Federal Deposit
Insurance Corporation

Housing Vermont


October 20, 2004

Mr. Robert E. Feldman

Executive Secretary

Attention: Comments/Legal ISS

Federal Deposit Insurance Corporation

550 17th Street, NW

Washington, DC 20429-9990.

Subject: RIN 3064-AC50

Dear Mr. Feldman:

This letter urges the FDIC to not adopt the proposed regulations which would fatally weaken the Community Reinvestment Act rules. The proposed rules would be especially damaging in rural areas like Vermont.

Vermont is well served by community banks, the vast majority of which have assets in the range of $250 million to $1 billion and, consequently, would be directly affected by the proposed rule change. Many of these banks are “community” institution in the best sense of that word. That is, they proactively seek community development opportunities. Unfortunately, we cannot rely simply on good faith as the basis for their continued participation in community development activities.

Community banks form the financial backbone of Vermont’s small towns. These institutions play vital roles in the communities they serve. Requiring that these banks demonstrate their community development achievements acknowledges the reality of their economic importance. It clearly represents sound public policy which fairly balances the public good with a reasonable level of regulation.

Thank you for this opportunity to comment on the proposed rules by stating our opposition.

Kenn Sassorossi

Vice President, Asset Management & Partner Relations

Housing Vermont

123 St. Paul Street

Burlington, VT