Federal Deposit
Insurance Corporation

Mr. Robert Feldman
Executive Secretary
Attention Comments/Legal ESS
Federal Deposit Insurance Corp.
550 17th Street NW
Washington DC, 20429-9990

Re:RIN 3064-AC50

Dear Mr. Feldman:

As a concerned member of the San Diego Real Estate Professional Community I am contacting you to express my concern and to discourage your plan tomodify the threshold for CRA examination to dilute Community Reinvestment Act requirements for institutions with assets less than $1B. The reduced requirements would include modification of testing requirements on the number of investments and services in low and moderate-income areas. The second is to allow mid sized banks reduce their community development activities.

As I understand the issue, this ruling would apply to all locally headquartered banks in San Diego. It would only exclude the very large national banks. It would create an unequal playing field in the banking industry in this region. It would allow for market domination in major geographical areas of the County for specific products and services. It would exclude ethnic and lower income residents from basic banking services and thereby be in direct violation of the federal Community Reinvestment Act and quite possibly the Fair Housing Act.

As I further understand it, the effect is to allow smaller banks to behave the way that they have traditionally been behaving in terms of CRA compliance. In my personal experience, they traditionally display an acute disregard for their obligation to the larger community. Branches are almost exclusively in suburban, wealthier communities. The smaller banks very seldom participate in regional consortia or directly offer products or access to simple access to basic banking services.

In my view, your decision will legitimatize the exclusionary lending policies of these institutions.

Smaller banks in San Diego are a growth industry. We grow banks for larger, multi- national institutions. This is part of the reason that these banks eschew CRA. It may interfere with their purchase by larger banks. The small banks exist not for the benefit of the consumer but rather for a select number of shareholders. CRA regulations (however limited) are the only link to the larger community required by a bank charter.

Government has provided much protection and risk diversion with affordable housing, investments and small micro lending efforts. This was offered with the confidence that the lenders would equally commit. The RTF has done constant and disciplined assessment of credit access and through dialogue, face to face, many new and innovative solutions have been created, so much so that a thriving and profitable "industry" has emerged in this region focused on economically healthy communities.

With the cost of real estate continuing to rise basic affordable housing is becoming an unobtainable goal for far too many lower income wage earners. If the smaller banks in San Diego have no interest or obligation in providing their services to these individuals the greater public interest is not served. The dream of Home Ownership should be made available to as many familys as possible.

We urge you to rescind your intent to reduce CRA related policies toward smaller banks. You will exclude them from very beneficial markets and encourage recognition that they are part of a larger community and can contribute to the regions overall economic growth.

Respectfully submitted,

Richard Trent, REALTOR
Real Estate Consultant
3365 Rosecrans Street, Suite B
San Diego, CA 92110

CC: NCRC
Rep. Bob Filner
REp. Susan Davis