FDIC Federal Register Citations
From: Christina
Clamp [mailto:c.clamp@snhu.edu]
Sent: Wednesday, October 20, 2004 11:58 AM
To: Comments
Subject: Oppose Efforts to Weaken CRA RIN number 3064-AC50
Christina Clamp
7 Niles St.
Brighton, MA 02135
October 20, 2004
Federal Deposit Insurance Commission
,
Dear Federal Deposit Insurance Commission:
The best tool that we have had to address the problems of revitalizing
neighborhoods has been the CRA. 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.
I agree with the National Congress for Community Economic Development
that
this proposed change would have a devastating effect on affordable housing
and community development investment throughout the nation, particularly
in rural areas.
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.
President Bush’s comments promoting an "Ownership Society" are
truly
disingenuous if the actions of officials he appointed are undermining
proven laws that revitalize communities, increase minority homeownership,
and increase small business ownership for women and minorities.
Please rescind your proposal.
Sincerely,
Christina A. Clamp
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