Federal Deposit
Insurance Corporation

From: Erik Kingston [mailto:ErikK@IHFA.ORG]
Sent: Wednesday, October 13, 2004 5:07 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

Greetings:
I am part of the Idaho Community Review Team and oversee the state of Idaho Five-Year Strategic Plan for Housing and Community Development; I routinely work with CRA officers and local communities who benefit from CRA investment and partnerships. I can testify that cooperative and leveraged investment of CRA dollars, combined with other resources, has made a significant difference in many areas of the state.

Investment in local workforce housing, for instance, creates a measurable wage subsidy for local employers, allowing them to compete in an evolving global market and enjoy a more stable labor force. Communities and families benefit from reduced transportation costs, better school attendance and lower financial stress. Workers who can afford stable housing will invest more in their local economy and are better able to weather eonomic shifts. They are much more likely to patronize local lenders than are housing cost-burdened households. This is just one area where CRA investment has proven invaluable.

Idaho is a predominantly rural state that is impacted by the loss of high-paying manufacturing jobs, geographically isolated communities and a large percentage of federal land ownership, which reduces the ability of many communities to maintain a self-reliant tax base.

I oppose the FDIC's proposal to allow banks with assets above $250 million to be examined as small banks under the Community Reinvestment Act. In the face of state and federal budget cutbacks, localized economic stress, underemployment and declining wages, rural communities depend on their neighbors in the lending community to invest in workforce housing, public facilities and other contributors to community resilience.

As I understand it, this policy would reduce lending, investments and services in low-income communities, and would represent a step backwards for local lenders and their community partners.

Sincerely,
Erik Kingston
Housing Resources Coordinator
Idaho Housing and Finance Association
P.O. Box 7899
Boise, ID 83707-1899