FDIC Federal Register Citations

September 15, 2004

Federal Deposit Insurance Corporation
comments@fdic.gov

Re: RIN Number 3064-AC50

To Whom This Concerns:

The FDIC proposed CRA rule change to increase the asset threshold from $250 million to $1 billion for small banks thereby reducing regulation and relieving more than 2000 insured depository institutions of half of their current CRA responsibilities will do real and considerable harm to affordable housing and community and economic development, particularly in rural areas of this country.

The CRA has been a powerful impetus for community development loans, investments and services that benefit low- and moderate-income people. With government subsidies drying up, now is not the time to eliminate regulatory incentives for private capital to leverage scarce subsidy dollars.

Under the guise of updating cumbersome rules, banks should not be allowed to jettison critically needed community reinvestment responsibilities.

On behalf of the Board of Directors of the Venice Community Housing Corporation and the thousands of low-income people we serve, I urge that you abandon the proposed rule change and preserve the present asset threshold for large bank lender, investor and community service obligations.

Sincerely,

Steve Clare
Executive Director
Venice Community Housing Corporation
720 Rose Ave
Venice, CA 90291