From: Housing Association of Delaware Valley
Sent: Monday, August 23, 2004 9:37 AM
To: Comments
Subject: Housing Association of Delaware Valley Opposes increase in
small bank threshold.
The Housing Association of Delaware Valley (HADV) is the
nation's oldest housing advocacy agency, founded in 1909.
We work with neighborhood groups, community development corporations
and housing developers to promote the construction and rehabilitation
of affordable housing, and to encourage equal housing opportunities
for all citizens. Nonprofit organizations benefit tremendously
from CRA-incented participation of lenders in their communities.
This participation is critical to reverse the many years
of dis-investment, redlining and discrimination that has
blighted our cities.
The Community Reinvestment Act is a critical component
to our community’s affordable housing and community
development solutions. We oppose any increase to the threshold
of what is considered to be small bank. The proposed FDIC
rule would exempt many of our community’s critical
partners from the effective and productive requirements
currently in place. We urge FDIC to withdraw its proposed
rule.
Marcus Saitschenko
Housing Advocate
Housing Association of Delaware Valley
1528 Walnut Street, ste. 1000
Philadelphia, PA 19102