Federal Deposit
Insurance Corporation

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

I am writing to request that you to withdraw your proposed changes to the Community Reinvestment Act (CRA) regulations. My organization, the Cleveland Housing Network, knows first hand that the CRA has been instrumental in increasing homeownership, boosting economic development, and expanding small businesses in the nation's low- and moderate-income communities.

The Cleveland Housing Network, established in 1981, was founded to create a citywide production system to achieve comprehensive community development and cultivate strong, vibrant and economically viable neighborhoods. CHN's mission is to develop a continuum of safe, energy efficient and affordable housing and homeownership options for low and moderate-income Cleveland families. CHN's housing development programs include the construction and rehabilitation of 300 single-family homes each year, transitional and permanent housing options for formerly homeless families, and a pilot initiative to preserve the affordability of expiring, Section-8 assisted multi-family housing. Over the past 23 years, CHN's programs have built more than 3,000 homes, and have generated more than $250 million of capital investments in Cleveland's neighborhoods. Simply put, the Community Reinvestment Act has been the single most important cornerstone of our track record. Without the strong support from our financial institution partners, this work would not have been possible.

The proposed FDIC rule would exempt many of our community's key financial partners from the effective and productive requirements currently in place. We oppose any increase to the threshold of what is considered to be a small bank, and we urge the FDIC to withdraw its proposed rule.