Federal Deposit
Insurance Corporation

Community Action Council

October 19, 2004

Donald E. Powell, Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Dear Chairman Powell:

Despite the successes locally and nationally of community investment, the banks and thrift institutions that provided the loans and investments to build new homes, businesses, and community facilities may no longer have the impetus to do so if you change the CRA exam threshold.

We hear from our association, the National Congress for Community Economic Development that the Federal Deposit Insurance Corporation is considering changes to weaken the Community Reinvestment Act.

It is estimated that 2,000 financial institutions would no longer be evaluated on their investment or services to low- and moderate-income communities. These banks have assets of nearly $1 trillion, and an estimated $5 billion ofprivate capital for affordable housing and community development overthe next few years.

These proposed rule changes would have a devastating effect on affordable housing investment in our state d elsewhere throughout the nation, particularly in rural areas.

In the past 10 years our organization has produced 107 affordably homes and apartments, in addition to creating much needed jobs. We have increased property values and the quality of life for hundreds of residents of our community.

We are very concerned that this step is being taken without Congressional action. Our legislators know that without financial partners, our efforts to revitalize our community would be nearly impossible.

The FDIC should be strengthening incentives for financial institutions to invest in the communities that provide homes, jobs, and economic opportunities to working families. Please do not raise the CRA exam threshold.

Sincerely,
JEFFERSON COUNTY CAC, INC.
Barbara V. West
Chief Executive Officer