Federal Deposit
Insurance Corporation

From: Tgogie611@aol.com [mailto:Tgogie611@aol.com]
Sent: Saturday, October 16, 2004 9:22 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

Re: changes to 12 CFR Part 345

I write to oppose proposed changes to Community Reinvestment Act rules which would exempt banks under $1 billion but over $250 million in assets, buy so-called "streamlining" their CRA review.

The approximately 2000 banks in this range account for trillions of dollars in assets. Their full participation in CRA -- including detailed scrutiny by CRA -- has resulted in many millions of dollars' worth of investments in low/moderate-income housing which will be threatened if these new rules take effect.

Similarly, exempting bank holding companies from these rules will have a similar deleterious impact on low-income individuals and communities, and on communities of color. History has shown that, since 1975, CRA has been THE force which has largely eliminated "red-lining" of such people and communities. It must be fully enforced, without needless rules changes, for all banks with assets over $250 million.
Thomas Gogan
Park Slope Action for the Environment