From: Jane Zhang [mailto:JZhang@accion.org]
Sent: Wednesday, October 20, 2004 10:00 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
Dear Sir or Madam,
Under current rules, small banks with assets under $250 million undergo a
limited CRA exam that covers only some basic lending activities. Larger
banks undergo a full CRA exam that covers lending, investments, and
services. Now the Federal Deposit Insurance Corporation (FDIC) has proposed
to allow all banks with assets under $1 billion to have the limited exam.
Only 4% of FDIC-regulated banks would face a full CRA exam. This change
would harm low- and moderate-income communities, and leave some states with
no banks subject to a full CRA exam. The Office of Thrift Supervision (OTS)
has already finalized a similar rule. The two other regulators, the Federal
Reserve Board and the Office of the Comptroller of the Currency, are
considering a similar change. Other similar organization could also follow
in this example. Accion USA is a non-profit, small business lender serving
low-income communities in 3 states - Florida, Georgia, and Massachusetts. We
have loaned over $90 million to more than 10,000 clients as of year-end
2003. Currently, the Miami branch has 190 clients with a portfolio of $650K.
The CRA exam requirement is a major incentive for banks in the communities
we serve to partner with us in supporting our lending services, either
through providing direct loan funds, or by referring clients to us that they
are unable to serve. We at the Miami branch of Accion USA believe that
removing the full CRA requirements for banks with assets above $250 million
would discourage banks from participating in our partnership opportunities.
Please reconsider the adoption of this policy.
Respectfully yours,
Luz Gomez
Program Director
Accion USA, Miami
