Federal Deposit
Insurance Corporation

From: Brenda Clement [mailto:bclement@housingnetworkri.org]
Sent: Tuesday, October 19, 2004 3:16 PM
To: Comments
Subject: Oppose Efforts to Weaken CRA RIN number 3064-AC50

Brenda Clement
48 Nashua Street
Providence, RI 02904

October 19, 2004

Federal Deposit Insurance Commission

Dear Federal Deposit Insurance Commission:

Despite the successes of community development locally and nationally, the banks and thrift institutions that provide the loans, services, and investments to build new homes, businesses, and community facilities may no longer have the impetus to do so if the FDIC raises the comprehensive CRA exam threshold. Rhode Island has been dramatically impacted by bank mergers which have left few local banks with local decisionmakers who understand low-moderate income Rhode Islander's concerns and needs.

I agree with the National Congress for Community Economic Development that this proposed change would have a devastating effect on affordable housing and community development investment throughout the nation, particularly in rural areas. The proposed community development criterion is not a replacement for ensuring adequate services and investment reach low- and moderate-income individuals and communities. Successful development must be targeted to lower income individuals and/or communities, not rural areas generally.

Please rescind your proposal.

Sincerely,
Brenda J. Clement