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FDIC Federal Register Citations
From:
raubg [mailto:raubg@norwescap.org]
Sent: Monday, October 18, 2004 8:58 AM
To: Comments
Cc: meaded
Subject: RIN 3064-AC50/Community Reinvestment 12 CFR Part 345
On August 20, 2004, the FDIC requested comment on revisions to 12
CFR 345 implementing the CRA that would (a) change the definition of
``small bank'' to raise the asset size threshold to $1 billion
regardless of holding company affiliation; (b) add a community
development activity criterion to the streamlined evaluation method for
small banks with assets greater than $250 million and up to $1 billion;
and (c) expand the definition of ``community development'' to encompass
a broader range of activities in rural areas. In addition, the FDIC
also sought comments on other options. Please note that I oppose the
FDIC's proposal to allow banks with assets above $250 million to be examined
as small banks under the Community Reinvestment Act. AS I understand
it, I believe that this policy would reduce lending, investments and
services in low-income communities. So please take this into consideration
before finalizing any changes and revise as necessary. Thank you.
Sincerely,
Gail A. Raub
1741 Raub Lane
Phillipsburg, NJ 08865
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