From: Bill Tilly
Sent: Wednesday, August 25, 2004 5:05 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
While we are
100% in favor of reducing reporting requirements of all banks,
large and small,
the Community Reinvestment Act is a critical
component to Alabama's affordable housing and community development
solutions. Because the CRA requirements for large banks are more
lending intense, we oppose any increase to the threshold of what
is considered to be small bank. Our concern is that the newly categorized
small banks ($250m - $1b) will opt for service rather than lending
and all the good intentions of teaching our disadvantaged citizens
about financial responsibility, etc. will certainly not outweigh
the fact that living conditions continue to deteriorate. We must
have the continued partnering of the banking community with the government
programs to provide safe and decent housing for the less advantaged
and elderly. 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.
William H. Tilly, Jr.
Executive Director
ALABAMA MULTIFAMILY LOAN CONSORTIUM