Federal Deposit
Insurance Corporation

City of Durango

October 15, 2004

Robert Feldman
Executive Secretary
Attention: Comments/Legal ISS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429-9990

RE: RIN 3604-AC50

Dear Mr: Feldman:

I am writing on behalf of the City Council of Durango, Colorado to ask that the FDIC NOT change the definition of a small bank for $250 million to $1 billion in deposits., The three-part exam is a critical component of making sure that access to capital is fair and balanced. The requirements of the Community Reinvestment Act helps ensure that less fortunate segments of our community have access to capital, and this makes for a healthier community.

Affordable housing is a case in point. Our community has invested in affordable housing projects for over 20 years. We currently invest $50,000 each year into an affordable housing fund. However, our area has difficult geography, with hard to develop slopes, sometimes on expansive soils, increasing the per unit costs above industry averages. Often a slight decrease in the interest rate on a construction loan, or in long-term financing, can make the difference between a project being built or not. CRA encourages lenders to become active partners to ensure a project's success.

Finally, we believe that CRA credits should not be diverted from where' they are truly needed, to assist low and moderate income people and places. Thus, we would urge that the FDIC not take any actions that would undermine the original
goals of the Act.

Sincerely
Robert F. Ledger, Jr.
City Manager