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

RE: RIN 3064-AC50

September 29, 2004

Dear Mr. Feldman:

JOLT (Justice Organizers, Leadership and Treasurers) urges you to withdraw your proposed changes to the Community Reinvestment Act (CRA) regulations. CRA has been instrumental in increasing homeownership, boosting economic development, and expanding small businesses in the nation's immigrant, low- and moderate-income, and people of color communities.

Our members invest in non-profit projects, which benefit from the bank involvement that would not have happened without the incentive of CRA. At the same time, we believe that the mission of banks in these communities is to offer them financial services so that they do not turn to Payday lenders, etc. It is the Community Reinvestment Act that has spurred this activity and helps us to assure that all have adequate access to capital.

The FDIC proposal would significantly harm community development activities, especially in rural areas. The proposal states that a bank's rural community development activities could benefit any group of individuals instead of only low- and moderate-income individuals. Many individuals already have access; we need to safeguard the access of low and moderate income and minority populations.

In sum, the FDIC's proposal is directly opposite CRA's statutory mandate of imposing a continuing and affirmative obligation to meet community needs. The proposed changes will dramatically reduce community development lending, investing, and services. The proposal will particularly affect rural areas least able to afford reductions in credit and capital. The Federal Reserve Board and the Office of the Comptroller of the Currency have recognized the harm this proposal would cause.

CRA is a vital reinvestment tool. If the FDIC refuses to reverse this proposed course of action, we will ask that Congress halt your efforts.

Sincerely
Corinne Florek, OP
JOLT Coordinator
Oakland, CA