From: Jeannee Mallow [mailto:missm@bedford.net]
Sent: Wednesday, September 15, 2004 4:06 PM
To: Comments
Subject: SPAM::RIN3064-AC50
FROM: JEANNEE MALLOW
TO: COMMENTS
SUBJECT: COMMUNITY REINVESTMENT – RIN 3064-AC50
WE ARE A PRIVATE NON-PROFIT COMMUNITY DEVELOPMENT CORPORATION SERVING
TWO RURAL COUNTIES IN PENNSYLVANIA. WE HAVE JUST BEGUN TO DEVELOP CLOSE
PARTNERSHIPS WITH A COUPLE OF SMALL LOCAL BANKS. EACH OF THESE BANKS
FALL BELOW THE PROPOSED THRESHHOLD UNDER THE NEW RULES. AS THE CRA
CREDITS ARE THE CATALYST FOR THESE PARTNERSHIPS IT WOULD BE EXTREMELY
DETRIMENTAL TO OUR RURAL COMMUNITIES SHOULD THE FDIC's PROPOSED CHANGE
OCCUR.
WE STRONGLY OPPOSE THIS PROPOSAL CHANGE TO RAISE THE THRESHOLD
DEFINITION OF SMALL BANKS, WHICH WOULD DECREASE OR MORE LIKELY TERMINATE
COMMUNITY REINVESTMENT BY SMALL LOCAL BANKS IN RURAL AREAS
