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From: Rish Kunzru
Robert E. Feldman
Dear Mr. Feldman:
Thank you for this opportunity to comment. My comments are limited to two of the Question and Answer provisions.
We are pleased that the agencies are proposing that banks will receive points on their CRA exams for financing community development in geographical areas impacted by disasters for up to one year after the expiration of official federal or state designation of disaster status. It is imperative that we also address the inherent risk of corporations and lending institutions using this as a short term and convenient public relations vehicle drawing attention away from the equally pressing and ever-present long term lending discrimination.
Further, in responding to the branches and services provision, while I completely agree that the number of actual bank branches as against distant affiliates or brokers in a traditionally ignored/under-served community should be used as a definite criterion in giving CRA points, qualitative factors like the efficacy or area-specificness of advertising by those branches of suitable products for that community may also be made pertinent in rating determination.
|Last Updated 01/06/2006||Regs@fdic.gov|