Federal Deposit
Insurance Corporation

21 September 2004

Mr. Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street NW
Washington DC 20429
Attn: Comments/Legal ESS
Re: RIN 3064--AC50

Dear Mr. Feldman:

The Community Action Committee of the Lehigh Valley opposes the FDIC's proposal to weaken the Community Reinvestment Act by raising the threshold for banks that are examined under the small bank test from $250 million to $1 billion CACLV has been a member of the National Community Reinvestment Coalition for more than ten years and has seen, through our community development efforts and CRA activism, how much of a difference CRA has made in our community. It is hard for us to imagine that the FDIC, in a time when communities are struggling to fund their way out of a recession, would want to weaken a law that has been so effective.

The Lehigh Valley, located in eastern Pennsylvania, has 22 banks with branches in the market. Fewer than ten of those falls below the $1 billion threshold and barely four fall below the $250 million threshold. Despite many years of working with the banking industry on a wide range of community development initiatives, none of those have played a particularly aggressive role. However, it is difficult for me to identify a single initiative of any of the smaller banks. Our region's lower-income families and neighborhoods will surely be denied access to credit if the banks between those two thresholds join the small banks by escaping the more rigorous test.

The Congress has repeatedly refused to cave in to the industry and weaken CRA. For the FDIC to do through regulation what the Congress would not do through legislation would be a gross misuse of its authority. I urge the FDIC to abandon its effort to weaken the Community Reinvestment Act.

Alan L. Jennings , Executive Director
Community Action Committee of the Leigh Valley
1337 East Fifth St., Bethlehem, PA