Federal Deposit
Insurance Corporation

City of Concord, CA

October 18, 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:

As Mayor of the. City of Concord, CA.- (pop 124,000) I am writing in opposition to proposed changes to the Community Reinvestment Act requirements for mid-sized banks. Currently, banks with over $250 million in assets must be tested on their number of loans, investments and services to low and moderate income neighborhoods. Under the proposal, banks with assets of up to $1 billion would have no investment or service requirements. This will result in significantly fewer loans and investments in affordable rental housing, health clinics, community centers and economic, development projects.

The proposal would also eliminate publicly available data on the small business lending practices of mid-size banks. Without this data community groups and citizens cannot hold banks accountable for lending to small businesses in their neighborhoods. For these reasons, I urge you to OPPOSE the changes contained in Docket No. RIN 3064-AC50.

Sincerely,
Helen M. Allen
Mayor, City of Concord