Federal Deposit
Insurance Corporation

Southwest Key Programs

From: Oscar Ramirez (100 : Admin) [mailto:oramirez@swkey.org]
Sent: Monday, October 18, 2004 4:28 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

As the Director of Economic Development for Southwest Key Programs, we oppose the FDIC's proposal to allow banks with assets above $250 million to be examined as small banks under the Community Reinvestment Act. This policy would reduce lending, investments and services in low-income communities. Banks have a responsibility to their communities and unfortunately, many would not provide the services they offer now to low-income communities without these requirements (they would find a way around these). Our opinion is that if they are going to be in the community, they should have the responsibility of giving back to that community. We oppose the FDIC’s proposal because it guts the CRA and waters it down. Thank you.

_________________________________________
J. Oscar Ramirez
Director of Economic Development/Legal Counsel
Southwest Key Programs, Inc.
3000 S. IH-35, Suite 410
Austin, TX