From: Alan Arthur [mailto:AArthur@ccht.org]
Sent: Wednesday, October 13, 2004 9:20 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

To Whom It May Concern -
The proposed change to CRA rules to increase the asset threshold above which banks are required to undergo a full CRA exam from $250 million to $1 billion does NOT make sense. It would dance around the very purpose of CRA. This change would clearly negatively impact smaller communities, by reducing lending and investments, and negatively impact the overall health of those communities.

Therefore, 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. Banks above $250 million should continue to be examined with a full CRA exam.

Thank you.
Alan
Alan Arthur, President, Central Community Housing Trust
1625 Park Avenue South, Minneapolis, MN 55404-1634
612-341-3148 ext. 201 Fax: 612-341-4208 aarthur@ccht.org