FDIC Federal Register Citations

Capital Access, Inc.

From: Jeremey Newberg
Sent: Thursday, August 26, 2004 11:36 AM
To: Comments
Subject: Proposed Changes to CRA

Dear Sir / Madame:

As a former member of the Community Investment staff of the Federal Reserve Bank of San Francisco, a former lender with CoreStates Bank, NA, of Pennsylvania and now as a planner and developer in housing and community development, I respectfully request the FDIC to not increase the threshold for CRA compliance for small banks to $1 billion in assets up from $250 million.

Since the passage of FIRREA, the growth of Community Development Financial Institutions, community based-loan funds, local housing trust funds, bank CDCs and tax credit investment vehicles has made community investment for small banks much easier. So I do not see how this perception of an "unwarranted burden" holds true.

CRA was established because banks large, medium and small benefit from a federal government guarantee of deposits. So long as that is in force, all banks should be held accountable to maintain vigorous community investment programs.

Thank you.

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