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FDIC Federal Register Citations
Roma Goodlander
517 Moody Street
Waltham, MA 02453-0506

January 6, 2006

Robert Feldman
Federal Deposit Insurance Commission
550 17th Street, NW.,
DC 20429

Dear Robert Feldman:

Here at WATCH CDC, we rely on a strong CRA to carry out the important work 
that we do building affordable housing, running job training programs and 
doing community organizing.  A strong CRA helps to multiple the benefits 
of the work we do by giving low and moderate income borrowers a chance to 
reach self-sufficiency.  

The most effective way to expand access to credit to underserved borrowers 
is to implement rigorous and comprehensive CRA exams that maintain the 
focus on meeting the credit and deposit needs of low- and moderate-income 
borrowers and communities.

The final Q & A Notice should clarify that the community development exam 
criterion includes an examination of the number and percent of branches in 
low- and moderate-income communities.

In addition, I recommend that the final Q &A Notice provide CRA points for 
the provision of low-cost banking services.

CRA exams should also penalize banks for abusive products such as bounce 
protection, the wealth stripping features of which are not advertised 
clearly to consumers.

Finally, I encourage the regulators to add an anti-predatory lending 
provision to the CRA regulations that will penalize banks for illegal, 
abusive, and discriminatory loans.

Thank you for your interest in my comments and I hope you will do 
everything in your power to promote and protect a strong CRA.


Roma Goodlander


Last Updated 01/09/2006

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