June 20, 2006   
   

The Honorable Paul S. Sarbanes
309 Hart Senate Office Building
Washington, D.C. 20510


Dear Senator Sarbanes:

On behalf of the National Housing Conference (NHC), I appreciate the opportunity to comment on the pending regulatory relief legislation.

The National Housing Conference is a nonprofit 501(c) (3) membership association dedicated to advancing affordable housing and community development causes.  A membership drawn from every industry segment forms the foundation for NHC’s broad, nonpartisan advocacy for national policies and legislation that promote suitable housing in a safe, decent environment across the nation.

NHC appreciates the fact that national banks have invested billions of dollars under the Part 24 authority to help fund critically needed urban revitalization and rural development projects that serve our nation’s low- and moderate-income families. As many institutions move closer to their current 10 percent capital and surplus limitation, a raise in the banks’ capital limitation to 15 percent, as implemented in the Section 112 provisions, could effectively improve these banks’ authority and potentially increase the amount of allowable public welfare investments by $30 billion.  

As such, NHC urges the Senate to reinstate the Section 112 of H.R. 3505 to the Senate’s bill. The Section 112 provisions are critical to advancing the investments needed for urban community development and rural developments under Part 24.  Enhancing banks’ ability to improve these investments also allow them to meet their required Community Reinvestment Act duties to invest and spur growth in low- and moderate-income communities.

Participation in community development investment is crucial. It spurs economic development, affordable housing and homeownership in underserved communities across the nation. Reinstating the Section 112 provisions will only enhance financial institutions ability to accomplish this goal.

The National Housing Conference is pleased to be able to submit these comments. If further information would be helpful, please feel free to contact me.

Sincerely,

Conrad E. Egan
President and CEO
National Housing Conference
1801 K Street, NW, Suite M-100
Washington, DC  20006
Telephone (202) 466-2121 ext. 224
Email: cegan@nhc.org


cc:Representative Barney Frank