Miami Valley Fair Housing Center

From: Jim McCarthy [mailto:jim.mccarthy@mvfairhousing.com]
Sent: Wednesday, October 20, 2004 3:00 PM
To: Comments
Subject: RIN 3064-AC50, Community Reinvestment Deadline: October 20

Dear Mr. Feldman:

I am the President/CEO of the Miami Valley Fair Housing Center, Inc. in Dayton, Ohio, and the Fair Housing Center is strongly opposed to your proposal to significantly weaken the Community Reinvestment Act (CRA). You propose much easier CRA requirements for banks between $250 million to $1 billion in assets. This proposal will result in much fewer home and small business loans to low- and moderate-income borrowers and much fewer community development loans and investments in low- and moderate-income communities. In addition, you propose that all FDIC-supervised banks can earn CRA points by financing community development projects that benefit affluent residents in rural areas, instead of low- and moderate-income consumers and communities in rural America. This is directly contrary to CRA’s focus on meeting credit needs of low- and moderate-income communities. In sum, your proposal to change the CRA regulation will result in much fewer loans, investments, and branches in low- and moderate-income communities.

Please withdraw your harmful proposal.

Sincerely,

Jim McCarthy

President/CEO

Miami Valley Fair Housing Center, Inc.

21-23 East Babbitt Street

Dayton, OH