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FDIC Federal Register Citations

PORTLAND COMMUNITY REINVESTMENT INITIATIVES INC.

August 23, 2004

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

RE: RIN 3064-AC50

Dear Mr. Feldman:

As a member of the National Congress of Community and Economic Development and the executive director of a community development corporation engaged in the development and management of affordable housing, I implore you to withdraw the proposed changes to the Community Reinvestment Act (CRA) regulations. CRA has been instrumental in increasing homeownership, boosting economic development, and expanding small businesses in the nation's minority, immigrant, and low- and moderate-income communities. Your proposed changes are contrary to the CRA statute and Congress' intent because they will slow down, if not halt, the progress made in community reinvestment.

Many of the most significant changes in urban and rural neighborhoods over the last 15 years are a result of the CRA related activities. The proposed changes curtail future development in those very communities that are beginning to show recovery in investment. It will also thwart the Administration's goals of improving the economy and creating 5.5 million new minority homeowners, by the end of the decade. We cannot promote community revitalization and wealth building when legislation that lead to such improvements in the past dramatically diminish banks' obligation to reinvest in the communities where they get their customers?

Eliminating the need to monitor required investment and service parts of the CRA exam for state-charted banks with assets between $250 million and $1 billion 'is not the answer to the problem. Please keep in place the community development criterion that requires banks to offer community development loans, investments or services in communities which they are located.

There is a national commitment to change this decision. I suspect you have received large volumes of letter in protest; letters that enumerate the problem this change will cause. Therefore, I won't go into all the details. I will simply ask for your advanced consideration of a proposed drastic measure.

Please feel free to contact me if you have any questions regarding this letter.

Sincerely,

Maxine Fitzpatrick
Executive Director
Portland Community Reinvestment Initiatives Inc.
4829 N. E. Marting Luther King Jr., Blvd.
Portland, OR 97211

CC: National Congress for Community and Economic Development
National Community Reinvestment Coalition
President George W. Bush
Senators John Kerry and John Edwards

Last Updated 09/03/2004 regs@fdic.gov

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