Federal Deposit
Insurance Corporation

From: staylor@justmoneyadvisors.com [mailto:staylor@justmoneyadvisors.com]
Sent: Tuesday, October 26, 2004 2:04 PM
To: Comments
Subject: Save the Community Reinvestment Act

Dear FDIC,

Mr. Feldman:

As a former economist for a multi-national corporate bank, and now, as a financial advisor in Kentucky, I ask that the FDIC re-examine the proposal to turn our backs on people for whom participation in the traditional capital markets is difficult.

The Community Reinvestment Act is vital to helping all our citizens participate in the economy. CRA requirements can be met with a minimum of effort on the part of banks, and is no more than is their obligation as corporate citizens. I've seen in my years at Bank of America, and now as an advisor who works with clients in placing money in community investments, that CRA- required loans can be a profitable line of business when done well, to say nothing of providing community public relations for the banks. This doesn't seem too onerous a burden, in my view.

As corporations are able to shrug off participating as citizens--with a profitable line of business and good public relations, no less--the public sector will be left to pick up more of the weight of the effects of people being more tightly shut out of traditional capital markets.

In the new watered-down process for mid-size banks, FDIC would allow these financial institutions to pick and choose which community development activities they will undertake. Right now, these banks must make community development loans, investments, and services. Your proposed test allows banks to choose only one of the three activities. The result will be less community development activity were I live. That will mean fewer jobs, fewer homes and fewer community services--and more public-sector obligations to fill in the gaps.

Please help support our communities by maintaining the current CRA standards.

Many thanks,
Susan Taylor, Ph.D.
Louisville, KY