Federal Deposit
Insurance Corporation

October 14, 2004

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street NW
Washington DC 20429

RE: RIN 3064-AC50

Dear Mr. Feldman,

On behalf of Livable Places, I am writing to express our opposition to the proposed regulation to raise to $1 billion the small bank threshold used for Community Reinvestment Act compliance.

Livable Places is a nonprofit housing developer working to make the Los Angeles region more livable and environmentally sustainable. We create new entry-level homeownership opportunities in areas that are well served by public transportation, by building new affordable condominiums. We focus on centrally located sites that are in neighborhoods that haven’t seen much private sector investment over the last 30 or 40 years. . We have two developments totaling 160 units underway in Long Beach and Los Angeles.

In addition to using bank financing on our projects, Livable Places has received financial support in the form of grants from a number of banks. It is our understanding that both activities, loans and grants, count towards the banks’ CRA credits. Livable Places is only one of over 100 non-profit developers in Southern California whose mission is to build affordable housing in underinvested communities. We need the banks as partners. The CRA has given the banks the incentive they need to forge working partnerships with non-profit developers. Raising the threshold will mean that 58% of the banks in California now subject to full CRA three-part test would no longer be examined for compliance. Such a move would be devastating to the efforts of the non-profits working for community development.

We urge you to leave the CRA small bank threshold untouched and to reject the proposed changes. Thank you.

Sincerely,
Beth Steckler
Policy Director

cc: U.S. Senator Diane Feinstein
U.S. Senator Barbara Boxer
Rep. Lucille Roybal-Allard
Rep. Juanita Millender-McDonald