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FDIC Federal Register Citations
Sharon Martinez
P. O. Box 4475
University, MS 38677-4475

January 6, 2006

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

Dear Robert Feldman:

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.

I would like to see provisions for all banks that offer credit card 
services to also offer credit counselling and community education 
resources so all clients, particularly low-income or middle-income 
clients, can easily learn the impact of their credit and debt choices.  

I would like to see nationwide limits on interest rates and finance 
charges; if states will no longer be allowed to enact banking legislations 
that limit these charges, then the federal government should inact 
provisions that limit these charges to no more than 25 percent.  

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

Thank you for the opportunity to comment on the need for a strong CRA.


Sharon Martinez

Last Updated 01/09/2006

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