Federal Deposit
Insurance Corporation

From: Brad Lamb [mailto:bradlamb@ncconsumer.org]
Sent: Monday, October 18, 2004 2:05 PM
To: Comments
Subject: Oppose /Change in CRA Rules

To the FDIC:

The Community Reinvestment Act (CRA) is a vital law that places an affirmative obligation of banks and thrift institutions to help meet the credit needs (and also retail banking service needs) of their local communities, including low and moderate income areas. CRA has been instrumental in increasing lending for homeownership, rental housing, and other important community needs and four federal banking agencies regularly assess and grade the lenders they supervise to determine the level of their CRA efforts. The FDIC is proposing to quadruple (to $1 billion) the minimum asset size for applying the full CRA exam to FDIC supervised state chartered banks. Among other things, the proposed revision would eliminate the retail banking service component of the CRA exam for an additional 900 banks (many of which are located in rural areas). Elimination of the retail service test would take away the incentive for these banks to maintain and open new branches serving low income consumers and to offer low cost checking and savings accounts.

The North Carolina Consumers Council thus opposes efforts to weaken the existing FDIC CRA rules.

Sincerely,
Brad Lamb

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Brad Lamb
Executive Director, General Counsel
North Carolina Consumers Council, Inc.
Advocating for North Carolinians since 1968.