I represent a Habitat for Humanity affiliate in southeastern Washington.
We have been community partners in the effort to develop affordable
housing for this area since 1991. The Community Reinvestment Act is a
critical component to our community’s affordable housing and community
development solutions. On behalf of the Board of Directors of this
organization we oppose any increase to the threshold of what is
considered to be a small bank. The proposed FDIC rule would exempt many
of our community’s critical partners from requirements currently in
place. If the proposed change were to go in to effect, 73% of the banks
in the state of Washington will be exempt from investing in the low
income community. We urge the FDIC to withdraw its proposed rule and
maintain the effective and productive threshold currently in force.
