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