From: Michael
Sent: Thursday, September 09, 2004 2:39 PM
To: Comments
Subject: RIN number 3064-AC50
How does one determine if a bank is a community bank or a large
bank? Can
you really look at just the size of the bank to tell? I don't think
so.
This change relieves the burden of collecting excess data from financial institutions that are otherwise doing a good job of being non-discriminatory,
working towards improving their communities and sticking to the spirit of the Community Reinvestment Act.
Collecting the
income and revenue and geographic location of every business and
farm loan an institution makes costs our financial institutions
both time and money that could be better spent working
towards improving the community around them.
I fully support
raising the bar separating the small bank from the large bank
to a far more clearer level. I support giving the larger community banks
the opportunity to redirect their attention from collecting data
to doing the right thing.
I recommend that
these insitutions continue to evaluate their community
development efforts, their levels of lending within their community,
and that we continue to ensure that no institution intentionally
avoids lending to low to moderate income communities.
I do not feel that requiring extensive paperwork is
necessary to achieve the desired goal inherent in the Community Reinvestment Act.
