O C T 9 1 20E4
15:33
FR N R Y O R S O F F I C E
October 20.2004
Mr. Robert E. Feldman Executive Secretary Attention: Comrncnts/Lesal ESS Federal Deposit Insurance Corporation 550 17th Street, N W Washingtan, DC 20429
Dear Mr. Feldman:
RE:RIN 3064-AC50
I am greatly distressed by a&empts to weaken the CRA (Community Reinvestment Act) requirements for midsized banks. C R A has been an indispensable tool for increasing
homeownership and economic development in our lower-income communities. The proposed changes will reverse the progress.
Banks with more tban $250 million in assets now must meet a standard of ofking loans, investments and services to low-and moderate-communities. By eliminating the investment and service requirements for banks with less than $1 billion in assets, significantly fewer loans and investments in affordable rental housing, health clinics, community centers and economic - development projects will occur.
Addirionally, your proposal allows mid-sized banks to choose which Q@ of the community developme& activities .they wiU undertake, instead of requiring -y ' t development lo&, investments and services. This d l surely lead to less 'community development activities.
:v Proposing that community development activiucs in rural areas can bend.; ,. group of individuals instead of only low-and-moderate-incoma individuals will allow banks to focus on afnuem residents instead of lower income consumers that the CRA targets. The proposal would banks. Without also eliminate publicly available data on the small business lending of m~d-sized data, citizens and community groups could not hold banks accountable for thelr obligation to make loans to small businesses in their communities.
These changes directly wntradia CRA's mandate to require lenders to meet community needs. I urge you TOreconsider &is harmful propossl and let CRA continue to live up to its promise. Sincerely.
.-Mara S. Giulianti Mayor
C:
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Neal Hexst, Dinctor, Depamnent of Housiugand Community Redevelopment
2GOO Holiywood Boulcvacd
Mayor h C:oinmib~ionorr: 10541 921-3321
Lorie Mazen~, Dimtor, Intergovemmmtal Main
PO.Box 229045
. Hollyvoad, FL 33021-3045
FA)( 1954) 921-3268
www.hollyrnrocltl.org
FAX 16)541 '11 1.3386
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C:i,izcn-' &rtsr:\~~rr\(9541 921-3139
Scrvicc
"An E q u a l O p p o r r v n i t v e n d
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