From: Robert Pearson
Sent: Friday, August 20, 2004
6:06 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
To Whom it May Concern:
The Housing Authority of the City of Santa Barbara works extremely
close with the small banks in our community. They are a regular
purchaser of our tax exempt debt issuances that we do for our low
income rental housing development efforts. They have often commented
that their aggressive rate structure (i.e. low on our deals) gain
them good CRA reviews. And small banks are much more responsive
and aggressive in handling private placement of small tax exempt
note purchases---far less bureaucratic than the larger institutions.
We therefore know that the Community Reinvestment Act is a critical
component to our community’s affordable housing and community
development solutions; and strongly oppose any increase to the
threshold of what is considered to be small bank. The proposed
FDIC rule would exempt many of our community’s critical partners
from the effective and productive requirements currently in place.
We urge FDIC to withdraw its proposed rule.
Robert G. Pearson, Executive Director
Housing Authority of the City of Santa Barbara
808 Laguna St.
Santa Barbara, CA 93101
