HO-CHUNK HOUSING & COMMUNITY DEVELOPMENT AGENCY

September 13, 2004

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429

RE: PIN 3064-AC50

Dear Mr. Feldman:

We at Ho-Chunk Housing and Community Development Agency, affordable housing provider of the Ho-Chunk Nation, deplore the proposed changes to the Community Reinvestment Act (CRA), changes that would considerably lessen the accountability of mid-sized banks in the Ho-Chunk Nation service area in regard to the banks' providing loans for homeownership and economic development to the low- and moderate-income communities. As I am sure you know, Native Americans fall disproportionately into these income categories, have a much lower historical level of homeownership than does the population as a whole or indeed than does any other minority, and benefit greatly from the provisions of C.RA, as they stand now. Members of the Ho-Chunk Nation are beginning to see the fruits of activism to increase the number of government and private loans on trust land and on fee-simple land, and the presence of a strong CRA is a great bulwark in this effort.

Your proposed changes to CRA are in direct contravention of CRA's purpose to hold lenders' feet to the fire in regard to the meeting of community needs. The act is far too important to be undercut. We respectfully request that you withdraw your proposal, as did two other federal agencies the Office of Thrifts Supervision and Office of the Comptroller of the Currency that recognized the harm that would be inflicted upon underserved communities by similar changes.

Sincerely,

Myra J. Price, Executive Director
Ho-Chunk Housing and Community Development Agency