THE CHILDREN'S DEFENSE FUND'S SOUTHERN REGIONAL OFFICE
From: Oleta Fitzgerald [mailto:ofitzgerald@childrensdefense.org]
Sent: Thursday, September 16, 2004 3:26 PM
To: Comments
Subject: RIN number 3064-AC50
September 15, 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, D. C. 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
The Children's Defense Fund's Southern Regional Office works on
economic and social justice issues in 77 rural counties in Alabama,
Georgia and Mississippi. These counties have struggled for years trying,
most cases in vain, to entice industry to provide jobs for their
citizens. They are also counties that have experienced the greatest
negative impact as a result of trade policies such as NAFTA. The
Community Reinvestment Act, though never fully operating to its
capacity, did provide some incentive for banks in these areas to provide
asset building opportunities for low income families so affected by
underemployment.
" Banks serving rural areas seldom have assets of $1 billion. If FDIC
removes the provision requiring more rigorous CRA examination of
community lending, investments and service provision by banks having
$250 million in assets, any hope of progress for many families will be
eliminated.
" Additionally, allowing a rule change to count investments made to
"anyone residing in a rural area" vs. the current provision that defines
rural community reinvestment as "investments to low income individuals"
will remove what little leverage hard working, low paid employees have
to attain credit and assets that help to lift their families out of
poverty.
We implore you not to pull yet another opportunity away from these
families.
Sincerely,
Oleta Garrett Fitzgerald
Southern Regional Director
