From: by way of Marty Newell <cra@ruralstrategies.org> [mailto:hcgceopmc@mac.com]
Sent: Wednesday, September 15, 2004 4:39 PM
To: Comments
Subject: RE: RIN 3064-AC50
name: Herbert Chao Gunther
address: 1217 Clay Street
city_st: SF CA
zipcode: 94108
I strongly oppose the proposed rule changes in the Community
Reinvestment Act (RIN 3064-AC50). This action will harm to rural
communities. : Re: Community Reinvestment Act rule-making (RIN
3064-AC50)...
Exempting banks with $1 billion or less in assets from the same
community reinvestment criteria as larger banks is totally without
justification and unwarranted. Social responsibility -- the fundamental
obligations corporations have to the communities that provide their base
capital -- isn't a function of
asset size and shouldn't be diminished by how large or small a bank is.
Because rural America is underserved by banks and for most rural areas
there is no effective competition, exempting
banks with $250 million to $1 billion will have the same effect as
redlining as entire communities lose access to market-interest capital.
A further devastating impact will be the expansion of high-margin
commercial lenders in rural areas as small banks cut back on CRA
programs related to lending, investment and financial literacy.
FDIC should be doing more to expand capital access and financial
services to under-served communities through the CRA, not doing less.
Rural voters are paying close attention to this.
If FIDC withdraws from rural America, rural voters will have one more
reason to elect new national leadership in November.
