Federal Deposit
Insurance Corporation

From: Ted Robb [mailto:trobbpa@rcn.com]
Sent: Wednesday, October 20, 2004 3:30 PM
To: Comments
Subject: Comments:Community Reinvestment12 CFR Part 345

I am writing as Chairman of a not for profit development company located in Philadelphia, and as a former Regional Director of HUD.

Your proposed changes to CRA will cripple efforts to provide much needed housing investment in low and moderate income areas. CRA has been one of the strongest links we have to find the financing for our projects.

Philadelphia used to be a haven for "red-lining" when I was director of HUD Region III. To exempt 43 banks in Pennsylvania from CRA regs will take us back to the days when many financial institutions believed that HUD should be the only vehicle for financing in low and moderate income areas. With cut backs in government assisted housing, and your proposed limitations to CRA, non profit devlopment companies such as mine will have zero resources to deliver our much needed product. Please reconsider.

Theodore Robb
Chairman, North County Conservancy