From: Danny Knee [mailto:dknee@tucsonurbanleague.net]
Sent: Thursday, September 16, 2004 2:17 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
As an affordable housing practitioner, it is hard to describe how
disappointed I am with the proposed rule change. The Community
Reinvestment Act (CRA) has been one of the most effective levers to
ensure banks are providing low and moderate income families, through a
whole host of programs and requirements, access to capital. While I wish
I could believe that the institutions exempted under the proposed rule
and thereby undergoing less stringent reviews and requirements would
still meet their obligations under CRA, the banking industries own
practices which lead to the creation of the CRA suggest otherwise. This
policy, undoubtedly, would reduce lending, investments and services in
low-income communities.
Therefore, 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.
