GREATER MILWAUKEE FOUNDATION
From: Sernorma Mitchell [mailto:smitchell@greatermkefdn.org]
Sent: Tuesday, April 06, 2004 4:58 PM
To: regs.comments@occ.treas.gov; regs.comments@federalreserve.gov;
Comments; regs.comments@ots.treas.gov
Cc: bethany_sanchez@hotmail.com; Jim Marks
Subject: Proposed Changes to CRA Regulations
April 6, 2004
Docket No. 04-06
Communications Division
Public Information Room Mailstop 1-5
Office of the Comptroller of the Currency
250 E Street SW,
Washington, DC 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 Street 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 funder of several human service organizations located in the
Milwaukee, Washington, Waukesha, and Ozaukee Counties, Wisconsin,
I am writing to object to the proposed changes to the Community Reinvestment
Act (CRA) regulations. The CRA has been instrumental in increasing
access to homeownership, boosting economic development, and expanding
small businesses opportunities to females, persons of color, and
economically disadvantaged persons throughout the United States and
in southeast Wisconsin. The proposed changes will have a negative
impact on the current CRA statute by streamlining exams for small
banks with assets between $250 million and $500 million, and establishing
a weak predatory lending compliance standard under $250 million.
The elimination of the investment and service test for more than
1,100 banks translates into considerably less access to banking services
and capital for underserved communities.
As background information, the Greater Milwaukee Foundation (GM Foundation)
is a community foundation started in 1915 to significantly improve
the quality of life of individuals residing in our targeted geographic
areas. The GM Foundation is a multi-purpose funder, made up of over
750 permanent charitable endowments, serving the four counties of
Milwaukee, Ozaukee Washington, and Waukesha. Two of the Foundation’s
grantmaking priority areas that the proposed changes will have a
financial impact include 1) impacting critical issues which negatively
affect child, youth and family development (in this instance support
is provided to nonprofits that assist first time homebuyers attain
homeownership, thus encourages family stability and builds wealth,
and 2) targeting small geographic areas through collaborative neighborhood
projects for housing, business and commercial development (in this
instance banks invest substantial dollars that make it possible for
a community foundation to provide "gap" funding). A significant
funding strategy for a community foundation is to leverage other
community and national resources. Rarely are we the only funder supporting
a home buying program, an affordable housing or commercial development.
In all instances the diminished participation of banks will make
it much more difficult to leverage limited philanthropic dollars.
We believe it will help contribute to more economic disinvestment
in lower income neighborhoods, thus increasing poverty. For these
reasons, we urge you to reconsider the proposed changes, so the existing
CRA may continue working towards increasing homeownership, prohibiting
redlining in neighborhoods, and discouraging predatory lending.
In closing, the GM Foundation supports the Metropolitan Milwaukee
Fair Housing Council (MMFHC) and their local and national affiliates
in opposing the proposed legislative changes. Should you have questions,
feel free to contact me
Sincerely,
Sernorma Mitchell
Program Officer
Greater Milwaukee Foundation
1020 N. Broadway
Milwaukee, WI 53202
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