Federal Deposit
Insurance Corporation

From: Tarry Edington [mailto:tarryhra@grandrapidsmn.com]
Sent: Monday, October 18, 2004 4:57 PM
To: Comments
Subject: RIN 3064-AC50

I stand in opposition to your modification of the Community Reinvestment Act requirements. The removal of the requirements of the Act on the vast majority of institutions could, and in my judgment, will have detrimental effects on the amount of capital reinvested in small communities, especially the rural communities of the U. S. Banks need the incentive of compliance with the Act to cause them to look for ways they can invest their money into local projects. As a developer of housing for low-moderate income households, it is helpful to have local banks with this incentive and looking for ways to comply. Regulatory efficiency may need to be considered, but raising the level at which compliance is required and enforced by examination and broadening the language to “ balance their community lending investing and service activities based on opportunities in the market and the banks own strategic strengths” is not the way to do it. A bank’s strategic strength is always making the maximum return with the least amount of effort and risk. Given the opportunity, most banks will take that course of action. Requiring them to reinvest in the local community is essential to stem the outflow of money from the local community to investments in larger financial markets. The Act has served the country well and should be continued in a manner that perpetuates its original intent.

Yours for success,

Tarry Edington
Housing Development Specialist
Itasca County HRA