Federal Deposit
Insurance Corporation

October 21, 2004
Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW Washington, D.C.20429
RE: RIN 3064-AC50

Dear Mr. Feldman:

I am writing on behave of the Fair Housing Center of the Greater Palm Beaches, Inc. (FHCGPB). The FHCGPB is a private non-profit agency dedicated to assisting in community development and improvements of low and moderate-income areas. The FHCGPB is vehemently opposed to lowering the Community Reinvestment Act (CRA) requirements for mid-sized banks. In addition, I serve as the Chairman of the Commission on Affordable Housing of Palm Beach County Florida and in that capacity I would like to go on record as opposing these changes. CRA is vital for increasing homeownership and economic development in lower-income communities. However, your proposed changes will halt the progress that has been made.

The current FDIC proposal would eliminate the investment and service requirements for all banks with under $1 billion in assets. This will result in significantly fewer loans and investments in affordable rental housing, health clinics, community centers, and economic development projects. The watered-down exam, the FDIC would allow mid-sized banks to choose which community development activities they will undertake. Right now, these same banks must make community development loans, investments, and services. Your proposed test allows banks to choose only one of the three activities. The result will be less community development activity.

The FDIC also proposes that community development activities in rural areas should benefit any group of individuals instead of only low and moderate-income individuals. This will allow banks to cherry-pick and focus on affluent residents of rural areas rather than the lower income consumers. Finally, the proposed changes would also eliminate publicly available data on the small business lending of mid-sized banks. Without data, community groups and citizens cannot hold banks accountable for lending to small businesses in their neighborhoods.

The FDIC’s changes directly oppose CRA’s mandate to require lenders to meet community needs. CRA is too important to be gutted. Please drop this proposal like the two other federal agencies that recognized the harm these changes would inflict on underserved communities.

Sincerely,
Vince L. Larkins
President/CEO
FAIR HOUSING CENTER OF THE GREATER PALM BEACHES 1300 W. LANTANA RD., SUITE 200 LANTANA FL. 33462