FDIC Federal Register Citations

Robert E. Feldman
Executive Secretary
Attn: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

RE: RIN 3064-AC50

Dear Mr. Feldman

Murex Investments is an SBA-regulated and approved venture capital fund that invests in Pennsylvania, New Jersey and Delaware under the New Markets Venture Capital program. Since 2000, Murex has provided more than 4,314,089 in total financing to 17 companies in the Greater Philadelphia region. Murex has brought needed economic activity and more than 251 high-quality; living-wage jobs to the most economically distressed communities of the area.

Much of our capital has been raised from banks as a result of CRA regulations. The proposed re-definition of "small bank" would hinder our ability to raise capital for the neediest parts of the tri-state area. Murex Investments therefore strongly opposes your proposal to raise the definition of "small institution" from its current $250 million in assets to the proposed $1 billion. We are also concerned that your proposal to modify the definition of "community development" to include any investing or service activities in rural areas runs counter to the goals of the Act.

Nor can we support your proposed change in the definition of "community development," which would append "rural areas" to the current definition of community development. We strongly believe that the current definition, which clearly and rightly emphasizes low-or-moderate income individuals and geographies, is the proper definition. Murex Investments encourages the FDIC and all of the federal regulators to continue their focus on improving access to credit and capital in rural parts of the US. However, redefining CRA is not the proper way to address the financial challenges facing rural people and communities.

We strongly encourage the FDIC to recognize that the proposed changes, which appear inconsequential at the national scale, would have substantial adverse consequences in thousands of communities and disproportionately affect rural communities. Additionally, the proposed change in "community development," which is intended to offset these negative effects, would result in a more confusing regulatory environment and run the risk of worsening access to credit and capital for low-and-moderate income persons and low-and-moderate income communities in both rural and urban areas.

Thank you very much for the opportunity to comment on your proposed changes to the FDIC's CRA regulations. If you have any questions about these comments please do not hesitate to contact Jacob Gray, our staff government-affairs liaison.

Sincerely,
Tami Fratis
Murex Investments