Federal Deposit
Insurance Corporation

October 15, 2004

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, D.C. 20429

Re: RIN3064-AC50

Dear Mr. Feldman:

I am writing regarding proposed changes to the Community Reinvestment Act. As CEO of the Social Development Commission, a Community Action Agency that works with low-income residents of Milwaukee County, I am troubled about the proposal that would allow banks with assets more than $250-million to be examined as small banks under the Community Reinvestment Act (CRA).

I am concerned that this proposal could reduce lending, investments and services in low and moderate income communities. This weakening of the Community Reinvestment Act would negatively impact many of the clients that we work with to regain their financial independence.

I ask that you reconsider these changes and the harmful effect they will have on those who can least afford it. As currently proposed, the changes would slow or even halt progress that has been made in community reinvestment.

Sincerely yours,

Deborah Blanks
Chief Executive Officer