FDIC Federal Register Citations

September 20, 2004

Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ISS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429-9990

REGARDING: RIN 3064-AC50

Gentlemen,

I strongly oppose the proposed rule changing the Community Reinvestment Act regulations. Such changes will undermine the efforts of rural communities to develop "real" economic opportunity and growth. Please, do not adopt the proposed rule.

I have been working for small Native American rural communities for many years in education, community and economic development. The Community Reinvestment Act opportunities through our small local banks have been the only way these small rural communities have been able to secure leverage funds for economic development ventures. An example: the Stillaguamish Tribe of the state of Washington now has a thriving native riparian restoration nursery serving the entire northwest thanks to the current rules under the CRA - we were able to borrow against privately owned tribal assets/lands with which to leverage and provide matching funds for EDA, USDA, local State and private foundation funding for the project. This risk of tribal assets made the very difference in the successful financing of this project. In fact, EDA showcases this project on its national website as an exemplary economic development program. This is just one example where the current law nurtures true economic development in rural America. Please do not take this valuable tool from us.

Thank you for your considered attention to our request not to adopt the proposed rule vis-a-vis RIN 3064-AC50.

Sincerely yours

Jay Moolemjzer
Community Planning and Development Department
Ramah Navajo Chapter
Ramah, NM