Federal Deposit
Insurance Corporation

From: jrestuccia2@clintonhousing.org [mailto:jrestuccia2@clintonhousing.org]
Sent: Friday, October 15, 2004 6:27 PM
To: Comments
Subject: Save the Community Reinvestment Act

Dear FDIC,

Mr. Feldman:

I am the Executive Director of not for profit community based organization which has developed over 1200 units of affordable housing at over 100 locations onthe Westside of Manhattan. Our organizaton opposes your proposed rule proposal that would ease Community Reinvestment Act (CRA) requirements for most of the banks in New York City and the metro area. CRA is vital for increasing homeownership, promoting minority business ownership, meeting the community development needs of struggling communities and support the capital requirements of nonprofits.

This rule would be harmful to New York and its suburbs. In the new watered-down process for mid-size banks, FDIC would allow these financial institutions to pick and choose which community development activities they will undertake. Right now, these banks must make community development loans, investments, and services. Your proposed test allows banks to choose only one of the three activities. The result will be less community development activity in New York and its metropolitan region. That will mean fewer jobs, fewer homes and fewer community services.

The Community Reinvestment Act was made law to require lenders to meet community needs. Your rule proposal flies directly in the face of this requirement. It would harm New York City, its metro region and the entire state. This change would affect the quality of life for tens of thousands of Americans. This rule change makes no common sense. Please drop this hurtful rule proposal.

Joe Restuccia
New York, New York