Federal Deposit
Insurance Corporation

From: Dora Leong Gallo [mailto:dgallo@acof.org]
Sent: Wednesday, October 20, 2004 5:06 PM
To: Comments
Subject: SPAM::RIN 3064-AC50October 20, 2004

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

RE: RIN 3064-AC50

Dear Mr. Feldman:

I am writing to urge the Federal Deposit Insurance Corporation (FDIC) not to adopt the proposed regulations that would raise the “small bank” threshold used for Community Reinvestment Act (CRA) examinations from the current $250 million to $1 billion, as well as other proposed changes that would weaken the effectiveness of the CRA.

In California, there are over 140 state-chartered banks located within urban areas with assets up to $1 billion. If the proposed changes are adopted, 122 of these banks (or 84%) would no longer have to meet the three-part test of the CRA (lending, investment, and service).

The Community Reinvestment Act is a critical component of my organization’s (A Community of Friends) affordable housing program. In the past 16 years, we have developed 26 apartment buildings totaling over 1,000 units for homeless individuals and families with special needs. We are currently in construction on another three projects and have five more projects in the pipeline. Without strong support from our financial institution partners, this work would not have been possible.

The proposed FDIC rule would exempt many of our community’s key financial partners from the effective and productive requirements currently in place. We oppose any increase to the threshold of what is considered to be a small bank, and we urge the FDIC to withdraw its proposed rule.

Sincerely,

Dora Leong Gallo
Chief Executive Officer
A Community of Friends
3345 Wilshire Boulevard, Suite 1000
Los Angeles, CA 90010
(213) 480-0809 ext. 230