From: Susan Holland [mailto:s.holland@npcnys.org]
Sent: Thursday, September 16, 2004 2:33 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
Dear FDIC:
I work for a statewide coalition that advocates for and advises
community-based organizations that do affordable housing and
neighborhood
revitalization in low-income and distressed communities. CRA has been
one
avenue that housing developers and communities have been able to build
partnerships with their local banking community to stabilize housing
infrastructure, to provide decent housing to low and moderate income
homeowners and to bring properties back to the municipal tax rolls.
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. This
policy would reduce lending, investments and services in low-income
communities. With larger banks merging or taking another bank over, the
local nonprofit community is already facing the question about the
significant loss of local investment; changing the CRA ruling at this
time
would push that agenda further. Again, I oppose FDIC's proposal.
Sincerely,
Susan Holland
Associate Director
Neighborhood Preservation Coalition of NYS, Inc.
