Federal Deposit
Insurance Corporation

From: Allen Hays [mailto:allen.hays@uni.edu]
Sent: Wednesday, October 20, 2004 5:44 PM
To: Comments
Subject: Proposed CRA rule changes

10/20/04

Re: RIN 3064-AC50

The Community Reinvestment Act has been a very successful piece of legislation in inducing banks to reinvest in disadvantaged neighborhoods that they had been avoiding in the past. By raising the asset floor below which a bank need not comply, you are, in effect, gutting the CRA requirement. Since the banks that serve most communities will fall below this floor, you are removing an important tool that these communities have to stimulated reinvestment.

I have been a housing scholar for 25 years, as well as a housing professional and a community organizer. I know the positive impact that this law has had, and I think it would be a tragedy if its effectiveness were seriously diluted.

R. Allen Hays, Director
Graduate Program in Public Policy
University of Northern Iowa
Cedar Falls, IA 50614-0137

Author of /The Federal Government and Urban Housing/, 1st and 2nd
Editions, SUNY Press