440 1st Street NW, Suite 450
Washington, DC 20001-2042
January 9, 2006
Federal Deposit Insurance Commission
550 17th Street, NW.,
Dear Robert Feldman:
On behalf of RESULTS, Inc., a grass roots citizen's lobby, I am writing in
support of maintaining a strong Community Reinvestment Act.
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 the opportunity to comment on the need for a strong CRA.
Alan W. Gold