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Enterprise Community Partners, Inc.January 9, 2006
Office of the Comptroller of the Currency
Jennifer J. Johnson, Secretary
Robert E. Feldman, Executive Secretary
To Whom It May Concern:
Enterprise appreciates the opportunity to comment on the agencies November 10, 2005 notice that would revise guidance relating to new Community Reinvestment Act (CRA) regulations, in effect as of September 1, 2005.
The devastation wrought by hurricanes Katrina, Rita and Wilma in 2005 underscored the critical nature of financing community development in geographies impacted by natural disasters. We strongly support the guidance that would provide more credit for community development activities that are responsive to the needs of low- and moderate-income individuals and communities in these areas. Our experience in revitalizing distressed communities across the country demonstrates that this is often a lengthy process, and reports suggest that the rebuilding of the Gulf region will be unprecedented in duration and scale. With respect to the proposed one-year lag period, we encourage the regulators to continue to closely monitor investment in the Gulf and in other disaster situations. To the extent that financial institutions are investing in designated disaster areas to the benefit of low- and moderate-income individuals, we urge the regulators to be responsive to the evolutionary situation and flexible in crediting banks CRA examinations.
We are concerned regarding the consideration of financing of housing for middle- and upper-income persons in distressed middle-income geographies or designated disaster areas as community development activity for purposes of the CRA examination. While we believe the intent of the guidance is well-placed (investment would be credited if the housing helps to revitalize or stabilize the community by attracting and retaining businesses and residents, providing benefits to the entire community), our concern is that scarce resources would be diverted from housing affordable to low-income families. Enterprises development experience has demonstrated that mixed-income communities lead to healthy, stable and sustainable neighborhoods. We encourage the regulators to modify their guidance to credit investment in mixed-income development in distressed and underserved communities.
We appreciate the clarification that mid-size banks must engage in community development lending, investment and services, and must not ignore any of these three critical categories. With respect to community development services, we applaud the listing of examples of qualifying services, including the provision of branches in low-income communities, low-cost banking accounts, international remittances and financial counseling to low- and moderate-income individuals. However, we encourage the regulators to specifically communicate that the number of bank branches and other facilities located in low-income communities will be considered as part of a financial institutions CRA examination.
Enterprise has invested nearly $6 billion to support more than 175,000 affordable homes in low-income communities across the country. Many of our partners are depository institutions covered by the CRA. The CRA is critical to the rebuilding of the devastated Gulf region, in which Enterprise, along with our private sector and financial institution partners, is actively engaged. The CRA is the key federal policy in expanding affordable housing and economic opportunities to low-income families and communities across America.
Alazne (Ali) Solis
|Last Updated 01/10/2006||Regs@fdic.gov|