Federal Deposit
Insurance Corporation

From: Rob Bryant [mailto:rjbryant@valley.net]
Sent: Wednesday, October 20, 2004 3:30 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

Twin Pines Housing Trust strongly opposes the proposed FDIC rule that would exempt small banks from the currently very effective CRA requirements in place. We are a community-based not-for profit affordable housing developer serving largely rural counties in the Upper Valley area of New Hampshire and Vermont. Our mission is to provide and maintain perpetually affordable housing in an area of very high housing and land costs and an extraordinarily low vacancy rate as a result of affordable housing units not being able to keep up with demand. There are many low-to-moderate income residents forced to commute a significant distance to find often substandard housing that they can afford. Many residents are forced to pay a much larger percentage of their income for barely adequate housing. The Community Reinvestment Act is a very important part of local banking institutional efforts in supporting the development of affordable housing and community re-investment. We urge every possible opposition to any increase in the threshold applied to small banks in order that they may continue to be critical partners in developing more affordable housing.

On behalf of our fifteen member Board of Trustees, our more than 360 current residents and the many more we are trying to serve, we appreciate your serious consideration of our position. Thank you.

Rob Bryant, Executive Director
Twin Pines Housing Trust
106 Railroad Row
White River Junction, VT 05001
Phone: (802) 291-7000