FDIC Federal Register Citations

September 8, 2004

Mr. Robert E. Feldman Executive Secretary
Federal Deposit Insurance Corporation
ATTN: Comments/Legal ESS
550 17th Street NW
Washington DC 20429

RE: RIN 3064-AC5: Small Bank Thresholds
Community Reinvestment Act
Affordable Housing Program dollars

cc: Senator Diane Feinstein (Fax#: 202-228-3954)
Senator Barbara Boxer (Fax#: 213-894-5042
NAAHL (Fax# 202-293-9852)
County Supervisor John Flynn (Fax# 805-487-7692)

Dear Sir:

As a person actively involved in grant funding for numerous nonprofits in Ventura County, CA, including those doing affordable housing, I wanted to bring to your attention a new regulation by the Office of Thrift Supervision (OFS) to raise the "small bank" threshold used for Community Reinvestment Act (CRA) examinations from $250 million to $1 billion. Since you regulate many more banks that OFS, I am appealing to you to not change this threshold.

If this change is adopted, the number of fully examined banks in California would drop to only 63 banks--a 58% loss! This will reduce access to capital for community development organizations seeking bank support for affordable housing, child care, nursing homes, job programs, redevelopment, graffiti removal and all sorts of other facilities.

Please reconsider this new regulation—it could badly hurt many people in California where the cost of living is extremely high and the dream of home ownership or even living in decent housing is very limited for many—including middle class workers and many hard working immigrants in our area. Thank you for reconsidering your support of this threshold change.

Sincerely,
Kathy Kramer, MPA
Consultant/Grant Writer
Kramer Consulting
659 Summer Tree Ct
Simi Valley, CA 93065 805-955-9364