From: Bobstil@aol.com [mailto:Bobstil@aol.com]
Sent: Sunday, September 19, 2004 7:16 PM
To: Comments
Subject: Re RIN Number 3064-AC50 Changes to CRA
I am writing to urge FDIC not to change the regulations governing the
Community Reinvestment Act, as has been proposed.
I am Chairman of SEAF US Partners, which is raising a $120 million
investment fund that will invest almost excluseively in low and moderate
income areas and minority-owned companies. Even withi two thirds of this
amount guaranteed by SBA under the SBIC program, it has been difficult
to convince investors to invest in these businesses, most of which will
be located in inner cities.
The CRA program encourages banks to invest in these areas, so vital
for economic developmant of our cities. It has been extremely effective,
as I observed when I was Assocate Administrator for Investmet at the
U.S. Small Business Administration from 1993 to 1995. The proposed
changes would substantially weaken the program, and remove from the
market most of the banks that now provide capital for inner city
investment.
I would be plaeased to elaborate on this, based on over 40 years of
private equity experience in the private and public sector. I hope the
proposals will be reconsidered, and at least deferred indefinitely.
Robert D. Stillman
Chairman, SEAF US Partners, L.P.
202-737-8463, Ext 103
