Federal Deposit
Insurance Corporation

From: Jeremey Newberg [mailto:jn@capitalaccessinc.com]
Sent: Wednesday, October 20, 2004 1:26 PM
To: Comments
Cc: Rick Sauer
Subject: Please Stregthen Do Not Weaken CRA Community Reinvestment -- RIN 3064-AC50

Hello:

The proposal for weakening of CRA is most ominous and counter-productive.

Every private financial institution that uses the benefit of federal insurance of deposits has an obligation to comply fully and affirmatively with CRA - big, medium or small financial institutions.

The case that compliance with CRA is overly cumbersome and/or expensive is unfounded. Small banks can easily participate as investors in community and statewide Community development financial institution loan funds. They can originate home mortgages by participating in State Mortgage Revenue Bond programs. They can simply reach out to local governments that administer HOME and CDBG programs and network to search lending opportunities, many times with LTVs below 50%.

This is a bad precedent. Our cities are getting older. Our housing stock is older and riddled with lead-based paint. Our population is getting old. We need more investment in our communities so that we can re-position them for another 100 years of growth.

As a former employee of the FRB of San Francisco and a former Vice President for CoreStates Bank, please discard this ill-conceived proposal to weaken CRA.

Jeremey Newberg
President
Capital Access, Inc.
237 Tasker Street
Philadelphia, PA 19148