Federal Deposit
Insurance Corporation

Habitat for Humanity of Washington State

October 19, 2004

Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429

RE: RIN #3064-AC50

Habitat for Humanity of Washington State represents the 37 local Habitat for Humanity affiliates and chapters across Washington State. To date, we have built over 716 homes in partnership with first-time homebuyers who are between 25-50% of area median incomes. We will build another 100 homes this year. Our local Habitat affiliates and chapters are closely connected to their individual communities and benefit from effective Community Reinvestment Act programs and services provided by their local banks, including many “small banks.”

We ask that the FDIC complete a cost/benefit analysis of the proposed changes before the proposed rule is adopted as a final rule.

We urge the FDIC to continue to require assessment of performance for all three community development categories: lending, investments, and services

We request that the definition of community development in rural areas be clarified to ensure that the banks will receive CRA “credit” only for activities directed at serving the needs of low-and moderate-income households.

We appreciate the FDIC's efforts to ease administrative burdens on community banks, but have grave concerns about the proposal at hand.

Thank you for the opportunity to comment on this important regulatory matter.

Sincerely,

Habitat for Humanity of Washington State