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FDIC Federal Register Citations


Garrett County Community Action Committee, Inc.

From: Duane Yoder
Sent: Wednesday, August 25, 2004 3:18 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

On behalf of the Garrett County Community Action Committee, I want to register opposition to the above proposed rule changes regarding the asset threshold for banks covered by the Community Reinvestment Act. The Garrett County Community Action Committee believes that the rule should be left as it currently stands.

Garrett Community Action is a rural private not for profit corporation that has developed close partnerships with banks on a variety of community and economic development projects and investments. Each of these banks falls below the threshold that is proposed under the new rules. The partner banks have repeatedly told me that the CRA credits received on our work is one of the benefits to the bank. I have no doubt that CRA was pivotal in opening the door and cementing the relationship between our organization and our partner banks. There have been direct pay offs in 200 first time home buyers, 335 new rental units and 100,000 square feet of community and commercial space. Each of the projects that we sponsored required bank participation. The involvement of the bank would not have occurred if CRA did not exist.

Isolated rural communities typically have the greatest need for public and private capital. Yet, it is these very communities that also lack banks large enough to meet the new thresholds proposed by the FDIC rule changes. In short, the proposed change will act to stop the kind of public private investments that are so needed in our poorer rural communities. In the long term, exempting the rural banks will hurt both the banks and the community. For those reasons, I want to strongly state GCCAC’s opposition to the proposed FDIC change.


Duane Yoder, President
Garrett County Community Action Committee, Inc.

Last Updated 08/26/2004 regs@fdic.gov

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