Federal Deposit
Insurance Corporation

From: Michelle L. Witham [mailto:witham@mhic.com]
Sent: Wednesday, October 20, 2004 4:52 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

I am greatly opposed to the proposed rule that would exempt financial institutions with assets between $250 million and $1 billion from meeting current requirements of the Community Reinvestment Act (CRA). Surely, the current CRA regulations might be improved in several areas, but this change would dilute incentives for most banks to participate in community reinvestment. At a time when our nation needs more investment in our communities to rebuild and insure their strength, this is not a road that should be traveled. I see little input from the constituencies that the CRA was designed to serve and that is not what Congress intended when the act was passed.

Community reinvestment over the last 30 years is what has maintained the lifeblood of our major economic centers. The continued success of this rebirth and rejuvenation depends absolutely on consulting with and involving the communities affected - in terms of their needs and the best way to meet those needs. This requirement extends not only to banks - but also to the FDIC itself as it considers this radical change to the way in which CRA is being implemented.

There are many organizations in the Boston area that have been intimately involved in this process. One of these, the Massachusetts Housing Investment Corporation, has raised over $750 million in capital from member banks to finance affordable housing and community development. That money has ensured that critical community needs have not gone unmet. The member banks have earned a fair return on the investment and there have been no loan failures. The incentive for banks to continue this level of participation, or increase it, at a time when affordable housing is more needed than ever will be seriously undermined if the proposed rules go into effect.

Gayle Simmons
Consultant
142 Welles Avenue
Dorchester, MA 02124
617-834-3538