Community Housing Innovations, Inc.


From: Alexander Roberts
Sent: Friday, September 17, 2004 10:27 AM
To: Comments
Subject: SPAM::Community Reinvestment -- RIN 3064-AC50

As the Executive Director of a nonprofit agency that provides millions of dollars in down payment assistance to first time homebuyers pursuant to contracts with the New York State Housing Trust Fund and Affordable Housing Corporation, I oppose the FDIC's proposal to allow banks with assets above
$250 million to be examined as small banks under the Community Reinvestment Act. This policy would reduce lending, investments and services in low-income communities. The CRA should be strengthened, not weakened at this critical time when low income communities are beset with sub-prime lenders. Legitimate banks must play a larger role in the revitalization of low-income communities because any rule changes that would have the effect of reducing options to low -income families only increase the likelihood they will be forced to turn to sub-prime lenders.

Alexander H. Roberts, Community Housing Innovations, Inc.