From: David Lawrence
[mailto:srvpgc@hotmail.com]
Sent: Thursday, April 01, 2004 5:42 PM
To: regs.comments@occ.treas.gov; regs.comments@federalreserve.gov;
Comments;
regs.comments@ots.treas.gov
Subject: Proposed CRA Regs.
April 1, 2004
Dear Officials of Federal Bank and Thrift Agencies:
As a banking customer in Juneau, Alaska, I would like to urge you to
change your proposed Community Reinvestment Act (CRA) regulation before
finalizing it. I believe you need a stronger predatory lending standard
and I believe you should keep the small bank definition as it is at $250
million in assets.
I do not sympathize with disreputable lenders who do what you call
"asset-based lending" and try to force borrowers into foreclosure so
they can take over their homes. However, there are many other ways that
seemingly good banks take advantage of customers who don't understand
the loan process. I urge regulators to use the CRA exams to penalize
lenders who push high cost loans with high fees and those who get people
into a bad loan and then try to flip them into an even worse loan. I
also dislike prepayment penalties that keep people from getting out of
bad loans and single premium credit insurance policies that cost a lot
but don't really help the customer. The possibility that you will lower
a bank's CRA rating when tjey act in this way will discourage this
negative behavior.
The larger banks are getting so big that they seem to have minimal
interest in smaller borrowers, so I hope you will pay more attention to
the smaller banks. They can do more if the regulators would only
encourage the larger of the small banks to support community development
lending and investments in smaller communities. Keeping them on the
large bank CRA exam will do more to encourage reinvestment in the
community than letting them take the small bank exam does. I'm asking
you not to raise the asset threshold definition of a small bank.
I also support the position of the National Community Reinvestment
Coalition.
Thank you very much for paying attention to my concerns.