From: Stan Stradley [mailto:ucha@uci.net]
Sent: Thursday, September 02, 2004 6:28 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
DON'T CHANGE THE REQUIREMENTS AND LOWER THE STANDARDS!!!!!
As developers, managers and providers of affordable housing projects
we are continuing to see less and less resources in providing this
services to the citizens of this country. In the rural area's we are
seeing local banks being gobbled up by the national chains where you
once was a valued customer now are just an account number. There are
really no new production programs for affordable housing other than tax
credits. Local small banks have been willing to invest in small projects
by buying the credits which in turn assist them in meeting their CRA
requirements. With this change that will go away and medium and large
institutions are not interested in the small deals as they refer to
them. I urge you to reconsider your position on this and get back to
what the CRA was intended for in the first place. In fact think about
each branch of each institution being required to reinvest in the
community they serve.
Stan Stradley
Executive Director
Umatilla County Housing Authority