From: Patrick Sullivan [mailto:psullivan@nycedc.com]
Sent: Thursday, September 16, 2004 3:11 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50
I oppose the FDIC's proposal to raise the threshold for defining
"small" banks under the Community Reinvestment Act. This proposal would
leave too few banks subject to the CRA's requirements. I have worked in
the community development field for 10 years, in both the private sector
and in local government agencies, and in my experience the "stick" of
CRA review is a critical factor in motivating banks to participate in
community lending activities. Banks of all sizes have developed
innovative approaches to satisfying the CRA, and have become involved in
important ways in their local communities. This proposal would only
reverse much of that progress.
