FDIC Federal Register Citations

From: Bruce Levine [mailto:bruce@3ddevelopment.com]
Sent: Wednesday, September 22, 2004 4:49 PM
To: Comments
Subject: RIN number 3064-AC50

I am a developer of affordable rental housing and I am strongly opposed to the proposal to significantly weaken the Community Reinvestment Act (CRA) and having easier CRA requirements for banks between $250 million to $1 billion in assets. This proposal will result in much fewer home and small business loans to low- and moderate-income borrowers and much fewer community development loans and investments in low- and moderate-income communities. In addition, the proposal suggests that banks can earn CRA points by financing community development projects that benefit affluent residents in rural areas, instead of low- and moderate-income consumers and communities in rural America. This is directly contrary to CRA's focus on meeting credit needs of low- and moderate-income communities. In sum, all of the proposed CRA changes will result in much fewer loans, investments,and branches in low- and moderate-income communities. We hope this harmful proposal is withdrawn.

Bruce L. Levine
3d Development Group, LLC