From: Joanna Villone Hicks [mailto:joanna@windndc.org]
Sent: Thursday, September 16, 2004 1:16 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

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, like the ones in which I work in St. Paul and Minneapolis. The CRA guidelines have prompted many banks in our area to develop community lending practices that give new immigrants, minorities and low income communities opportunities to achieve greater wealth and assets through business development and homeownership. In a time when we need more opportunities, not less, this rule would discourage the types of positive steps that we have seen since the CRA’s creation.

Thank you.

JoAnna Villone Hicks
Real Estate Development Director

_________________________________________

Neighborhood Development Center
651 ½ University Avenue
St. Paul, MN 55104
651-291-2480 x15
Fax: 651-291-2597