Community Development Corporation of Long Island,
Inc.
From: Teresa Arellano
Sent: Monday, August 30, 2004 2:56 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
TO: FDIC
My name is Wilbur Klatsky and I am the President of Community
Development Corporation of Long Island, Inc. (“CDC”),
a not-for-profit with over 35 years of a track record.
We serve a population of approximately 3 million and the
corporation has a broad mission responding to the housing
needs of the underserved and providing capital to small
businesses who are being declined by the traditional banking
community. We continue to maintain a strong relationship
with all of the money center banks as well as the regional “small” banks.
The not-for-profit industry is doing the heavy lifting
that traditional banks both small and large find not within
their strategic plans. We fully understand that the banking
community must report to their investors and they are required
to provide a satisfactory return. This profit is critical
to their livelihood. The not-for-profit industry devotes
its resources to these market niches, i.e. housing and
small businesses, which do not meet the banking community’s
financial goals. CDC and other not-for-profits, both locally
and nationally, have secured much of these needed resources
from our banking partners. This has been a partnership
of material interest. Our banking partners within our region
include money center banks such as Citibank, JPMorgan Chase,
Bank of New York, HSBC, Bank of America as well as local,
regional banks such as Bank of Smithtown, Astoria Federal
Savings, New York Community Bank, Ridgewood Savings Bank
and First Bank of Long Island to name but a few.
While it is difficult to ascertain how much of this on
going financial support is a direct result of the Community
Reinvestment Act, it is certainly clear that it has been
a major influence meeting the Community Reinvestment Act
services or investment test. From our perspective, the
trend of gutting the Community Reinvestment Act by the
proposed FDIC and OTC changes is a race to the bottom.
If these regulations are approved, it is only a matter
of time that the Federal Reserve and the OCC follow. What
makes this all the more critical is the most recent information
from the recent census reports which reveal that those
in poverty are growing astronomically in our country.
The safety net we are all speaking about is in the process
of being withdrawn. We are categorically recommending that
the current Community Reinvestment Act not be revised to
permit the so called smaller banks to be relieved of their
obligations.
I am available for any additional comments, if required.
Wilbur Klatsky
Community Development Corporation of Long Island, Inc.
2100 Middle Country Road - Suite 300
Centereach, New York 11720
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