Non-Profit
Housing Association of Northern California
From: Doug Shoemaker
Sent: Thursday, August 26, 2004 8:22 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
On behalf of the Non-Profit Housing Association of Northern California
(NPH), we write in opposition to the FDIC's proposal rule which would
raise
the asset threshold for "small banks." The membership
of NPH, currently
about 500, draws together the main public, private, and nonprofit
partners
active in the preservation, development and management of affordable
housing
for low-income people in Northern California.
From our 30 years of experience, we know that The Community Reinvestment
Act is a critical component to our community¹s affordable housing
and
community development solutions. We oppose any increase to the threshold
of
what is considered to be small bank. The proposed FDIC rule would
exempt
many of our community¹s critical partners from the effective
and productive
requirements currently in place. We urge FDIC to withdraw its proposed
rule.
------------------------
Dianne J. Spaulding
Executive Director
The Non-Profit Housing Association of Northern California