WNC & ASSOCIATES, INC.
From: NAAHL
Sent: Wednesday, September 08, 2004 3:46 PM
To: Comments
Subject: RIN number 3064-AC50
September 8, 2004
Donald E. Powell
Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
Re: RIN Number 3064-AC50
Dear Mr. Powell:
As I indicated
in my letter of August 6, 2004 (below), WNC & Associates
believes that the FDIC's proposal to quadruple the asset threshold
for the "streamlined" CRA exam to $1 billion will harm
affordable housing and community and economic development in LMI
communities, particularly in rural areas, and we urge you not to
adopt it.
Sincerely,
Wilfred N. Copper, Sr.
Chairman of the Board
WNC & ASSOCIATES,
INC.
August 13, 2004
Donald E. Powell
Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429
John M. Reich
Vice Chairman
Federal Deposit Insurance Corporation
550 17th Street,
NW
Washington, DC 20429
Thomas J. Curry
Director
Federal Deposit Insurance Corporation
550 17th Street,
NW
Washington, DC 20429
John D. Hawke, Jr.
Comptroller of the Currency
Office of the Comptroller of the Currency
250E Street, SW
Washington, DC 20219
Dear Sirs:
WNC is a national real estate company with over three decades of
experience investing in affordable rental housing. The company is
headquartered in California and has acquired a portfolio of affordable
housing with a cost of over $2 billion representing more than 800
properties in 40 states and the District of Columbia. Since 1971,
WNC and its affiliates have acquired and/or structured investments
in more than 150 affordable rental properties in California.
We understand that the FDIC shortly will consider a proposed rule
change by the Office of Thrift Supervision (OTS) to increase the
asset threshold for the CRA small bank exam from $250 million to
$1 billion. We believe this proposal could have negative consequences
for hundreds of communities, including many in rural areas, and we
urge you not to adopt it.
While we understand
that the OTS ruling is intended to help reduce regulatory burden
for
small banks, no studies have been conducted
on the potential benefits – or harm – of such a change.
There is considerable evidence to believe that proposal could have
severe, unintended consequences for the flow of much-needed private
capital and services to LMI communities.
If the FDIC adopts
the OTS' proposal, 2,000 fewer insured institutions, with assets
of
nearly $1 trillion, would have far less impetus to
provide investments and services in LMI communities – and an
estimated $5 billion that would have been available, under the current
rules, for affordable housing and community development over the
next few years would be lost.
As an example, in California the impact will be even greater, because
banks of this size make up a greater proportion of financial institutions
here than in the nation as a whole. Also, because institutions
with assets between $250 million and $1 billion comprise a substantial
market share in rural and exurban areas, the proposed change also
means that in some states and many communities there will no longer
be any insured institutions with a CRA impetus to invest in affordable
housing, tax credits, and even fmancial literacy training. This
would have a disproportionate impact in the Central Coast, Northern
California, and the fast-growing Central Valley and Sierra Foothills.
As federal resources for affordable housing and community development
continue to dwindle, our nation's poorest communities can ill-afford
to lose billions of dollars in private investment and services. We
urge the FDIC not to move forward with OTS' proposal, and we urge
all four bank regulatory agencies to continue to consider rule changes
that update CRA for the communities the Act is intended to serve.
Sincerely,
Wilfred N. Cooper, Sr.
Chairman of the Board
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