Federal Deposit
Insurance Corporation

From: Reggie.Johnson@huntington.com [mailto:Reggie.Johnson@huntington.com]
Sent: Wednesday, October 20, 2004 10:28 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

Dear FDIC,

Recently, you have proposed a rule change to offer streamlined testing under the Community Reinvestment Act (CRA) to institutions up to $1 billion in assets.  As a member of the Fiancial Industry, this proposed change, I feel, will have an enormous impact by significantly reducing the amount of private capital available for affordable housing and economic & community development by eliminating any regulatory incentive for 1300 banks to include low and moderate income persons in community development loans, services, and investments.

Without the participation of lenders and investors incentivized by CRA, sufficient capital may not be available for the highly successful Low-Income Housing Tax Credit program.  I do not support this rule change and urge you leave the threshold at its current level.

Reggie Johnson
Vice President
Huntington National Bank