Federal Deposit
Insurance Corporation

County Corporation

From: DEB WENIG [mailto:DWENIG@COUNTYCORP.com]
Sent: Wednesday, October 20, 2004 4:18 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

COUNTY CORP, Montgomery County’s non-profit affordable housing and economic development organization, opposes the FDIC proposed changes to the Community Reinvestment Act (CRA) requirements for mid-sized banks. It is vital to the communities we serve that banks continue to offer community development loans, services, and investments to low- to moderate-income individuals and communities. We believe that the proposed changes will reduce the amount of capital available for this purpose. The streamlined exam will, unfortunately, only serve to streamline capital for programs such as the Low Income Housing Tax Credit program which our agency has utilized to provide much needed affordable housing.

Please withdraw your proposal as it will result in fewer loans, investments and branches in low-and moderate-income communities.

Marlene J. Flagel
President
COUNTY CORP
40 West 4th Street
Suite 1600
Dayton, OH