Federal Deposit
Insurance Corporation

From: Chuck Miller [mailto:chuck.miller@treasurer.mo.gov]
Sent: Tuesday, October 19, 2004 3:48 PM
To: Comments
Cc: Nicole_Hackmann; Mark Mathers; Scott Harper; Richard Moore; Robert Boone; suzanne archer
Subject: Community Reinvestment -- RIN 3064-AC50 on behalf of Nancy Farmer, State Treasurer

October 19, 2004

The Honorable Donald E. Powell
Chairman
Federal Depository Insurance Corporation
550 17th St. NW
Washington, DC 20429

RE: Opposition to RIN 3064-AC50

Dear Chairman Powell:

I would like to voice my strong opposition to the proposed FDIC revisions to 12 CFR 345, the Community Reinvestment Act. The proposed FDIC revisions would remove CRA obligations from many rural banks, discouraging many of these banks from being partners with public entities that promote economic development and affordable housing.

This proposed change is fundamentally flawed and could dilute resources away from underserved populations. I understand that this proposal could result in CRA credit being given to banks that make substantial loans to corporate executives for vacation retreats located in rural areas. In addition, a bank could be deemed to have provided community services to individuals in rural areas by merely placing copies of the FDIC's "Money Smart" brochures on its counters. Obviously, neither of those activities would serve the same benefit to low- and moderate-income individuals as other types of services such as basic banking accounts or remittances.

As State Treasurer, I serve on the Missouri Housing Development Commission and have a vital interest in the economic development of this state. I have no doubts that if this proposal is adopted affordable housing and economic development will suffer in rural areas.

Sincerely,
Nancy Farmer
State Treasurer

Chuck Miller, Deputy State Treasurer
Office of the Missouri State Treasurer
PO Box 210
Harry S Truman Building Room 780
Jefferson City, MO 65102
573.751.4974 phone
573.751.0343 fax
chuck.miller@treasurer.mo.gov
www.treasurer.mo.gov