Federal Deposit
Insurance Corporation

From: KENMIA22@aol.com [mailto:KENMIA22@aol.com]
Sent: Sunday, October 17, 2004 10:25 AM
To: Comments
Subject: Comment from Ken Thomas (CRAHandbook.com) on CRA REFORM -- RIN 3064-AC50

Please accept the attached Public Policy Brief titled "Optimal CRA Reform: Balancing Government Regulation and Market Forces" from the website www.levy.org with the URL address as follows:
www.levy.org/2/bin/datastore/pubs/files/ppb/ppb68.pdf
as my comment on this proposal.

Please note in particular two items:

1. On p. 23, I recommend use of the original $500 mil. definition for a small bank rather than the proposed $1 bil. one as the optimal one for public policy from an independent perspective and

2. The FDIC and other regulators should read the section on p. 19 titled "Community Groups Potentially Conflicted in Defending Investment and Service Tests" and consider this information in its evaluation of the various comments submitted on this proposal.

Thank you,

Ken Thomas

voice 305-663-0100
fax 305-665-2203