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FDIC Federal Register Citations
St. Louis County Economic Council
From: Owens, Patrick [mailto:POwens@stlouisco.com]
Sent: Thursday, October 14, 2004 10:29 AM
To: Comments
Subject: EGRPRA Burden Reduction
As a former bank examiner, I oppose the FDIC's proposal to allow banks
with assets above $250 million to be examined as small banks under the
Community Reinvestment Act. This policy would reduce lending, investments
and services in low-income communities.
I was a Consumer Compliance Bank examiner for 4 years and have now
worked in community development for another 8 years. It is very clear
that the Community Reinvestment Act has resulted in direct investment
and services to low- to moderate-income (LMI) areas that would otherwise
not have been given a second thought.
There is increasing pressure on the lending industry to get more from
the bottom line. Lenders can do that if they educate themselves about
how to make loans and investments in these under served areas. There
is a largely untapped market there where educated lenders can and do
make a profit.
To ease this restriction would remove the incentive for smaller banks
to educate themselves how to serve these markets. Not only will this
reduce the amount of competition for lending in the LMI areas, it will
also damage the lending industry that has fewer and fewer competitors
due to the cut-throat merger and acquisition climate.
Less competition means less banks to regulate. Isn't that a concern
of each of the Federal regulatory agencies? I encourage the FDIC, Federal
Reserve, OTS and the OCC to fully consider this proposal and the negative
effects it will have on not only the LMI areas but the lending industry
as a whole.
Patrick M. Owens
St. Louis County Economic Council
121 S. Meramec, Suite 900
St. Louis, Missouri 63105
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