From: Greg Maher [mailto:GMaher@liscnet.org]
Sent: Thursday, September 16, 2004 3:08 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
Dear FDIC Officer,
CRA has made the difference in many community development projects. I
know, because I've seen it with my own eyes. I've been on the national
Credit Committee of Local Initiatives Support Corporation (LISC) for
over fourteen years. LISC is a national, nonprofit intermediary with 36
offices nationwide, and is the largest community development support
organization in the country. Over the last fourteen years, I have seen
well over a thousand projects proposed for financing at Credit
Committee. Most of these developments contained financing from banks,
banks of all sizes, including many having assets below $1 billion. In
almost every case these institutions made the loan with CRA as a major
motivating factor. They collected fees on these loans, and created new
business opportunities in the process in underserved markets. Without
the extra motivation CRA provided, these lenders&nbs! p;would have
reluctant to originate their loans, and wouldn't have done so. In some
cases LISC program staff have heard bankers come right out and say that.
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. Please preserve the rule as it is - it is an
effective regulation that pushes banks to get to the finish line in
unconventional markets, breathing renewed life into isolated places
struggling to get back to the mainstream.
Thank your for considering this comment.
Sincerely,
Gregory Maher
Vice President
Local Initiatives Support Corporation
212-455-9860
