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FDIC Federal Register Citations




UNIVERSITY NEIGHBORHOOD HOUSING PROGRAM


From: JBucUNHP@aol.com [mailto:JBucUNHP@aol.com]
Sent: Tuesday, April 06, 2004 12:57 PM
To: regs.comments@occ.treas.gov; regs.comments@federalreserve.gov; Comments; regscomments@ots.treas.gov
Subject: Comments on Regulations

University Neighborhood Housing Program
2751 Grand Concourse
Bronx, NY 10468
(718)933-3101
fax (718)933-3624
www.unhp.org


April 6, 2004

Docket No. 04-06
Communications Division
Public Information Room, Mailstop 1-5
Office of the Comptroller of the Currency
250 E St. SW,
Washington 20219

Docket No. R-1181
Jennifer J. Johnson
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington DC 20551

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


Regulation Comments, Attention: No. 2004-04
Chief Counsel's Office
Office of Thrift Supervision
1700 G Street NW
Washington DC 20552


Dear Officials of Federal Bank and Thrift Agencies:


UNHP is a Bronx-based non-profit organization that has worked closely with non-profit housing organizations, financial institutions and government agencies to bring reinvestment money back into our neighborhoods in the Bronx. Since our beginning in l983, we have worked closely with a number of financial institutions and their community reinvestment programs.

The importance of the Community Reinvestment Act and its accompanying regulations has always been clear to us in our work. It is based on that history that we make the following comments on the proposed regulatory changes.

We do not feel that the expansion of the streamlined CRA processes to banks with assets between $250 million and $500 million is justified. We understand that the proposed changes will eliminate the investment and service pieces of the CRA exam for those banks. Removing those requirements from so many institutions cannot be justified. For
example, these banks would no longer have as clear an inducement to invest in Low Income Housing Tax Credits, which have played a tremendous role in the reclamation of so much housing in our neighborhoods in the Bronx.

The revised regulations on predatory lending do not go far enough to protect homeowners and homebuyers. The proposed standard states that loans based on the foreclosure value of the property can negatively impact CRA ratings. We have seen many other types of predatory practices that should be included in the regulatory review. Excessive fees and rates should also be taken into accout.

Finally, some of the proposed changes on data disclosure and collection would be very useful in our analysis of bank practices. For instance separately reporting originations and high cost lending will be very useful in monitoring lending activities.

We urge you to look seriously at revising the proposed regulations to take into consideration our first two points. Thanks for your attention.

Jim Buckley
Director

 





Last Updated 04/23/2004 regs@fdic.gov

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