From: Dominic Melone [mailto:dmelone@CHIVENTURES.org]
Sent: Thursday, September 16, 2004 2:29 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
I oppose the FDIC's proposal to allow banks with assets above $250
million to be examined as small banks under the Community Reinvestment
Act. Very few banks are reinvesting in low and moderate income
neighborhoods. This proposal would only serve to decrease these
activities. In fact, I believe that they should be forced to make more
of an effort at investing in businesses located in Low to Moderate
income neighborhoods. In my review of banks in the Chicago region many
are passing there exams by only making mortgages in qualifying
neighborhoods. While this is important this doesn’t qualify as
reinvestment in my mind. Banks are happy to do these deals as they are
full collateralized and would be doing these deals none the less. I
don’t see any banks in our region making mortgages to people or business
loans to candidates with a low credit score or less than 100 percent
collateral. That’s where the rub lies, because I thought that CRA was
supposed to address these systemic problems in our financial system.
Don’t lower the standard now, raise it!
Thank you,
Dominic Melone
Director of Economic Development Initiatives
Chicago Community Ventures
700 N. Sacramento Ave.
Chicago, Illinois 60612
773-822-0319
773-822-0310 fax
