Federal Deposit
Insurance Corporation

From: Neil Gaffney [mailto:ngaffney@co.ho.md.us]
Sent: Monday, October 18, 2004 1:45 PM
To: Comments
Cc: cra@nahro.org
Subject: RIN 3064-AC50

I am against modifying the Community Reinvestment Act (CRA).

The proposal would:
-Raise the asset threshold from $250 million to $1 billion of financial institutions that have to undergo the comprehensive CRA examination
-Add language allowing banks to "balance their community lending investing and service activities based on opportunities in the market and the banks own strategic strengths." This impacts the low and moderate income

These modifications not only decrease the number of banks that would face the comprehensive compliance exams, but would also affect the examination itself by removing the requirements on the investment and service elements and instead making them options under the lending test.