Federal Deposit
Insurance Corporation

From: John Lenahan [mailto:John.Lenahan@pcdc1.com]
Sent: Wednesday, October 20, 2004 10:48 AM
To: Comments
Subject: RIN Number 3064-AC50

October 20, 2004

Mr. Donald E. Powell
Chairman
Federal Deposit Insurance Corporation
550 17th Street NW
Washington, DC 20429

Re: RIN Number 3064-AC50

Dear Mr. Powell:

This is to comment on the recent proposals to raise the threshold for small community banks from $250 million to $1.0 billion for the streamlined CRA exam. Philadelphia Commercial Development Corporation (PCDC) has been serving the needs of low to moderate income individuals for the past thirty years within the City of Philadelphia via the provision of financial and technical assistance services to the small business community. The Community Reinvestment Act has been an important tool in securing the participation of small community banks in financing both the establishment of new businesses and the expansion of existing companies. These businesses have created thousands of new jobs for low to moderate income residents while also providing much needed products and services to low to moderate income neighborhoods within the City.

In light of the importance of the CRA to PCDC's mission, we strongly urge the FDIC not to adopt the proposed rule.

Sincerely
John D. Lenahan
Vice President
Lending Department