Federal Deposit
Insurance Corporation

From: Beth Weinstein [mailto:bweinstein@jamboreehousing.com]
Sent: Wednesday, October 20, 2004 5:54 PM
To: Comments
Cc: Laura Archuleta; cra@nahro.org
Subject: RIN: 3064-AC50

October 20, 2004
Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429

RE: RIN 3064-AC50: Notice of Proposed Rulemaking to 12 CFR Part 345

Dear Mr. Feldman:

Jamboree Housing Corporation would like to take this opportunity to comment on the FDIC’s proposed changes to the Community Reinvestment Act (CRA) Requirements.

Jamboree Housing Corporation (JHC) was incorporated in 1990 as a non-profit 501(c)(3) public benefit corporation to expand housing opportunities for low-income households. JHC’s role as a non-profit developer has been important to a variety of local jurisdictions in building, acquiring, and renovating permanently affordable housing units (both rental and for-sale) for low income families and seniors. JHC has an ownership interest in, developed or assisted in over 3700 units across the state of California.

JHC faces many challenges to building affordable housing in a high cost and highly populated region. JHC firmly believes that the Community Reinvestment Act has helped to increase the amount of funding available to developers for affordable housing construction or acquisition rehabilitation and also has helped to increase homeownership among low income individuals and seniors.

Under existing CRA regulations a small bank is defined as a bank with assets of $250 million or less. The changes currently being proposed would increase the asset threshold to $1 billion. JHC opposes the proposed changes to the definition of a “small bank.” The proposed changes would eliminate the investment and service components of the CRA examination for state chartered banks with assets between $250 million and $1 billion. In place of the investment and service part of the CRA exam, the FDIC proposes to add a community development criterion. The community development criterion would require mid-size banks with assets between $250 million and $1 billion to engage in only one of three activities: community development lending, investing or services. Currently, mid-size banks must engage in all three activities. We believe that these changes will result in less investment in low and moderate income communities and therefore in opposition to the original intent and spirit of the CRA.

FDIC’s proposal would also eliminate the small business lending data reporting requirement for mid-size banks. Mid-size banks with assets between $250 million and $1 billion would no longer be required to report small business lending by census tracts or revenue size of the small business owners. State chartered and mid-size banks play an important role in meeting the financial needs of local communities. We urge you to maintain the current level of evaluation and reporting requirements for these banks.

Taken as a whole the proposed changes will hurt the very communities CRA was enacted to protect. CRA has been the driving force behind increased lending, investment and banking services in what were underserved communities. Efforts to weaken these protections will have a devastating impact on these communities and our capacity to create affordable housing within them. With government funding shrinking, eliminating regulatory incentives for private capital to leverage public dollars is reckless. For these reasons JHC is opposed to the proposed changes.

Thank you for the opportunity to comment on the proposed rule.

Sincerely
Laura Archuleta
President
Jamboree Housing
2081 Business Center Drive, Ste. 110
Irvine, CA 92612