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FDIC Federal Register Citations Amy Harlib New York, NY January 7, 2006 Robert Feldman Federal Deposit Insurance Commission 550 17th Street, NW., DC 20429 Dear Robert Feldman: A strong Community Reinvestment Act (CRA) services test ensures that low-income individuals and families can begin a relationship with a financial institution. Accessing financial services helps low-income individuals enter the financial mainstream, which enables them to save money and build assets. 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 the opportunity to comment on the need for a strong CRA. Sincerely, Amy Harlib
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Last Updated 01/09/2006 | Regs@fdic.gov |