Federal Deposit
Insurance Corporation

Umpqua Community Development Corporation

October 4, 2004

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW 20429

RE: RIN 3064-AC50

Dear Mr. Feldman:

I am the President of Umpqua Community Development Corporation, a small, rural, non-profit in southwestern Oregon. Since our founding in 1991, we have produced over 200 units of below market housing. We operate a successful micro-lending and business education program for small entrepreneurs with good business ideas. We operate a used building materials business which retails recycled items, performs contract deconstruction, and does maintenance and repair work on our housing units. We are nearing completion on a renovation and restoration of a 5-story, 100-year old downtown hotel, which had been abandoned and unused for 50 years. The hotel will provide.37 housing units and 5 commercial spaces. We have done a number of single-family rehabilitation projects, and soon we will begin a self-help single-family housing construction project of between 8 and 10 units. These are the highlights of our work, and there is more.

Our growth and our success as a non-profit has been the result of many factors, among them our ability to obtain various forms of assistance including cash grants, favorable lending rates, and real estate purchase price write-downs from area banks. The proposed changes to the Community Reinvestment Act regulations would significantly reduce our ability to obtain such assistance in the future. Because we are rural, many of the banks are smaller. Under the proposed CPA requirements, the exemption of smaller banks would eliminate a crucial source of support for our community development work. I urge you not to adopt the proposed regulations.

Sincerely

David Morrison