FDIC Federal Register Citations

From: Erin Kelleher [mailto:Erin@ACEcommunities.org]
Sent: Thursday, September 16, 2004 6:17 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

Dear Regulators,

ACE advocates for and develops rental housing for very low and low income residents, including persons with developmental disabilities, in Clark County WA. There are no huge banks here and many small-local and mid-size regional banks. This proposed huge change to CRA reviews based on assets of the bank could be devastating to our community and to our most vulnerable residents.

Therefore, we oppose the FDIC's proposal to allow banks with assets above $250 million to be examined as small banks under the Community Reinvestment Act. This policy would reduce lending, investments and services in low-income communities across the states of Washington and Oregon. Perhaps the heavily populated Eastern states will feel no impact, but sparsely populated Wester states, allready starved for funding and jobs, will be completely divested of this much needed resource.

Banks have made boat loads of money over the last two years, with cheap money to them offered to local residents at hefty interest rates. This is certainly not the time to releave them of their community responsibilities under CRA.

Thank you for your careful and cautious evaluation of this proposal.

Go in Peace and remember the Poor,

Erin Kelleher
Executive Director
Affordable Community Environments
"We beleive in affordable communities for everyone."