October 15, 2004

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

Dear Mr. Feldman:

RE: RIN 3064-AC50

On behalf of the Everett Housing Authority, I wish to express opposition to the proposed changes in the CRA requirements for mid-sized banks. There was a noticeable increase in the interest all banks, including mid-sized ones, expressed in affordable housing as a direct result of the 1995 CRA modifications.

Mid-sized banks are an important part of many of our local efforts to meet the significant housing needs of our community. We have no doubt that the FDIC’s elimination of the service and investment requirements for all banks with less than $1 billion in assets would quickly reduce the number of lenders interested in affordable housing opportunities and result in fewer investment dollars going into this important area.

The CRA has worked! It should not be weakened in the face of its proven success. The FDIC should withdraw the proposed regulatory changes and reaffirm the importance of the CRA in providing affordable housing for this country’s low-income families.

Sincerely,
Bud Alkire
Executive Director