Federal Deposit
Insurance Corporation

From: Thomas FitzGibbon [mailto:TFitzgib@mbfinancial.com]
Sent: Wednesday, October 13, 2004 9:26 PM
To: Comments
Cc: amooney@liscnet.org; John Taylor; mbush@woodstockinst.org
Subject: CRA Proposed Rules

As a banker, community development professional and civic leader I cannot see how the FDIC can support a change of this magnitude given the unknown outcome and the disregard for the opportunity to evaluate the performance of nearly 96% of all the banks that you regulate.

I know that the FDIC board and leadership have made announcements that they are trying (once again) to destroy the important role that the examiners and supervisors play in maintaining the integrity of the financial services industry. The pronouncements state that this will be achieved through reduction in examinations, staff and focus. I have (unfortunately) been around long enough to have experienced the 1980's and the fallout from the lack of supervision and regulation in that time period that almost collapsed the financial services industry in this country. It was not only the S&Ls, but many BANKS failed too because of political expediency and undue influence by politicians in the delivery of important and vital financial services to all of our country.

It was a direct result of that lack of oversight and poor business practices by bankers that led to the Congressional action to increase the impact of the 1977 Community Reinvestment Act to encourage and evaluate the delivery of credit into the entire market place, including low and moderate income communities and households. That was the least that the industry could/should do for the taxpayer support to bail out the FDIC fund and the FSLIC fund. It was only through special assessments paid by bankers that the FDIC fund did not require a bailout similar to that of the FSLIC.

This latest move(changes to CRA examination procedures)to basically eliminate the important role of the examiner in the process of evaluating the lending, service and investment performance shows callous disregard for the examiners individual intelligence and guidance to the leadership of the banking industry on how to direct resources to credit-starved and under served credit markets throughout our country.

Make no mistake about it. If the banking regulators start to go down the slippery slope of enforcing the same laws and regulations using different rules it will lead to further confusion by the consumer and civic mistrust of the very banking regulators that are supposed to be helping the banking industry build trust in the financial system.

Thomas P. FitzGibbon, Jr.
Executive Vice President
Chief Retail Banking Officer
MB Financial Bank
1200 North Ashland Avenue
Chicago, Illinois 60622
773-292-2052