Federal Deposit
Insurance Corporation

From: John Fairbanks [mailto:JFairbanks@vhfa.org]
Sent: Wednesday, October 20, 2004 3:51 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
Importance: High

October 20, 2004

Jennifer J. Johnson
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, N.W.
Washington, D.C. 20551

Re: Proposed Rulemaking Regarding Community Reinvestment Act Regulations

Dear Ms. Johnson:

I am the Executive Director of Vermont Housing Finance Agency, and I am writing in regards to proposed changes being considered in the Community Reinvestment Act regulations. I appreciate the opportunity to make comments as this process moves forward.

I share the concern of many of my colleagues in Vermont’s housing industry that the proposed changes will make several a number of Vermont banks subject only to a streamlined review under the Act. As a small rural state we have predominately small community banks. Many of the members of Vermont’s banking industry have been a good partners in affordable housing development in our state, and they have lived up to their responsibilities, both as members of the community and as institutions subject to CRA, to help create more housing for low- and moderate-income Vermonters.

Nevertheless, we believe efforts to modernize CRA should not bend in the direction of loosening requirements for lending institutions. There should be a consistent continuing standard for community reinvestment, both small and large institutions.

Given Vermont’s serious housing shortage, our state cannot afford to lose resources when we are working so hard to try to development new affordable housing to meet the demand.

Thank you for your attention.

Sincerely,
Sarah E. Carpenter
Executive Director
Vermont Housing Finance Agency