| FUND FOR AN OPEN SOCIETY
August 31, 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
As the executive voice of a national organization dedicated to
promoting and sustaining communities of choice for racially and
ethnically robust markets, I am a critic of CRA regulations as they have
been and as they would not be improved by your proposed changes.
Integrated and balanced living patterns and robust markets, an
American ideal that was anticipated to be furthered by the 1968 Civil
Rights Act, Title VIII and by CRA, continue to elude establishment in
much of America. In part, this is because of over-reliance on
place-based—and, therefore race-based, given segregation levels--housing
and community reinvestment policy and regulation. Giving (double)
community-support credit for investments and services to lower-income
and minority people in lower-income and minority areas is predictably
segregative.
In their well-vetted book, American Apartheid, "Massey and Denton
provide unambiguous evidence that residential segregation is the major
factor accounting for the black underclass," avers Reynolds Farley,
renown scholar. George Galster and other economists agree.
Financial institutions should be investing in removal of ghetto
chains that bind too many people in geography of low opportunity.
Instead, CRA credits are distributed for making the chains of American
Apartheid more comfortable. And this kind of outcome is largely hidden
even from those well-intentioned people representing both financial and
community intereasts. How does this happen? It happens because CRA
regulations do not require or even encourage
integration/segregation-impact analysis. Separate and unequal prevails
in a system that does not measure it and correct for it.
Your proposal may achieve less segregation by requiring less of
financial Institutions, but that is not the way to fix what is wrong.
Sincerely,
Don DeMarco
Acting Executive Director
Fund for an Open Society
The Philadelphia Building #1708
1315 Walnut Street
Philadelphia, PA 19107
|
