From: George Garchar [mailto:ccho@cboss.com]
Sent: Wednesday, October 13, 2004 12:24 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
To whom it may concern,
I am writing to express my concern about the proposed regulatory changes
that would exempt small banks and expand the definition of what constitutes
community reinvestment in rural areas. As I understand the changes,
financial institutions would be able to claim investment activities in rural
areas that have no true "community development" benefit. It seems to me we
don't need to encourage more market rate subdivision development in rural
areas. Unfortunately, more than enough of that is already occurring without
our having to give banks CRA credit to do it.
George Garchar
Executive Director, Catholic Charities Housing Opportunities