From: Jim Wheaton [mailto:Jwheaton@nhschicago.org]
Sent: Thursday, October 14, 2004 6:42 PM
To: Comments
Subject: SPAM::RIN 3064-AC50

I am a registered voter in the City of Chicago, State of Illinois and wish to offer my comments in opposition to rule change proposed by the FDIC with regard to the designation of "large" and "small" financial institutions under the Community Reinvestment Act.

I work in the area of community development and have done so for more than 25 years. During that time, I have seen the positive effects created by the requirements of CRA - lower-income neighborhoods have benefited from loans and new capital, new markets have been created for conventional lenders throughout Chicago as a result of CRA-type lending, and thousands of new homebuyers and lower-income homeowners have been able to get financing to purchase a home, improve their living conditions through home improvement, and build wealth for themselves and their families from the equity in their home.

Changing the classification of lending institutions would present a real threat to the progress that has been made in providing access to capital for lower-income families and for homes in economically-disadvantaged neighborhoods. Re-classifying institutions so that they are no longer held to a more rigorous standard will create a situation wherein capital from the conventional lending institutions will be less available to such borrowers and neighborhoods and these borrowers and neighborhoods will have no other recourse than to go to the non-regulated lenders who are not interested in building wealth, creating equity, or even in responsible lending.

Your proposed change in the CRA is ill-advised and potentially devastating for older and lower-income neighborhoods across the country. I oppose the change and urge the FDIC to reconsider and not re-classify lending institutions.

James K. Wheaton
4903 N. Lawndale
Unit # 2
Chicago, IL 60625
jwnhs101@hotmail.com