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Trillium Asset Management, Inc.
From: Steve Lippman
[mailto:slippman@trilliuminvest.com]
Sent: Tuesday, April 06, 2004 12:08 AM
To: regs.comments@occ.treas.gov; regs.comments@federalreserve.gov;
Comments;
regs.comments@ots.treas.gov
Subject: Comments on Proposed Changes of Community Reinvestment Act
Regulations
April 5, 2004
Docket No. 04-06
Communications Division
Public Information Room, Mailstop 1-5
Office of the Comptroller of the Currency
250 E St. SW,
Washington 20219
Docket No. R-1181
Jennifer J. Johnson
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington DC 20551
Robert E. Feldman
Executive Secretary
Attention: Comments
Federal Deposit Insurance Corporation
550 17th St NW
Washington DC 20429
Regulation Comments, Attention: No. 2004-04
Chief Counsel's Office
Office of Thrift Supervision
1700 G Street NW
Washington DC 20552
Dear Officials of Federal Bank and Thrift Agencies:
Trillium Asset Management is a 20-year old socially responsible asset
management firm, with a strong commitment to socially responsible
investment and community investment. We are one of only a few active
asset management firms with more than 1% of assets under management in
community investment instruments. (At Trillium Asset Management, all
community investments are client-directed. Our investment team provides
both analytical and administrative support to clients wishing to direct
capital to underserved communities. Trillium Asset Management analyzes
investment opportunities with community development banks, credit
unions, loan funds, and other non-profit organizations.) We also
encourage many of the private banks, insurance companies, and other
financial institutions we invest in to engage in responsible lending
practices and vigorously meet their obligations under the Community
Reinvestment Act (CRA).
Given our support for community investing and the goals of the CRA,
we are writing to express our strong concern regarding some of the
pending proposed changes to CRA regulations. While we support the
proposed expansion of data collection and reporting for small businesses
and home lending, we have significant concerns about certain other
elements of the proposal. In particular, we have concerns about the
detrimental impacts of the proposed weakening of CRA exams for banks
with with assets between $250 million and $500 million. We strongly feel
that implementation of the CRA program would be better served if this
element of the proposal was withdrawn. In fact, we would like to see the
final rules strengthen CRA exams by requiring financial institutions to
include all affiliates, in order to prevent manipulation of CRA exam
results. We also have concerns that the predatory lending screen
proposed fails to protect individuals from many types of abusive lending
practices, including packing of fees into mortgage loans, high
prepayment penalties, loan flipping, and mandatory arbitration.
We strongly believe the proposed changes under consideration seem
contrary to the CRA statute and threaten to hinder progress made in
community reinvestment. The proposed changes also seem to thwart the
Bush Administration's goals of improving the economic status of
immigrants and creating 5.5 million new minority homeowners by the end
of the decade. Instead, the proposed CRA changes would facilitate
predatory lending and reduce the ability of the general public to hold
financial institutions accountable for compliance with consumer
protection laws. As an institution committed to promoting community
investment in the U.S., and asking the private banks and financial
institutions we invest in to be accountable to do the same, we urge you
to strengthen rather than weaken CRA protections for low- and
moderate-income Americans and communities.
Thank you or the opportunity to provide comments on this important
issue.
Sincerely,
Steve Lippman
Senior Social Research Analyst
Trillium Asset Management, Inc.
Boston, MA
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