From: Jeremey Newberg
Sent: Thursday, August 26, 2004 11:36 AM
To: Comments
Subject: Proposed Changes to CRA
Dear Sir / Madame:
As a former member of the Community Investment staff of the Federal
Reserve Bank of San Francisco, a former lender with CoreStates
Bank, NA, of Pennsylvania and now as a planner and developer in
housing and community development, I respectfully request the FDIC
to not increase the threshold for CRA compliance for small banks
to $1 billion in assets up from $250 million.
Since the passage of FIRREA, the growth of Community Development
Financial Institutions, community based-loan funds, local housing
trust funds, bank CDCs and tax credit investment vehicles has made
community investment for small banks much easier. So I do not see
how this perception of an "unwarranted burden" holds
true.
CRA was established because banks large, medium and small benefit
from a federal government guarantee of deposits. So long as that
is in force, all banks should be held accountable to maintain vigorous
community investment programs.
Thank you.
Jeremey Newberg
President
Capital Access, Inc.
237 Tasker Street
Philadelphia, PA 19148
