Federal Deposit
Insurance Corporation

From: Stuart GROGAN [mailto:grogans@ci.boulder.co.us]
Sent: Friday, October 15, 2004 5:26 PM
To: Comments
Subject: Comments regardomg RIN 3064-AC50

I oppose the FDIC's proposal to allow banks with assets above $250 million to be examined as small banks under the Community Reinvestment Act. This policy would reduce lending, investments and services in low-income communities.

I have found that CRA is critical to local housing and community revitalization activities...either through investing in rental housing or lending to homebuyers and small businesses. Smaller institutions are often closer to their communities and better able to ascertain opportunities. Often they pool resources to spread risk and undertake projects that smaller institutions alone could not participate in. They seem to have handled the mandates well to date; there is no compelling reason to relax the regulations. To do so will reduce resources and hamper local efforts.

I am concerned with any requirement for community lending that goes from mandatory to optional because the requirement will not promote an outcomes based community lending approach.

Thank you for your consideration of my concerns.

Stuart Grogan
New offices at 4800 B'way
Phone (720) 564-4644
Fax (303) 544-9553