Federal Deposit
Insurance Corporation

From: Francis McIlveen [mailto:francis.mcilveen@nclt.org]
Sent: Friday, October 15, 2004 1:39 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

The Northern California Land Trust, a non-profit developer of permanently affordable housing for over 30 years, opposes 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.

All of the units we sell to first time homebuyers under 80% of the Area Median Income must be purchased with a mortgage acquired by the home buyer. Banks are reluctant to take on these types of mortgages because they require a bit more work to underwrite and to navigate the more complicated programs. If the FDIC relaxes the CRA examination for larger banks, we will loss important lenders, and deserving families will not be able to buy these homes. It is that simple.

Francis McIlveen
Program Coordinator
Northern California Land Trust
3126 Shattuck Ave
Berkeley, CA 94705
francis.mcilveen@nclt.org
ph: 510-548-7878 x369
fax: 510-548-7562