From: Abrams, Donald-Bruce [mailto:don.abrams@bingham.com]
Sent: Wednesday, October 20, 2004 2:53 PM
To: Comments
Subject: FW: community reinvestment act

I am writing to oppose the FDIC's proposal to allow banks with assets above $250 million to be examined as small banks under the Community Reinvestment Act.

For the past 17 years, my wife has worked on projects involving the redevelopment of low income, distressed urban communities. The participation of banking institutions, including many small, local banks, has been invaluable to these projects. Particularly with the decline in direct federal grant assistance to affordable housing, the participation of banks - both as investors and lenders - has become absolutely essential to both housing and other economic development in
low-income communities. The FDIC's proposal would drastically reduce
the availability of funds for critically needed urban redevelopment projects, in addition to reducing lending and services available to individuals in low-income communities, many still suffering the effects of discrimination and "redlining" in the past.

I join my wife, who has commented separately, in urging the FDIC to continue to treat banks with assets above $250 million as large banks, subject to full CRA examination for lending, investment and services.

Donald-Bruce Abrams
17 Day Street
Cambridge, MA