From: Robert Burns [mailto:burns@avalon.net]
Sent: Tuesday, August 31, 2004 5:32 PM
To: Regs
Subject: Proposed Regulation RIN 3064-AC50
Dear Sit or Madame,
We recommend against a change in the threshold to $ 1 Billion for
certain compliance with CRA requirements. The proposed increase will
deter raising equity from banks for affordable housing under the low
income housing tax credit (LIHTC).
As a developer of affordable rental housing, we have found that CRA
credit has been one of the prime motivations of financial institutions
to invest in Section 42 LIHTC. Many banks with assets under $1 billion
have invested in the past. Increasing the cap will reduce the amount of
capital available to finance affordable housing.
We have recently developed an affordable assisted living project at
Iowa City that has been able to save federal and state funds an average
of $1,200 per month per tenant who remains out of a nursing home in our
assisted living development. Eighteen of the fifty-four dwelling units
are occupied by tenants who moved out of a nursing home. The other
tenants are able to avoid premature institutionalization to a nursing
home. FDIC's proposed rule change would discourage development of
similar projects.
Please leave the qualification at its current category.
Robert P. Burns, Manager
Burns & Burns, L.C.
Architects, Developers, Property Managers
319 E. Washington St., Suite 1226
Iowa City, Iowa 52240
