Federal Deposit
Insurance Corporation

From: Aaron Shiffman [mailto:AShiffman@FIFTHAVE.ORG]
Sent: Wednesday, October 20, 2004 4:12 PM
To: Comments
Subject: RIN number 3064-AC50

I am writing to strongly urge the FDIC to withdraw its proposed rule raising the asset threshold for “small banks” from $250 million to $1 billion and thus exempting these banks from the more stringent requirements of the Community Reinvestment Act (CRA). This change would have a devastating impact on investments in low and moderate income communities, particularly in rural areas where institutions with assets of $250 million to $1 billion hold the principal market share. At a time when affordable housing is vitally needed, and financing for community development proposals is critical, this is not the time to exempt banking institutions from compliance with the terms of the CRA. Please withdraw this proposed rule change.

Thank you for the opportunity to comment on this important matter.

Aaron Shiffman, Excutive Director
Brooklyn Workforce Innovations
141 Fifth Avenue
Brooklyn, NY