Federal Deposit
Insurance Corporation

From: Keith Kelley [mailto:keithkelley@fwced.org]
Sent: Wednesday, October 20, 2004 2:11 PM
To: Comments
Subject: Oppose Efforts to Weaken CRA RIN number 3064-AC50

Keith Kelley
302 Fresno St
Fresno, CA 93721

October 20, 2004

Federal Deposit Insurance Commission

Dear Federal Deposit Insurance Commission:

CRA has played an integral role in securing funding for community economic development in Fresno, California. Specifically, its impact on our low-income, minority neighborhood of west Fresno has been acute. West Fresno is a neighborhood that has been relined and has limited access to traditional financial institutions. Our neighborhood does, however, have three payday loan shops, all located on the same corner.

Without CRA, our organization's efforts to provide financial education and economic development services will be hindered.

Despite the successes of community development locally and nationally, the banks and thrift institutions that provide the loans, services, and investments to build new homes, businesses, and community facilities may no longer have the impetus to do so if the FDIC raises the comprehensive CRA exam threshold.

I agree with the National Congress for Community Economic Development that this proposed change would have a devastating effect on affordable housing and community development investment throughout the nation, particularly in rural areas. The proposed community development criterion is not a replacement for ensuring adequate services and investment reach low- and moderate-income individuals and communities. Successful development must be targeted to lower income individuals and/or communities, not rural areas generally.

Please rescind your proposal.

Sincerely,
Keith Kelley