From: cmckelway@penquiscap.org [mailto:cmckelway@penquiscap.org]
Sent: Wednesday, September 15, 2004 4:31 PM
To: Comments
Subject: CRA
To: Robert Feldman
Executive Seretary
Attn: Comments/Legal ISS
FDIC
550 17th Street NW
Washington, DC 20429--9990
Re: RIN 3064-AC50
To Whom It May Concern:
I manage a small rural Community Development Financial Institution in
Maine. Prior to this I was a banker for 25 years. I see my current job
as my opportunity to give back to my community by using the knowledge I
developed as a banker. We provide one on one counseling to people who
want to start a business, counseling to first time homebuyers,
counseling to people who are possibly losing their homes in foreclosure,
budget and debt management counseling to those who have taken on too
much debt or been victims of predatory lending. Things that bankers
understand are not common knowledge for many, especially low income
people. I have been working for the past 3 years to build a performing
loan portfolio with sufficient interest income to support our counseling
and reduce our reliance on grant funding. I have raised loan funding for
my programs to a large extent from banks who are working to comply with
CRA. The CRA incentive really does encourage banks to address community
needs and assist businesses like this one. I am not convinced that banks
would have provided me with my financing without a CRA benefit to them.
Having been a small rural bank CEO I understand the impact of this
regulation on a small bank. I do not believe the burden on small banks
is such that the program needs to be altered in a way that would
negatively impact its community development benefits. I am therefore,
opposed to the proposed rule changing the CRA. I believe it will have a
negative impact on communities that need it most. I think you need to
find a way to apply the CRA rules to credit unions. Why not focus your
efforts on that sort of legislation?
