FDIC Federal Register Citations

From: Justin Maxson [mailto:jmaxson@maced.org]
Sent: Wednesday, September 15, 2004 4:33 PM
To: Comments
Cc: Sandy Rosenblith (E-mail)
Subject: RIN 3064-AC50

Dear Robert Feldman:

I am the President of a 30-year old rural community development organization in Appalachian Kentucky, the Mountain Association for Community Economic Development (www.maced.org). We are a small business developer looking to create economic opportunity in low-income communities. We often partner with banks in our service area to provided needed capital and technical assistance to nonbankable but viable small businesses.

The current proposed changes to the Community Reinvestment Act would mean a dramatic reduction in investment in already greatly underserved and economically distressed communities in our area.

If these proposed rule changes were to be adopted as is, the number of banks that would continue to have to test under the current CRA rules in Kentucky would drop 86%--from 23 banks to 3 banks! I believe that most banks and bankers have good intentions--but the reality is that the CRA framework as currently crafted creates a critical framework that addresses real market failure. Without this framework, best intentions or not--bank investment in rural communities will drop dramatically.

I strongly oppose the proposed rule changing the Community Reinvestment Act regulations. Please do not adopt this rule. Please feel free to contact me if we can provide any additional information to you or your staff.

Thanks for your time and consideration of these critical regulations.
Justin Maxson
President
MACED
433 Chestnut Street
Berea, Kentucky 40403
(859) 986-2373
(859) 986-1299 (fax)
www.maced.org