Some Housing alert

Extended deadline:

October 20


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=””

>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.”

That’s all

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=””>National Community Reinvestment Coalition or target=”_blank” href=””>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.