Jeff Merkowitz
1209 Noe St.
San Francisco, CA 94114-3713



January 6, 2006

Robert Feldman
Federal Deposit Insurance Commission
550 17th Street, NW.,
DC 20429


Dear Robert Feldman:

The most effective way to expand access to credit to underserved borrowers 
is to implement rigorous and comprehensive CRA exams that maintain the 
focus on meeting the credit and deposit needs of low- and moderate-income 
borrowers and communities.

The final Q & A Notice should clarify that the community development exam 
criterion includes an examination of the number and percent of branches in 
low- and moderate-income communities.

In addition, I recommend that the final Q &A Notice provide CRA points for 
the provision of low-cost banking services.

CRA exams should also penalize banks for abusive products such as bounce 
protection, the wealth stripping features of which are not advertised 
clearly to consumers.

Finally, I encourage the regulators to add an anti-predatory lending 
provision to the CRA regulations that will penalize banks for illegal, 
abusive, and discriminatory loans.

Thank you for the opportunity to comment on the need for a strong CRA.

Sincerely,


Jeff Merkowitz