|
FDIC Federal Register Citations
National
Black Chamber of Commerce
From: Harry
Alford [mailto:halford@nationalbcc.org]
Sent: Wednesday, October 20, 2004 11:57 AM
To: Comments
Subject: FDIC Rule to Decrease CRA Obligations to Banks
While this rule may not affect markets that are comprised solely of
major regional and national banks, there are many communities that capital
access evolves around smaller banks. Despite the successes of community
development locally and nationally, the banks and thrift institutions
that provided the loans, services, and investments to build new homes,
businesses, and community facilities may no longer have the impetus to
do so if the FDIC raises the comprehensive CRA exam threshold.
President Bush's comments on promoting an "Ownership Society" will
be truly threatened if the actions of officials seek to undermine proven
laws that revitalize communities, increase minority homeownership, and
increase small business ownership for women and minorities.
We agree that this proposed change would have a devastating effect on
affordable housing and community development investment throughout the
nation, particularly in urban and rural areas. Small communities who
are not fortunate enough to have corporate banks will lose support for
local projects that reinvest in urban and rural centers across the nation.
The FDIC proposes that the community development loans and investments
in rural areas can benefit any group of individuals, not just low and
moderate income individuals. Currently, banks have to finance affordable
housing and economic development projects that target low and moderate
income borrowers and neighborhoods. Under the proposed changes, nothing
in the CRA regulations would prevent banks from earning CRA points for
financing developments with no community development benefit whatsoever.
Moreover, the one part exams would cover 99 percent of all FDIC supervised
banks located in rural areas. Minorities significantly populate rural
areas throughout the United States.
Please rescind your proposal. CRA works, it is not broken - so why mess
with it.
Harry C. Alford
President/CEO
National Black Chamber of Commerce
Washington, DC 20036
|
