Housing Authority of the City of Santa Barbara


From: Robert Pearson
Sent: Friday, August 20, 2004 6:06 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

To Whom it May Concern:

The Housing Authority of the City of Santa Barbara works extremely close with the small banks in our community. They are a regular purchaser of our tax exempt debt issuances that we do for our low income rental housing development efforts. They have often commented that their aggressive rate structure (i.e. low on our deals) gain them good CRA reviews. And small banks are much more responsive and aggressive in handling private placement of small tax exempt note purchases---far less bureaucratic than the larger institutions. We therefore know that the Community Reinvestment Act is a critical component to our community’s affordable housing and community development solutions; and strongly oppose any increase to the threshold of what is considered to be small bank. The proposed FDIC rule would exempt many of our community’s critical partners from the effective and productive requirements currently in place. We urge FDIC to withdraw its proposed rule.


Robert G. Pearson, Executive Director
Housing Authority of the City of Santa Barbara
808 Laguna St.
Santa Barbara, CA 93101