Federal Deposit Insurance Corporation
comments@fdic.gov
Re: RIN Number 3064-AC50
To Whom This Concerns:
The FDIC proposed CRA rule change to increase the asset threshold
from $250 million to $1 billion for small banks thereby reducing
regulation and relieving more than 2000 insured depository institutions
of half of their current CRA responsibilities will do real and
considerable harm to affordable housing and community and economic
development, particularly in rural areas of this country.
The CRA has been a powerful impetus for community development loans,
investments and services that benefit low- and moderate-income people.
With government subsidies drying up, now is not the time to eliminate
regulatory incentives for private capital to leverage scarce subsidy
dollars.
Under the guise of updating cumbersome rules, banks should not be
allowed to jettison critically needed community reinvestment
responsibilities.
On behalf of the Board of Directors of the Venice Community Housing
Corporation and the thousands of low-income people we serve, I urge that
you abandon the proposed rule change and preserve the present asset
threshold for large bank lender, investor and community service
obligations.
Sincerely,
Steve Clare
Executive Director
Venice Community Housing Corporation
720 Rose Ave
Venice, CA 90291