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FDIC Federal Register Citations Roma Goodlander 517 Moody Street Waltham, MA 02453-0506 January 6, 2006 Robert Feldman Federal Deposit Insurance Commission 550 17th Street, NW., DC 20429 Dear Robert Feldman: Here at WATCH CDC, we rely on a strong CRA to carry out the important work that we do building affordable housing, running job training programs and doing community organizing. A strong CRA helps to multiple the benefits of the work we do by giving low and moderate income borrowers a chance to reach self-sufficiency. The most effective way to expand access to credit to underserved borrowers is to implement rigorous and comprehensive CRA exams that maintain the focus on meeting the credit and deposit needs of low- and moderate-income borrowers and communities. The final Q & A Notice should clarify that the community development exam criterion includes an examination of the number and percent of branches in low- and moderate-income communities. In addition, I recommend that the final Q &A Notice provide CRA points for the provision of low-cost banking services. CRA exams should also penalize banks for abusive products such as bounce protection, the wealth stripping features of which are not advertised clearly to consumers. Finally, I encourage the regulators to add an anti-predatory lending provision to the CRA regulations that will penalize banks for illegal, abusive, and discriminatory loans. Thank you for your interest in my comments and I hope you will do everything in your power to promote and protect a strong CRA. Sincerely, Roma Goodlander
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Last Updated 01/09/2006 | Regs@fdic.gov |