Federal Deposit
Insurance Corporation

From: Kathleen Halloran [mailto:kathleen@mesacan.org]
Sent: Tuesday, October 19, 2004 5:41 PM
To: Comments
Subject: Oppose Efforts to Weaken CRA RIN number 3064-AC50

Kathleen Halloran
635 East Broadway Road
Mesa, Arizona 85204

October 19, 2004

Federal Deposit Insurance Commission

Dear Federal Deposit Insurance Commission:

The work the Assets for Arizona Institute does in Arizona is dependent upon the reinvestment of funds required by the CRA. Many banks say because they are small, doesn't apply to them.

We need the ensure that the federal laws and reporting requirements provide to get these businesses investing and offering credit in neighborhoods where they take deposits.

To make the proposed change would have a devastating effect on affordable housing and community development investment throughout the nation, particularly in rural areas.

By proposing that community development loans and investments in rural areas can benefit any group of individuals, not just low- and moderate-income individuals, the FDIC guts opportunity for these people in our community.

Under the proposed changes, nothing in the CRA regulations would prevent banks from earning CRA points for financing developments with no community development benefit whatsoever. Moreover, the one part exams would cover 99 percent of all FDIC-supervised banks located in rural areas.

Please rescind your proposal. It would have a devastating effect on community development for the low- to moderate-income communities across the country at a time when they need this investment the most.

Sincerely,
Kathleen Halloran