FDIC Federal Register Citations

Texas Mezzanine Fund

September 20, 2004


To Whom It May Concern:

The purpose of this letter is to voice the strong opposition of the Texas Mezzanine Fund, Inc. (TMF) regarding changes that the Federal Deposit Insurance Corporation (FDIC) is considering that would allow all banks with assets under one billion dollars to have a limited Community Reinvestment Act (CRA) exam that focuses on basic lending activities and not fully evaluate investments and services.

TMF is a statewide community development financial institution that provides financing for businesses located in distressed areas, women- or minority-owned businesses, and small businesses that create jobs for low-and-moderate income people. TMF also provides financing to for-profit and nonprofit developers of single-and multifamily affordable housing for families, senior citizens and households with special needs. The Fund was capitalized by a consortium of financial institutions in Texas.

Earlier this year, the Federal Reserve Bank of Dallas and TMF co-sponsored Momentum Texas – The Texas Community Development Finance Summit. The summit was held in cooperation with FannieMae, the FDIC, the Federal Home Loan Bank, the Office of Comptroller of the Currency, and the Office of Thrift Supervision. By undertaking this summit, TMF has a deep understanding of the community development finance needs throughout the State of Texas. It would be tragic to adopt rules that undercut the ability to finance beneficial community development initiatives in Texas.

If you have questions regarding our opposition, please contact me at 214.943.5900, extension 101.

Sincerely,

Jim Reid
President