Federal Deposit
Insurance Corporation

From: barrypboothe@aol.com [mailto:barrypboothe@aol.com]
Sent: Thursday, October 28, 2004 7:34 PM
To: Comments
Subject: Save the Community Reinvestment Act

Dear FDIC,

Mr. Feldman:

I am a California citizen not in favor of your rule proposal that would ease Community Reinvestment Act (CRA) requirements for most of the banks in my area.

As of March 31, 2004, there were over 75 banks headquartered in California with assets between $250MM and $1 billion, and these bank have about $37 billion in assets. By changing the regulations, assuming each bank would otherwise make new investments of a mere .25% of its assets each year in CRA qualified "Investments", you are depriving California of $92.5MM of new CRA investments each year ($925MM over ten years).

I also object to your exempting banks owned by holding companies (where the holding companies have over $1 billion in assets, but may have no bank with over $1 billion in assets) from needing to pass a CRA "Investment" test. For any bank holding company with this sizable amount of assets, the holding company should be required to pass the CRA "Investment" test itself if it has no banks with over $1 billion of assets. Also, even if the bank holding company does own a bank or more than one bank with over $1 billion of assets, it should be required to pass the CRA "Investment Test" itself with respect to all the other banks it owns with less than $1 billion in assets if the total of such banks' assets is over $1 billion.

CRA is vital for increasing homeownership, providing affordable rental units to low income families, promoting minority business ownership, meeting the community development needs of struggling communities and supporting the capital requirements of nonprofits.

I am very concerned that the proposed Federal Deposit Insurance Corporation (FDIC) rule would be harmful to the community in which I live and hundreds of town, cities and rural areas in California and across the United States.

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 where I live. That will mean fewer jobs, fewer homes and fewer community services.

As I understand it, the Community Reinvestment Act was made law to require lenders to meet community needs. Your rule proposal flies directly in the face of this requirement. It would harm my community, the quality of my life and tens of thousands of Americans like me. I urge you in the strongest possible terms to drop this hurtful rule proposal.

Barry Boothe
San Francisco, CA