Federal Deposit
Insurance Corporation

From: Minnesota NAHRO [mailto:mnnahro@qwest.net]
Sent: Tuesday, October 19, 2004 2:48 PM
To: Comments
Subject:

Sent: Tuesday, October 19, 2004
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

To Whom it May Concern:

The Housing and Redevelopment Authorities in Minnesota work extremely close with their small banks within their communities. They are regular purchasers of our tax exempt debt issuances that are done for our low income rental housing development efforts. They have often commented that their aggressive rate structure (i.e. low on our deals) gain them good CRA reviews. And small banks are much more responsive and aggressive in handling private placement of small tax exempt note purchases---far less bureaucratic than the larger institutions. Small banks have also been a partner in revitalizations of communities with providing private loans at decreased interest rates for qualifying owners to provide match funds in rehabilitating commercial and rental properties to renovate neighborhoods and provide community and economic development within communities. They also comment on how this assists them to achieve better CRA reviews.

As an association of Minnesota Housing and Redevelopment Authorities (HRAs) with nearly 150 agencies and 450 other members, our board of directors representing HRAs statewide know and have agreed through board action, that the Community Reinvestment Act is a critical component in Minnesota to affordable housing and community development solutions in our communities; and strongly oppose any increase to the threshold of what is considered to be small bank. The proposed FDIC rule would exempt many of our community’s critical partners from the effective and productive requirements currently in place. We urge FDIC to withdraw its proposed rule.

Patricia A. Gustafson, Executive Director
Minnesota Chapter of the National Association of Housing and Redevelopment Officials 1228 Town Centre Drive Eagan, MN 55123

Julie Frick, President Minnesota Chapter of the National Association of Housing and Redevelopment Officials 1228 Town Centre Drive Eagan, MN 55123