Federal Deposit
Insurance Corporation

From: Randy G. Thomason [mailto:randygthomason@netscape.net]
Sent: Monday, October 18, 2004 1:30 PM
To: Comments
Subject: RIN 3064-AC50

I would like to make the following comments regarding raising the asset threshold from $250 million to $1 billion for financial institutions that have to undergo the comprehensive CRA examination. Since CRA, the Housing Authority of the City of Shawnee, Oklahoma has been able to work with area banks more closely in addressing the needs of low and moderate-income clients. We have found these institutions more eager to listen and more willing to partner in adapting strategies.

The Housing Authority is currently working with area banks to partner on our new Section 8 Homeownership program, a program supported strongly by the President. These banks are also being asked to help with Homeownership Programs that are not Section 8, but are low to moderate-income in nature. It is our belief that raising the threshold will significantly reduce the number of institutions available to address these programs, causing a reversal in improvements obtained by CRA. Removing the requirements on the investment and service elements and making them optional under the lending test would be a serious step backwards, and would ultimately reduce homeownership for these families. This decision seems to fly in the face of the President's commitment to homeownership, and we would hope you will reconsider.

Thank you for the opportunity to comment on this important matter.

Randy G. Thomason
Executive Director
Housing Authority of the City of Shawnee, Oklahoma