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PORTLAND COMMUNITY REINVESTMENT INITIATIVES INC.
August 23, 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 a member of the National Congress of Community and Economic
Development and the executive director of a community development
corporation engaged in the development and management of affordable
housing, I implore you to withdraw the proposed changes to the Community
Reinvestment Act (CRA) regulations. CRA has been instrumental in
increasing homeownership, boosting economic development, and expanding
small businesses in the nation's minority, immigrant, and low- and
moderate-income communities. Your proposed changes are contrary to the CRA statute and Congress' intent because they will slow down, if not
halt, the progress made in community reinvestment.
Many of the most significant changes in urban and rural neighborhoods
over the last 15 years are a result of the CRA related activities. The
proposed changes curtail future development in those very communities
that are beginning to show recovery in investment. It will also thwart
the Administration's goals of improving the economy and creating 5.5
million new minority homeowners, by the end of the decade. We cannot promote community revitalization and wealth building when legislation
that lead to such improvements in the past dramatically diminish banks'
obligation to reinvest in the communities where they get their
customers?
Eliminating the need to monitor required investment and service parts of
the CRA exam for state-charted banks with assets between $250 million
and $1 billion 'is not the answer to the problem. Please keep in place
the community development criterion that requires banks to offer
community development loans, investments or services in communities
which they are located.
There is a national commitment to change this decision. I suspect you
have received large volumes of letter in protest; letters that enumerate
the problem this change will cause. Therefore, I won't go into all the
details. I will simply ask for your advanced consideration of a proposed
drastic measure.
Please feel free to contact me if you have any questions regarding
this letter.
Sincerely,
Maxine Fitzpatrick
Executive Director
Portland Community Reinvestment Initiatives Inc.
4829 N. E. Marting Luther King Jr., Blvd.
Portland, OR 97211
CC: National Congress for Community and Economic Development
National
Community Reinvestment Coalition
President George W. Bush
Senators John Kerry and John Edwards
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