Federal Deposit
Insurance Corporation

From: Paul Johnson [mailto:Paul_in_portland@msn.com]
Sent: Wednesday, October 13, 2004 4:49 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

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. There is at present a strong incentive for larger banks to invest in poorer areas of our communities because of facing potential penalties if they do not. Reducing or eliminating the audit would decrease that incentive. If there is to be any change in audit procedures, I would encourage more frequent audits of the larger banks; they are the primary source of this type of investment and strengthening their incentives to invest (or disincentives to not invest) would benefit our communities. I therefore strongly feel that the proposed change in policy would reduce lending, investments and services in low-income communities. Paul Johnson, Portland, OR