From: Nick Cardoso [mailto:ncardoso@unitedhomesintl.com]
Sent: Wednesday, September 15, 2004 3:51 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
TO WHOM IT MAY CONCERN:
The CRA is a critical component to Florida's affordable housing and
community development solutions. Currently, there are many forces
working against the feasibility of affordable housing including, but not
limited to the low interest rate environment and the booming real estate
environment, which work against some of the financing vehicles used for
affordable housing, such as bonds. Also, the Governor's redution of SHIP
funds, which was created specifically for affordable housing. Plus, the
increased scarcity in land and the value at which the land can be
purchased. I oppose any increase to the threshold of what is considred
to be a small bank, this would be yet another set back to the
feasibility of affordable housing at a time when the need is so great.
The proposed FDIC rule would exempt many of our community's critical
partners from the effective and productive requirements currently in
place. I urge the FDIC to withdraw its prosed
rule.
Nicholas Cardoso
United Homes International
(305) 558-2600
