| ENROLLED MEMBER OF THE
CROW TRIBE OF INDIANS, MT
From:
Cynthia Jurosek [mailto:crowindianland@yahoo.com]
Sent: Saturday, September 11, 2004 12:46 PM
To: Comments
Subject: Proposed changes to CRA; Attn: Comments
Mr. Robert Feldman; Executive Secretary Re: RIN 3064-AC50
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429
Attn: Comments/Legal ESS
Dear Mr. Feldman,
This is to adamantly urge the FDIC to withdraw its proposed changes
to the Community Reinvestment Act. The FDIC's proposed changes will
thwart the Administration's goals of creating 5.5 million new minority
homeowners by the end of this decade; they will eliminate the investment
and service parts of the CRA exam for state-chartered banks with assets
between $250 million and $1 billion; and, additionally, as I understand
it, the FDIC proposes to add a community development criterion which
seems to be a sort of alternative remedy for what it proposes to
eliminate.
These proposed changes are unquestionably contrary to the CRA Statute
and the lawmakers intent of increasing homeownership and community
development in low-moderate income communities. The proposed alternative
remedy is not in the best interests of any community because it would
allow banks to choose a community development activity that is easiest
for them. Here is the problem with that: In rural areas, and states such
as Montana with smaller populations, a large percentage of banks,
including state-chartered and small banks, have an intolerable habit of
"choosing" to reinvest their community development funds in their
"wealthy and substantive friends" and youth organizations of such
people--which is fine for them to do, however it is not fine for them to
do it under the umbrella of the CRA--the CRA is for low-moderate income
people, minorities, the underserved and those less fortunate--it is not
to benefit the wealthy, the elite or the fortunate. The FDIC's proposed
changes will defeat the CRA's true purpose.
If the FDIC goes forward with its proposed changes many low-moderate
income communities, including Native Americans in both urban and rural
areas, will suffer. Won't you please reconsider and leave the CRA as is?
Thank you for your consideration.
Very truly,
Cynthia Jurosek
Enrolled Member of the Crow Tribe of Indians, MT
Cc: Senate Members
Cc: House Members
Cc: Various Others
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