From: Beth Hohl Asbury [mailto:beth@cooperativeresourcecenter.org]
Sent: Tuesday, October 05, 2004 10:12 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
To whom it may concern:
As affordable housing developers in three regions of the State of
Georgia, we are deeply concerned about the proposed changes to
the Community Reinvestment Act regulations for mid-sized banks.
Cooperative Resource Center is the largest nonprofit housing developer
in Georgia, and the vast majority of the financing for our affordable
family, senior, and special needs housing comes from mid-sized
banks. We believe the proposed changes will severely curtail our
access to the capital necessary to construct this much-needed housing.
CRA is a critical component to our community's affordable housing
and community development solutions. We oppose any increase to the
threshold of what is considered to be a small bank. The proposed
FDIC rule would exempt many of our community's critical partners
from the effective and productive requirements currently in place.
We urge the FDIC to withdraw its proposed rule.
Thank you for this opportunity to comment.
Sincerely,
Beth Hohl Asbury
Deputy Executive Director
Cooperative Resource Center, Inc.
191 Edgewood Avenue, SE
Atlanta, Georgia
