Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ISS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429-9990
REGARDING: RIN 3064-AC50
Gentlemen,
I strongly oppose the proposed rule changing the Community
Reinvestment Act regulations. Such changes will undermine the efforts of
rural communities to develop "real" economic opportunity and growth.
Please, do not adopt the proposed rule.
I have been working for small Native American rural communities for
many years in education, community and economic development. The
Community Reinvestment Act opportunities through our small local banks
have been the only way these small rural communities have been able to
secure leverage funds for economic development ventures. An example: the
Stillaguamish Tribe of the state of Washington now has a thriving native
riparian restoration nursery serving the entire northwest thanks to the
current rules under the CRA - we were able to borrow against privately
owned tribal assets/lands with which to leverage and provide matching
funds for EDA, USDA, local State and private foundation funding for the
project. This risk of tribal assets made the very difference in the
successful financing of this project. In fact, EDA showcases this
project on its national website as an exemplary economic development
program. This is just one example where the current law nurtures true
economic development in rural America. Please do not take this valuable
tool from us.
Thank you for your considered attention to our request not to adopt
the proposed rule vis-a-vis RIN 3064-AC50.
Sincerely yours
Jay Moolemjzer
Community Planning and Development Department
Ramah Navajo Chapter
Ramah, NM