Federal Deposit
Insurance Corporation

September 20, 2004

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

RE: BIN 3064-AC50

Dear Mr. Feldman:

At Volunteers of America we have a program to build and remodel homes for low to moderate income people. We also run homeless shelters providing 35,000 bed-nights of emergency and transitional shelter per year. Our banks routinely discuss CRA credit as their incentive to finance our projects. These loans are often low margin for the banks and the CRA is vital to sustain homeownership and economic development in lower-income communities.

I understand that banks with over $250 million in assets must be tested on their number of loans, investments, and services to low and moderate-income communities. But your proposal would eliminate the investment and service requirements for all banks with under $1 billion in assets. This will result in significantly fewer loans and investments in affordable rental housing, health clinics, community centers and economic development projects.

In Michigan, the FDIC oversees 107 institutions, controlling $31 billion in assets. Overall, 93% have under $1 billion in assets and 22% have between $250 million and $1 billion in assets and would be affected by the proposed changes in CRA regulations. Eighty nine percent of the institutions in urban areas have less than $ I billion in assets. If the proposed changes to CRA are adopted by the FDIC, 46% of the assets in urban Michigan would not be subject to the current level of scrutiny under CRA. I'm further concerned that accountability would be lost due to dropping public reporting under the act.

Your changes directly oppose CRA's mandate to require lenders to meet community needs. CRA progress is too important to be cut back. I urge you to reconsider your proposal.

Sincerely,
Patrick Patterson
Director of Operations
Volunteers of America
Lansing, MI