ALABAMA MULTIFAMILY LOAN CONSORTIUM

From: Bill Tilly
Sent: Wednesday, August 25, 2004 5:05 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

While we are 100% in favor of reducing reporting requirements of all banks, large and small, the Community Reinvestment Act is a critical component to Alabama's affordable housing and community development solutions. Because the CRA requirements for large banks are more lending intense, we oppose any increase to the threshold of what is considered to be small bank. Our concern is that the newly categorized small banks ($250m - $1b) will opt for service rather than lending and all the good intentions of teaching our disadvantaged citizens about financial responsibility, etc. will certainly not outweigh the fact that living conditions continue to deteriorate. We must have the continued partnering of the banking community with the government programs to provide safe and decent housing for the less advantaged and elderly. 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.

William H. Tilly, Jr.
Executive Director
ALABAMA MULTIFAMILY LOAN CONSORTIUM