Federal Deposit
Insurance Corporation

Syracuse United Neighbors (SUN)

From: SUN [mailto:sun@sunaction.org]
Sent: Wednesday, October 20, 2004 4:22 PM
To: Comments
Subject: Community Reinvestment 12 CFR Part 345

To Whom It May Concern:

On behalf of the Board of Directors and the members of Syracuse United Neighbors (SUN), I am writing to you to oppose the proposed rule to allow banks with assets under $1 billion to be examined as small banks under the Community Reinvestment Act.

SUN is a 27 year-old community organization that has done extensive work on bank investment in the low-income neighborhoods on Syracuse, NY's south and near-west sides. SUN has negotiated four CRA lending agreements with banks in the past several years. SUN is also part of a seven-city project with neighborhood groups affiliated with National People's Action. The groups have worked with Fannie Mae to develop a mortgage project targeted to low-income borrowers in an attempt to increase lending in our neighborhoods.

In our experience with the Community Reinvestment Act, we have found that banks with a poor record of lending in our neighborhoods often seek to remedy this with investments in affordable housing projects. Our neighborhoods also often lack bank branches and many services that other neighborhoods take for granted.

By limiting the number of banks that are examined on investments and services, banks will have little incentive to provide our neighborhoods, and many neighborhoods across the country, with investments and bank services.

Richard Puchalski
Executive Director
Syracuse United Neighbors (SUN)
1540 S. Salina St. Syracuse, N.Y.