FDIC Federal Register Citations

From: Linsk, Michael [mailto:Michael.Linsk@FTIConsulting.com]
Sent: Friday, October 15, 2004 6:46 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

I oppose the FDIC's proposal to allow banks with assets above $250 million to be examined as small banks under the Community Reinvestment Act. This policy would reduce lending, investments and services to low-income families in general, with particular impact on smaller cities and towns where many of the smaller institutions are located. CRA responsibilities should not be relegated only to the largest institutions in the Nation. While it may be appropriate to reduce the administrative burden on some very small banks, the existing regulations which set the criteria at $250 million satisfy that desire without the risk of significantly reducing compliance in larger institutions that, in many cases, dominate the smaller markets in which they operate.

Michael Linsk
Managing Director
FTI Consulting
633 W. Fifth Street, 16th Floor
Los Angeles, CA 90071
213 452-6009 Phone
213 452-6099 Fax