From: Helen Lehman [mailto:westgdc@iserv.net]
Sent: Thursday, September 16, 2004 1:47 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
As the Executive Director of a small, neighborhood-based community
development corporation, I am writing to express my outrage at the
proposed changes to the CRA that would allow all banks with assets under
$1 billion to have the limited CRA exam.
Organizations such as ours, which produce the majority of affordable
housing units in this country, could not operate without the "hammer"
that the CRA holds over lenders. Access to cash for rehabilitation and
acquisition would not happen without the CRA requirements currently in
place. I can name banks that would no longer be working with us, if this
proposed change takes place.
The FDIC and OCC need to take a hard look at this proposal. It serves
no one in the low and moderate income neighborhoods we serve. The gaps
in affordability continue to widen. Let's not allow this change to make
the gap even wider. The rehabilitation of our core cities depends on
this leverage point.
Helen Lehman
Executive Director
New Development Corp.
fka West Grand Development Corp.
671 Davis, NW
Grand Rapids MI 49504
616/451-2291 (phone)
