FDIC Federal Register Citations

From: Robert Burns [mailto:burns@avalon.net]
Sent: Tuesday, August 31, 2004 5:32 PM
To: Regs
Subject: Proposed Regulation RIN 3064-AC50

Dear Sit or Madame,

We recommend against a change in the threshold to $ 1 Billion for certain compliance with CRA requirements. The proposed increase will deter raising equity from banks for affordable housing under the low income housing tax credit (LIHTC).

As a developer of affordable rental housing, we have found that CRA credit has been one of the prime motivations of financial institutions to invest in Section 42 LIHTC. Many banks with assets under $1 billion have invested in the past. Increasing the cap will reduce the amount of capital available to finance affordable housing.

We have recently developed an affordable assisted living project at Iowa City that has been able to save federal and state funds an average of $1,200 per month per tenant who remains out of a nursing home in our assisted living development. Eighteen of the fifty-four dwelling units are occupied by tenants who moved out of a nursing home. The other tenants are able to avoid premature institutionalization to a nursing home. FDIC's proposed rule change would discourage development of similar projects.

Please leave the qualification at its current category.

Robert P. Burns, Manager
Burns & Burns, L.C.
Architects, Developers, Property Managers
319 E. Washington St., Suite 1226
Iowa City, Iowa 52240