FDIC Federal Register Citations

From: Rick Kiernan, NCDS [mailto:rkiernan@ncdsinc.net]
Sent: Thursday, September 16, 2004 1:43 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

I oppose the FDIC's proposal to allow banks with assets above $250 million to be examined as small banks under the Community Reinvestment Act.

As a representative of an organization that deals directly with community development organizations, I have seen first-hand their impressive accomplishments in low-income neighborhoods due in large part to the current CRA requirements. Changing this policy would reduce lending, investments and services in these inspiring low-income communities and potentially erase many of efforts made in recent years!

I oppose ANY increase in the threshold for small banks, but if it absolutely MUST be done, at least set the bar lower: $500 million. Even this lower target exempts more than 1,100 financial institutions (those between $250 million and $500 million in assets) from undergoing a full exam that covers lending, investments, and services.

Please reject this proposal!

Rick Kiernan
Senior Vice President
NCDS, Inc.
404 231-0730 x276 (V)
919 270-2137 (M)
919 882-9642 (F)
rkiernan@ncdsinc.net
www.ncdsinc.net