From: Jan Parke [mailto:janparke@turn.nu]
Sent: Tuesday, October 05, 2004 12:35 PM
To: Comments
Subject: RIN Number3064-AC50
May we add our voice to those who oppose any increase to the threshold
of what is considered to be a small bank. Utah is a breeding ground
for Independent Loan Banks as well as many Thrift and Savings quasi
banks and many small home town units that currently meet the definition
and have been involved in making CRA donations of significance to
their communities BECAUSE of the CRA structure in place.
Changes that will dilute their responsibility to the communities
in which they are chartered will negataively impact agencies such
as ours that provide affordable housing to low income persons with
disabilities and similarly challenged citizens.
Under the current CRA rules, we make make application and expect
to receive assistance in improving the number and quality of housing
and rental stock in each of our communities from CRA funds. Funds
that cannot be borrowed by nonprofits on current LTV or cash flow
basis.
We urge the FDIC to withdraw its proposed rule. The CRA funds coupled
with HUD HOME, CDBG and Section VIII vouchers are the means for
most of the disabled population to own or rent affordable, attractive
and safe places to live.
