Public Comment, CRA Q&A, GeoDataVision

To: FDICRe: RIN 3064-AC97Comments on Proposed Q & A’sDear Sirs,GeoDatavVision is a consulting firm specializing in the Community Reinvestment Actand the Home Mortgage Disclosure Act. We advise and provide services to hundreds ofcommunity banks around the country and we frequently observe the confusion surrounding thoseActs. The proposed Questions & Answers help to clarify a number of nebulous areas under theCommunity Reinvestment Act. However, they fail to address other areas of widespreadconfusion and inconsistent practice and simultaneously create new questions. The following areour comments on the proposed Q&A’s.Q&A §__.12(h)-3 proposes to offer Intermediate-Small Banks (ISB’s) the option to includehome mortgages and small business or small farm loans under the community development testproviding those mortgages and small business loans have the requisite commentqualifications and those loans cannot also be included in the lending test portion of a CRAperformance evaluation.Question – the language states “a retail institution that is not required to report . . . underHMDA . . .” Does that mean an ISB that reports under HMDA does not have the elective?Question – an ISB by definition is not required to report under CRA. What if theinstitution voluntarily reports the data? Does the voluntary filing disqualify the bank fromhaving the option?Q&A §__.12(g)(4)(i)-1 and (ii)-2 and (iii)-3 provide for the “presumption” that an activity willrevitalize ...