Astor Place Neighborhood Association
From: MLMAssocAICP@aol.com
[mailto:MLMAssocAICP@aol.com]
Sent: Monday, April 05, 2004 4:27 PM
To: regs.comments@occ.treas.gov; regs.comments@federalreserve.gov;
Comments; comments@ots.treas.gov
Cc: jsilver@ncrc.org; cford@ncrc.org
Subject: Proposed Changes to Community Reinvestment Act (CRA)
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:
As a member of the National Community Reinvestment Coalition, the
Astor Place Neighborhood Association urges you to withdraw the proposed
changes to the Community Reinvestment Act (CRA) regulations. These
changes, if adopted, would make it even more difficult for community
development organizations such as ours to obtain financing for projects
in distressed areas.
The proposed changes include three major elements: 1) provide
streamlined and cursory exams for banks with assets between $250 million
and $500 million; 2) establish a weak predatory lending compliance
standard under CRA; and 3) expand data collection and reporting for
small business and home lending. The beneficial impacts of the third
proposal are overwhelmed by the damage imposed by the first two
proposals.
The proposals for streamlined exams for banks and thrifts with assets
between $250 and $500 million would reduce the rigor of CRA exams for
1,111 banks that account for more than $387 billion in assets. The
elimination of the investment and service tests for these banks would
translate into considerably less access to banking services and capital
for underserved communities.
For example, these banks would no longer be held accountable under
CRA exams for investing in Low Income Housing Tax Credits, which have
been a major source of affordable rental housing needed by large numbers
of immigrants and lower income segments of the minority population.
Likewise, the banks would no longer be held accountable for the
provision of bank branches, checking accounts, Individual Development
Accounts (IDAs), or debit card services. Thus, the effectiveness of the
Administration's housing and community development programs would be
diminished. Moreover, if the investment and service test is eliminated
for a large subset of depository institutions,the federal bank agencies
will fail to enforce CRA's statutory requirement that banks have a
continuing and affirmative obligation to serve credit and deposit needs.
CRA has been instrumental in increasing access to 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 because they will
halt the progress made in community reinvestment.
The proposed CRA changes will thwart the 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.
Please do not let this happen. CRA is too vital to be gutted by
harmful regulatory changes and neglect.
Thank you for your attention to this critical matter.
Sincerely,
Mary L. McLean
President
Astor Place Neighborhood Association
90 Astor Place
Jersey City, NJ 07304
Cc: National Community Reinvestment Coalition
President George W. Bush
Treasury Secretary John W. Snow
