Federal Deposit
Insurance Corporation

City of Kansas City, MO - Office of the Mayor

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 opposed to the watering down of the Community Reinvestment Act requirements for mid-sized banks. CRA is vital for increasing homeownership and economic development in lower-income communities. However, your proposed changes will stop the progress that has been made.

I understand that banks with more than $250 million in assets must be tested on their number of loans, investments and services to low-and-moderate communities. But your proposal would eliminate the investment and service requirements for all banks with less than $1 billion in assets. This will significantly reduce loans and investments in affordable rental, housing, health clinics, community centers, and economic development projects.

Under the proposed change, mid sized banks would choose which community development activities they would undertake. Right now, these banks must make community development loans, investments, and services. Your proposed test allows banks to choose only one of those activities and it is inevitable they will choose to do less community development activity.

Your changes directly oppose CRA's mandate to require lenders to meet community needs. CRA is too important to be gutted. Please drop your proposal like the two other federal agencies which recognized the potential harm to underserved communities.

Sincerely,
Kay Barnes
Mayor