P. O. Box 4475
University, MS 38677-4475
January 6, 2006
Federal Deposit Insurance Commission
550 17th Street, NW.,
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.