Federal Deposit
Insurance Corporation

From: ken@gstand.org [mailto:ken@gstand.org]
Sent: Friday, October 15, 2004 8:44 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429
RE: RIN 3064-AC50

Dear Mr. Feldman:

I am writing to request that you to withdraw your proposed changes to the Community Reinvestment Act (CRA) regulations. My organization, GA State Trade Assn of Nonprofit Developers, Inc., knows firsthand that the CRA has been instrumental in increasing homeownership, boosting economic development, and expanding small businesses in the nation’s low- and moderate-income communities.

I was an officer of Neighborhood Reinvestment Corporation when it was Congressionally authorized in the late 1970's when redlining was rampant in the US and few of the financial institutions recognized that their practices were discriminatory. When the CRA act came along it was a breath of fresh air that helped community-based nonprofits get the attention of the banking industry to enter into partnerships. Those partnerships have resulted in opening new markets for many small and community banks that would have otherwise continued the "good ole boy" system of making loans and extending services. In fact, the law encouraged major banks and the GSE's to also start setting targets of participation that have benefitted lower-income Americans. WE DO NOT WANT TO GO BACK TO THOSE DAYS!! Now, as director of a state association of nonprofit housing developers (that construct hundreds of below-market rate housing units each year) and housing groups that promote homeownership, its important that the threshold for banks remaining under the CRA regs be maintained at the $250,000,000 level. Why should we exempt over 90% of all the financial instutitions from continuing to make the progress we have seen for the past 25 plus years? Please listen to reason and reject the precedent of OTS and keep banks under the CRA regs.

Thank you,

Kenneth J. Knox, Executive Director
G-STAND

The proposed FDIC rule would exempt many of our community’s key financial partners from the effective and productive requirements currently in place. We oppose any increase to the threshold of what is considered to be a small bank,and we urge the FDIC withdraw its proposed rule Sincerely,

Kenneth Knox
GA State Trade Assn of Nonprofit Developers, Inc.
2825 Breckinridge Blvd., Suite 160
Duluth, GA 30096