Federal Deposit
Insurance Corporation

From: Erin Delaney [mailto:edelaney@familiesinschools.org]
Sent: Wednesday, October 20, 2004 8:15 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

Dear Legislator and/or FDIC Administrator,

The Boyle Heights Learning Collaborative (BHLC) Steering Committee does not want to see regulations put in place that will have the effect of curtailing the community reinvestment activities of the banking institutions in Los Angeles.

The BHLC Steering Committee opposes the FDIC’s proposal to allow banks with assets about $500 Million to be examined the way that small banks are today under the Community Reinvestment Act.

We support changing the definition of a small bank such that the asset limit is raised to $5 million from the $250 million it is today. This change will bring the numbers of banks and the number of assets more closely in line to what they were in 1995 when the bill was first passed into law.

We strongly oppose changing the definition of a small bank such that the holding company’s asset size will no longer matter. This change will mean that numerous banks who have individual assets under the limit set by the FDIC (presently $250 million) but are part of a holding company with assets over $250 million will not be considered large banks. This change will not be good for our community because of the less rigorous examination process.

We are opposed to the addition of a community development criterion, as is defined in the existing proposed rules, for small banks of any size. This criterion seems to weaken the banks commitment to community by allowing them to choose one or more of the areas they are to be working to support their communities. The present criterion for community development includes the following four areas: lending, investment, service, and community development. We believe that criteria should be applied to all banks.

The more thorough large bank examination and rating process done by FDIC has encouraged more aggressive community investment by large banks in our community. The large banking institutions in our county have been a major source of affordable rental housing. We want this investment and other examples of investment to continue.

Sincerely,
Maria A. Casillas

President of Families In Schools
On behalf of the BHLC Steering Committee
The Boyle Heights Learning Collaborative is an initiative of Families In Schools