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From: RONALD MINIONIS [mailto:rminionis@lsnv.org]
Sent: Wednesday, September 01, 2004 6:05 PM
To: Comments
Cc: cford@ncrc.org
Subject: FW: [Consumer law] A message from the National Community
Reinvestment Coalition
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
I am a concerned citizen opposed to watering down CRA (Community
Reinvestment Act) requirements for mid-sized banks. CRA is vital for
increasing homeownership and economic development in lower-income
communities. However, your proposed changes will halt the progress that
has been made. I understand that banks with over $250 million in assets
must be tested on their number of loans, investments, and services to
low- and moderate-income communities. But your proposal would eliminate
the investment and service requirements for all banks with under $1
billion in assets. This will result in significantly fewer loans and
investments in affordable rental housing, health clinics, community
centers, and economic development projects. In the watered-down exam,
you would allow mid-sized banks to choose which community development
activities they will undertake. Right now, these banks must make
community development loans, investments, and services. Your proposed
test allows banks to choose only one of the three activities. The result
will be less community development activity. You also propose that
community development activities in rural areas should benefit any group
of individuals instead of only low- and moderate-income individuals. But
this will allow banks to cherry-pick and focus on affluent residents of
rural areas rather than the lower income consumers CRA targets. Finally,
you would also eliminate publicly available data on the small business
lending of mid-sized banks. Without data, community groups and citizens
cannot hold banks accountable for lending to small businesses in their
neighborhoods. Your changes directly oppose CRA¹s mandate to require
lenders to meet community needs. CRA is too important to be gutted.
Please drop your proposal like the two other federal agencies that
recognized its harm to underserved communities.
Sincerely,
Ronald V. Minionis
8611 Dora Ct.
Annandale, VA 22003
Cc:
National Community Reinvestment Coalition
President George W. Bush
Senators John Kerry and John Edwards
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