Well, I see the community groups representing low income housing are turning out in force against the CRA proposal.
What do these people think.......that we big bad banks will just ignore the low income people? If they qualify for loans then we give them loans! There are still other laws in place that see to that whether CRA proposal "flys" or not. Sorry, I just HAD to vent this morning but I'm just tired of working so hard to see everything handed to others who do not seem to try half as hard as I to get somewhere and yes, I know my statement does not apply to ALL low income people. I have been among those ranks myself.

Editorial
I had posted previously that we had not heard from these groups yet and that when they waded in passage of the new proposal will be difficult to achieve. This is an extreamly powerful lobbying group with direct access to various influential law makers.

Unfortunately, and while difficult to believe in this day and age, many minority and economically depressed areas are still underserved by financial institutions. IMO its precevied that what is being served is only done so by the enforcement of a lot of regulations placed on the banking community. If regulations are watered down or removed there quesstion is will products and services again be removed. They don't trust the banks and have statistics to show why not. Until bankers earn the trust of these groups expect continued increases in audit and reporting requirements.

Again IMO until bankers sit down with these groups and find ways to participate with them the adversareial roles will continue.

The bad news is as with most things there are extreamist on both sides. The good news is 97% of the institutions work very hard everyday to do whats right. The 97% has to get some PR going with the non profits. Tremendous strides have been made in providing funds to economically depressed areas which has brought new life to these areas. Is it because the need was there and financial institutions stepped in or because a lot of laws forced them to? I do not defend some of the actions taken by these groups, but I do believe bankers have to find out who and what these organizations are, what they are doing, and why they even exist. That really needs to be understood

Neither banks or non profits want or expect giveway or free programs. Just sound financial help. IMO both groups have to start talking to each other.

Sorry didn't know I wasn't logged in The above was posted by me

So, at this time, you don't think we will see any change by year end?

Anything is possible and my crystal ball is probably no better than anyone else on this. I will say I'm not optomistic it will pass. While happening very slowley have you noticed it isn't less but more data is being asked for. Reg B is the only thing in the way of requireing the same type of information for CRA as required for HMDA. Several attempts have already been made to change it.

Will the Small/Large bank definations change? I don't think so, especially if the non profits lobby the way they can do. Thinking that raising the amount to $500,000 is going to mean less work may be very optomistic. If its being done as a cost and man power saving to regulators it has a chance but expect some compromises to be made.

Meanwhile, I spent three days in DC this week with a group from our state banking association. We were primarily lobbying in support of Ways & Means Chmn. Thomas' call for investigations into credit unions and tax exemptions, but we also took time to sit in with the FDIC and the OCC. Both recommended that we "be bold" in our comment letters on CRA - that lifting the small bank threshold to $1 billion isn't out of the question - and that support from the industry will be vital. I wrote my comment letter a couple of weeks ago. If you haven't taken the time yet, I'd encourage you to consider a letter of your own.

Raising the threshhold to a $1 Billion won't help some of us, how about eliminating the Investment Test for banks under $10 Billion in size. Now that turns me on !

See? That's what the FDIC was talking about! BOLD!

LMAO Don!!! Please write that one and use my name as well. If we can get Don N. to agree we could send a 3 Don endorsement or the request That must be good for something

I haven't written a comment letter yet and thought I would ask for some feedback before I do. My concern is regarding changing the Disclosure Statement to contain the number and amount of small business and small farm loans by census tract. What are your thoughts about this? I wonder if this will just turn the CRA Disclosure Statement into a stack of paper too huge to easily read with any meaning (like the HMDA Disclosure Statement). Wouldn't a public release of the data listing report sorted by census tract be a more efficient means to evaluate where we're making small business and small farm loans? I personally prefer the summary inside/outside assessment area, borrower income level, etc. reports that we can generate right now from the FFIEC software. I have no problem sharing those reports with community groups who ask for them.

Please submit your comment letter Brad. But the advocacy groups really want this info available, so look out.