Federal Deposit
Insurance Corporation

From: Darys Estrella & Andy Wilson [mailto:darys.estrella@verizon.net]
Sent: Wednesday, October 20, 2004 2:42 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

In the late 1990s, I served as an assistant CRA Officer for Fuji Bank and Trust Company, a wholesale FDIC-insured bank. As the U.S. subsidiary of a foreign parent company, FBTC would have had no reason to consider CRA, were it not for the legal requirement. Yet, given this requirement, senior expatriot management gained much more authentic knowledge and experience regarding U.S. culture and society. This contributed to their understanding of all segments the market and served to help approach middle-market corporations and their customers with keener insight. Further, CRA served as the conduit for corporate citizenship activities, which raised the public profile of the institution and generated tremendous goodwill. Additionally, the CRA portfolio, though modest, was perfectly performing. Although the CRA dept was not a profit center, it also did not lose money, thus demonstrating the myth of poor performance within low- to moderate income communities. Finally, foreign banks serve a function in the U.S. market to help share credit risk and provide capital so there won't be a credit crunch; much in the same way, CRA provides capital where it is needed most, to seed burgening opportunities in the communities which need the credit and technical assistance to enter the formal banking, borrowing and lending community. In my observation, CRA has always been a win-win proposition. Please do not do anything to compromise the status of CRA. If anything, CRA should be extended to all securities firms conducting retail money market funds that have supplanted much of the traditional depository functions of FDIC institutions. In this way, the intention of CRA could be more evenly applied to all financial institutions that SHOULD be in these markets, anyway.

Therefore, I oppose the FDIC's proposal to allow banks with assets above $250 million to be examined as small banks under the Community Reinvestment Act. This policy would reduce lending, investments and services in low-income communities.

C. Andrew Wilson
210 Burns Street
Forest Hills, NY 11375
718.261.5136