FDIC Federal Register Citations

From: nblack@fclf.org [mailto:nblack@fclf.org]
Sent: Thursday, October 14, 2004 1:24 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

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, Florida Community Loan Fund, 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 10 years, the Loan Fund has provided financing to assist non-profits in a variety of community development efforts to serve low-income families. As a statewide CDFI, our funding often substitutes for more difficult to find conventional sources of funding from banks. About 40% of our loan capital funding comes from our bank partners who are encouraged to do so through the Investment Test of CRA. 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,

Nelson Black
Florida Community Loan Fund
Jacksonville Field Office
Orange Park, FL 32073-6515