Letters to Regulators

Reponse to HUD Secretary's Comments to the Credit Union Journal

November 17, 2004

November 17, 2004

The Honorable Alphonso R. Jackson
Department of Housing and Urban Development
451 Seventh Street, SW
Washington, DC 20410

Dear Mr. Secretary,

As the representative of community bankers, I was concerned to read your comments reported in the October 25 edition of the Credit Union Journal [“HUD Secretary Says Most Banks Too Big For Communities, Applauds CUs”] that suggest that credit unions, but not banks, are close to their communities.  While I agree that some banks are “just too big” to have a close relationship with their communities, the nearly 5,000 members of the Independent Community Bankers of America define themselves by their commitment to serving their customers and communities.  Since you hail from Texas – home to well over 600 community banks – I am sure you understand the differences between community banks and large regional or nationwide institutions.

As HUD Secretary, it is important that you know that community banks strongly support the Administration’s goal of increasing home ownership, particularly among minority groups.  As homeownership increases, our banks’ communities prosper, which is essential to our members’ ultimate survival.

Community banks’ commitment to home lending has greatly increased in recent years.   They now depend heavily on the Federal Home Loan Banks, Fannie Mae, and Freddie Mac to obtain funding for local mortgage loans.  Since HUD is so intimately involved in the regulation of these housing GSEs, I believe it is essential that you fully understand the role that community banks play in this area.

ICBA also commented extensively on HUD’s proposed RESPA reform proposal.   I gather from recently reported remarks that some version of this proposal might be re-proposed.  We would welcome the opportunity to participate in discussions of any revision to the RESPA proposal.  Given community banks’ strong interest in improving the mortgage process, you can be sure that we will again actively participate in any new rulemaking. 

I would very much like to meet with you to discuss all of the matters raised in this letter and to learn how ICBA and its members could assist you in carrying out the Administration’s plans to increase homeownership and simplify the mortgage process. 


Camden R.  Fine

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