Federal Deposit
Insurance Corporation

October 13, 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 urge you to withdraw the proposal of the Federal Deposit Insurance Corporation to quadruple (to $1 billion) the minimum asset size for applying the full Community Reinvestment Act (CRA) exam to state chartered non-member banks. This proposed change in the CRA regulations would have a devastating impact on lending, housing, and access to financial services in urban and rural communities across America.

CRA has been instrumental in increasing homeownership, boosting economic development, and expanding small businesses in the nation's minority, immigrant, and low- and moderate-income communities. The FDIC proposal would dramatically diminish banks' obligation to reinvest in their communities. It revises the CRA rules to make the less rigorous CRA exam applicable to an additional 900 banks with assets totaling $401 billion. Adoption of the FDIC measure is likely to mean the loss of hundreds of millions of dollars in loans, investments, and services for local communities and would disproportionately impact rural areas and small cities where the market presence of these mid-sized banks is often great.

The FDIC rule, as proposed, would greatly weaken or eliminate extremely important standards necessary to ensure that CRA is effective. The proposed change would weaken the lending test and also eliminate the investment and service parts of the CRA exam for FDIC supervised banks that have assets between $250 million and $1 billion.

The FDIC's plan to add a weak and trivial community development criterion in lieu of the investment and service tests applicable today (that collectively count for 50 percent of a bank's CRA grade) is a wholly inadequate substitute for the present exam standards. The new factor permits these banks to satisfy the community development criterion by choosing whether to provide community development loans, investments or services instead of assessing their performances for all three categories, as is currently required. This change is likely to result in a significant drop-off of lending, investments and services for affordable housing development, Low Income Housing Tax Credits, community service facilities, such as clinics, and economic development projects.

Another harmful element in the proposal is the dramatic weakening of the lending test for midsize banks which could decrease access to credit for many Americans. Under the proposal banks with assets between $250 million and $1 billion will no longer be subject to the rigorous examination of their mortgage, small business, small farm, and consumer lending. Further, these banks would no longer be required to collect and report essential lending information such as small business lending by census tracts or revenue size of the small business borrowers. Without data on lending to small businesses and small farms, it is impossible for the public to know how well these midsize banks help to meet the credit needs of their local communities.

In addition, this proposal would broaden the definition of community development in rural areas so that all FDIC-supervised banks could receive CRA "credit" even if these activities are not particularly directed at serving the needs of low- and moderate-income households, as is presently required. The proposal would be particularly harmful to rural counties, which already have fewer banks. Rural counties have 4.3 banks compared to 10.9 banks in urban counties, on average.

I urge you to withdraw this proposal.

Sincerely,
Kristine Stroad Moore