Federal Deposit
Insurance Corporation

Housing Opportunities Commission of Montgomery County, MD

October 21, 2004

Robert E. Feldman, Executive Secretary
Federal Deposit Insurance Corporation
Attention: Comments/Legal ESS
550 17th Street, N.W.
Washington, DC 20429

RE: RIN 3064-AC50: Notice of Proposed Rulemaking to 12 CFR Part 345

Dear Mr. Feldman:

The Housing Opportunities Commission of Montgomery County, Maryland appreciates this opportunity to comment on the FDIC's proposed changes to Community Reinvestment Act (CRA) requirements. We oppose the change to the definition of "small bank." In Maryland, for example, we have 19 banks with assets between $300 million and $1 billion. If the proposed rule is made final, none of those would undergo a full CRA examination. Furthermore, Maryland has another 34 banks with assets between $100 and $300 million. A portion of them would also be exempt from full CRA examination if the rule goes into effect.

It is unwise at best, and perhaps reckless, to eliminate regulatory incentives for commercial banks to use their private capital to leverage public dollars. CRA has been successful in creating access to community development loans, investments and services for low- and moderate-income households and communities. These families and communities have benefited from CRA regulations. FDIC's proposed rule will impair the creation and preservation of affordable housing and community and economic development.

The communities that CRA was enacted to protect will suffer if these proposed regulations are implemented. CRA has led to increased lending, investment and banking services in communities that were underserved. The Housing Opportunities Commission therefore opposes the proposed rulemaking and asks the FDIC to withdraw it immediately.

Thank you for providing the opportunity to comment on this proposed rule.

Sincerely,
D. Scott Minton
Executive Director