Federal Deposit
Insurance Corporation

From: Fleischaker, Debbie [mailto:Debbie.Fleischaker@edd.state.nm.us]
Sent: Thursday, October 14, 2004 12:29 PM
To: Comments
Cc: Jeffrey Dekro (jdekro@shefafund.org)
Subject: Community Reinvestment -- RIN 3064-AC50

To Whom it May Concern:

As the Deputy Secretary of Economic Development of a small and very poor state I realized the importance of holding our banking community responsible for community commitments. Our banks' lending practices are extremely conservative hence my job is very intensive.

Just last week we met with local bankers some of whom represented larger banks with New Mexico locations. Indeed it became apparent that their commitment to our poor communities and potential relocations, expansions and retention of businesses is prompted by the CRA. Unfortunately carrots and sticks are still prime motivators. They don't use internal values to create value.

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. This policy would reduce lending, investments and services in low-income communities.

Debbie Fleischaker

DebbieFleischaker MPA PhD
Deputy Secretary of Economic Development
Joseph M. Montoya Bldg
1100 St. Francis Drive
Santa Fe, NM 87505-4147