From: Franklin Lee [mailto:fmlee@shapirosher.com]
Sent: Thursday, September 16, 2004 2:15 PM
To: Comments
Cc: fmlee@shapirosher.com
Subject: Community Reinvestment -- RIN 3064-AC50
To Whom It May Concern:
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. It would also undermine efforts to encourage
more equitable lending to small and minority-owned businesses that tend
to be located in urban communities.
For the past 18 years, I have been an advocate on behalf of small and
minority owned businesses. In my work, I have seen countless examples of
commercial lending discrimination by banks of various sizes, including
those that have less than $1 billion in assets. Increasingly, research
by well-respected economists and academicians has been confirming the
pervasiveness of this problem of unequal access to capital caused by
discriminatory lending practices. If anything, the oversight and review
of financial institutions' compliance with CRA in this regard needs to
be strengthened, not watered down.
I urge you to reject any rule that would raise the threshold for full
CRA audits and reviews of financial institutions.
Very truly yours,
Franklin M. Lee, Esquire
4295 Mary Ridge Drive
Randallstown, MD 21133
(410) 385-4239
