FDIC Federal Register Citations

Lawyers Alliance for New York

From: sgogliormella@lany.org [mailto:sgogliormella@lany.org]
Sent: Thursday, October 14, 2004 2:01 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

10/14/04 2:00:30 PM

Mr. Robert E. Feldman

Executive Secretary

Attention: Comments/Legal ESS

Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429
RE: RIN 3064-AC50

Dear Mr. Feldman:

I am writing to request that you to withdraw your proposed changes to
the Community Reinvestment Act (CRA) regulations. My organization,
Lawyers Alliance for New York, knows firsthand that the CRA has been
instrumental
in increasing homeownership, boosting economic development, and
expanding small businesses in the nation’s low- and moderate-income
communities.

The Community Reinvestment Act is a critical component of our community’s
affordable housing and community development solutions. For the past 35
years, Lawyers Alliance has represented nonprofits and community
development organizations that have built homes and helped to create jobs,
improving the lives of low- and moderate-income families in our community.
Without strong support from our financial institution partners, this work
would not have been possible.

The proposed FDIC rule would exempt many of our community’s key
financial partners from the effective and productive requirements
currently in place. We oppose any increase to the threshold of what
is considered to be a small bank,and we urge the FDIC withdraw its
proposed rule Sincerely,

Salvatore Gogliormella
Lawyers Alliance for New York
330 Seventh Avenue, 19th Floor
New York, NY 10001