FDIC Federal Register Citations

Spokane Housing Ventures

From: Helen Stevenson [mailto:helens@spokanehousingventures.org]
Sent: Friday, September 17, 2004 1:47 PM
To: Comments
Cc: Jayne Auld; terri@impactcapital.org
Subject: Community Reinvestment -- RIN 3064-AC50

As an affordable housing provider in Spokane, Washington it is imperative that this proposed ruling NOT be approved. With resources dwindling in our communities in this state it is vital that we maintain an expectation of investment from large banks that service the community. Without the current CRA requirements we could be left with little community development support from the private sector. As a developer working for a small non-profit we have been very successful in leveraging these private funds by blending private and public money to complete our projects. We currently have 450 units of affordable housing (affordable to under 60% of median income with 70% of our units actually housing 40% and below median income households). Because of our lower rents we usually blend between 4 and 7 funding sources. Without CRA the amount of private funds in these projects would most likely diminish because of no requirements at the Federal level to maintain community reinvestment. This would put a strain on the already limited public funds available and fewer units would be developed which would exacerbate the problem of housing the poor in this nation. Please do not change the CRA requirements as proposed in RIN 3064-AC50.

Thank you for your assistance on behalf of affordable housing in Spokane, Washington.

Helen Stevenson, Manager
Acquisitions & Development
Spokane Housing Ventures
715 E Sprague STE 102
Spokane, WA 99202