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FDIC Federal Register Citations

From: Arthi Varma 
Sent: Tuesday, February 25, 2003 2:21 PM
To: Comments
Subject: RE: Proposed Rule Part 303

February 25, 2003

Robert E. Feldman
Executive Secretary
Attention: Comments/ES
Federal Deposit Insurance Corporation
550 17th St. NW
Washington DC 20429

RE: Proposed Rule Part 303

Dear Mr. Feldman:

The California Reinvestment Committee (CRC) opposes the FDIC's proposal 
to waiveregulatory procedures on a case-by-case basis that are not required
by statute. CRC is a nonprofit membership organization of more than two
hundred nonprofit organizations and public agencies across California.
Working with community-based organizations, CRC advocates for the economic
revitalization of California's low-income communities and communities 
of color. CRC promotes increased access to credit for affordable housing
and community economic development, and to financial services 
for these communities.

If the FDIC waived regulations not required by statute, it is likely 
that the agency will waive public comment, public notice requirements, 
and other vital parts of the merger application process. Consequently,
important public input on bank mergers and the effects on local 
communities will be limited. The public would have no recourse to a
federal agency when a merger affects the well-being of their community. 
Public comments have motivated banks and federal agencies to address 
weaknesses in lender community reinvestment and fair lending performance. 
Therefore, eliminating public comment eliminates the chance to increase
bank lending and investing after mergers.

In order for a regulatory process to be fair to all parties, the federal 
agency cannot waive a process for some banks and not others. Waivers on 
a case-by-case basis are arbitrary and result in uneven regulatory 
enforcement. CRC urges the FDIC to withdraw this proposal.

Alan Fisher
Arthi Varma
Executive Director Policy Advocate
Last Updated 02/26/2003

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