FDIC Federal Register Citations

Patsy Mbughuni
324 N Wood Lane
Stevens Point, WI 54481

October 15, 2004

Federal Deposit Insurance Commission
,

Dear Federal Deposit Insurance Commission:

If we weaken the CRA RIN some of the successes of community development
locally and nationally will also be weakened. Banks that provided the
loans, services, and investments to build new homes, businesses, and
community facilities will no longer have the impetus to do so if the FDIC
raises the comprehensive CRA exam threshold.

The change would set back already tenuous increases in affordable housing
and community development investment throughout the nation, particularly
in rural areas.

The FDIC proposes that the community development loans and investments in
rural areas can benefit any group of individuals, not just low- and
moderate-income individuals. Currently, banks have to finance affordable
housing and economic development projects that target low- and
moderate-income borrowers and neighborhoods. Under the proposed changes,
nothing in the CRA regulations would prevent banks from earning CRA points
for financing developments with no community development benefit
whatsoever. Moreover, the one part exams would cover 99 percent of all
FDIC-supervised banks located in rural areas.

Why do we continue to target scarce resouces to those who already can
muster sufficient resources and leave those with no alternatives to wither
by the wayside? That is not an efficient use of scarce resouces.

Please rescind your proposal.

Sincerely,

Patsy Mbughuni