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MOUNTAIN ASSOCIATION FOR COMMUNITY ECONOMIC DEVELOPMENT
From: Justin Maxson [mailto:jmaxson@maced.org]
Sent: Wednesday, September 15, 2004 4:33 PM
To: Comments
Cc: Sandy Rosenblith (E-mail)
Subject: RIN 3064-AC50
Dear Robert Feldman:
I am the President of a 30-year old rural community development
organization in Appalachian Kentucky, the Mountain Association for
Community Economic Development (www.maced.org). We are a small business
developer looking to create economic opportunity in low-income
communities. We often partner with banks in our service area to provided
needed capital and technical assistance to nonbankable but viable small
businesses.
The current proposed changes to the Community Reinvestment Act would
mean a dramatic reduction in investment in already greatly underserved
and economically distressed communities in our area.
If these proposed rule changes were to be adopted as is, the number
of banks that would continue to have to test under the current CRA rules
in Kentucky would drop 86%--from 23 banks to 3 banks! I believe that
most banks and bankers have good intentions--but the reality is that the
CRA framework as currently crafted creates a critical framework that
addresses real market failure. Without this framework, best intentions
or not--bank investment in rural communities will drop dramatically.
I strongly oppose the proposed rule changing the Community
Reinvestment Act regulations. Please do not adopt this rule. Please feel
free to contact me if we can provide any additional information to you
or your staff.
Thanks for your time and consideration of these critical regulations.
Justin Maxson
President
MACED
433 Chestnut Street
Berea, Kentucky 40403
(859) 986-2373
(859) 986-1299 (fax)
www.maced.org |
