Consumers in those LTM groups would likely find
reduced access to credit and their banking options would be limited to
the larger regional, national banks. This lack of options and decreased
competitive bank services would translate to higher banking costs and a
limited array of services for an already unbanked group of Americans.
Once again, we would find the infamous situation of butique banks that
focus their market on wealthier customers serving their CRA obligations
through token charity donations and activities.
What LTM consumers need are real and definite options for accessing
credit and banking services to fund their home and consumer goods
purchase and finance their small business. The access to real and
affordable credit is already reduced given the financial woes of local
governments. Consequently, the private sector is the primary option for
these services. So I urge the regulatory authorities to weigh the need
for reducing the administrative burden on banks and examination staff
with the needs of an ever-expanding group (given recent census
statistics on poverty levels in this country) of Americans.
Sincerely,
Juana Escobedo Teixeira
4079 Brookside Manor Drive
Tucker, GA 30084