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.
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