Federal Deposit
Insurance Corporation

From: Michael Hickey [mailto:michael.hickey@db.com]
Sent: Tuesday, September 21, 2004 5:21 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

To whom it concerns,

As a community development banker, I oppose the FDIC's proposal to increase the asset threshold for the CRA "streamlined" exam to $1 billion. The proposal will harm low- and moderate-income communities across the country by reducing private capital for affordable housing and community and economic development. While I support a meaningful "Community Development Test" for all institutions as a way of increasing private capital for these important activities, the proposed "Community Development Criterion" is a poor substitute.

Sincerely,

Michael Hickey
Vice President
Deutsche Bank
60 Wall St
NYC60-2110
New York, NY 10005