Federal Deposit
Insurance Corporation

September 16, 2004

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

RE: RIN Number 3064-AC50

Mr. Feldman:

I am writing on behalf of Housing Resources of Columbia County, Inc to voice strong opposition to the FDIC's proposed changes to the regulations governing the Community Reinvestment Act (CRA). Raising the asset threshold for small banks to $1 billion would severely weaken the CRA and undermine partnerships that community development organizations such as ours has developed with local banks.

Housing Resources of Columbia County, Inc. is a non-profit organization that advocates for better neighborhoods and housing for low and moderate income individuals and families. We are a NeighborWorks organization that uses Neighborhood Reinvestment funds to leverage private dollars in order to create new homeowners, revitalize distressed communities, and build single family and multi-family housing for low to moderate income families.

Since 1996 the NeighborWorks Campaign for Home Ownership has assisted 70,000 households to become homeowners, 89% of whom were low or moderate income. Additionally, the network provided homeownership counseling to more than 420,000 individuals: None of this could have been achieved without the significant participation of local bank partners, as investors, lenders and service providers.

A major issue that many of the rural NWOs struggle with is the loss of small and medium sized, locally controlled banks as that industry is consolidated through mergers. This trend has a significant impact on low and moderate income communities – the very communities that we serve. A result of these mergers is the reduction of community lending programs and local loan officers; the transfer of grant making and lending decision making goes to central bank headquarters that are more often than not, far away from the applicant community. Bank centralization is particularly difficult for rural areas; most bank headquarters are located in urban centers where decision makers have little knowledge of rural communities.

CRA provides one of the few tools which Housing Resources and other community based organizations can influence the merger process. Again, we express our opposition to regulatory changes designed to allow more institutions to bypass the full CRA exam process.

Sincerely,