From: Fred Bennett
Sent: Friday, August 27, 2004 10:52 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
I
have been developing, building and managing affordable housing
in the rural areas of Florida, Alabama, Georgia and Mississippi
since 1969. The Community Reinvestment Act is essential to both
rural and urban affordable housing development. Perhaps more than
any single institutional change in the last 30 years, the CRA program
has helped to bridge the "information and cultural gap" that
heretofore has inhibited banks from lending in less affluent areas
of the South.
We therefore strongly oppose any increase to the threshold of what
is considered a "small bank." Small banks are the banks
that presently lend in these communities, and in fact, are best
positioned to make good loans in these areas. The proposed rule
would exempt many of our community's critical partners from the
effective and productive requirements currently in place at the
point in time when most of them are now becoming truly comfortable
with these requirements.
I pray that the FDIC will withdraw this proposed rule.
