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Insurance Corporation

Each depositor insured to at least $250,000 per insured bank

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FDIC Federal Register Citations

    Arran Thomson
    4613 NE 19th Ave
    Portland, OR 97211-5807

    January 7, 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.

    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.


    Arran E. Thomson




Last Updated 01/10/2006

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