FDIC Federal Register Citations

From: Jonathan Chaffee [mailto:lebanon.housing.authority@valley.net]
Sent: Wednesday, October 20, 2004 1:29 PM
To: Comments
Subject: "RIN 3064-AC50"

Please do not raise the asset thresholds for CRA compliance, or make the service and lending activities optional. Locally, we have seen the exemplary contribution that a small bank can make if motivated. Mascoma Savings Bank, a mutually owned bank, has taken the lead in addressing the affordable housing crisis. By hosting breakfast seminars for business and community leaders it has helped launch an Affordable Housing Coalition, and many of its staff play key volunteer roles. Many small local banks have also invested in Low Income Housing Tax Credit projects to meet their CRA requirements. These banks would be excused from participating under the proposed rule changes.

For many local banks, CRA was at first one more onerous requirement. But over the years the intent of the regulation has permeated the culture and some banks are doing more now than they absolutely need to. Don't weaken the motivation now.

Jonathan Chaffee, Executive Director