| Extended deadline:
Preserve CRA in 1O minutes
take a few minutes right now to write a brief e-mail comment and ask all
your colleagues to write one to preserve the Community Reinvestment Act
against a very serious threat. Comments are due October 20. Thank
you to the 861 people who responded to our first Alert in September. We
need another big effort in the next week.
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 changes could also follow.
It is critical that including community organizations and the general
public submit comments to the FDIC opposing the proposed change. The
FDIC has already received a record 7,000 comments, but the majority are
from small banks supporting the FDIC’s proposal. The Fed and the OCC are
watching closely to see whether community groups care. This is an
important moment for maintaining and expanding bank involvement in
How To Send a Comment
It is really
quick and easy. Just visit the target=”_blank” href=”http://lisc.org/cgi-bin/tr.pl?date=2004/oct/13&url=http%3A%2F%2Fwww%2Efdic%2Egov%2Fregulations%2Flaws%2Ffederal%2Fpropose%2Ehtml”
>FDIC website and find “Community Reinvestment 12 CFR
Part 345″. Click on “Submit Comment” and type in your comment. Your comment
can be very simple. For example:
“I oppose the FDIC’s proposal to
allow banks with assets above $250 million to be examined as small banks
under the Community Reinvestment Act. This policy would reduce lending,
investments and services in low-income communities.”
there is to it. Of course, feel free to write more if you wish.
For more information on this issue, please go to target=”_blank” href=”http://lisc.org/cgi-bin/tr.pl?date=2004/oct/13&url=http%3A%2F%2Fwww%2Encrc%2Eorg”>National Community Reinvestment Coalition or target=”_blank” href=”http://lisc.org/cgi-bin/tr.pl?date=2004/oct/13&url=http%3A%2F%2Fwww%2Enaahl%2Eorg”>National Association of Affordable Housing Lenders. We
also encourage you sign on to group letters that organizations may have,
but that is no substitute for sending individual letters.