| RURAL OPPORTUNITIES, INC. From: Jean Lipani [mailto:jlipani@ruralinc.org] Sent: Friday, September 17, 2004 9:55 AM
 To: Comments
 Subject: CRA
 Dear Mr. Feldman:  Rural Opportunities, Inc (ROI) a not for profit community service 
        organization is strongly opposed to your proposal to significantly 
        weaken the Community Reinvestment Act (CRA). You propose much easier CRA 
        requirements for banks between $500 million to $1 billion in assets. 
        This new ruling would negatively impact our current relationships with 
        Lenders that have assets of of less that $1 billion as well as with 
        establishing new relationships with future Lenders/Banks. The new ruling 
        provides an incentive to not lend in what is now considered CRA lending 
        areas or to low to moderate income families. Community Development 
        Corporations like ROI have worked diligently with Banks or Lenders to 
        ensure that they offer affordable products to everyone in the community 
        so that low to moderate income families can afford to live an work in 
        the communities of their choice. The new FDIC ruling would undo all the 
        good that has been done. Please withdraw your harmful proposal.
         "I am stunned that, after years of progress in opening up the 
        channels of credit and capital to lower income communities, this 
        Administration is now proposing to undo it. This is a slap in the face 
        of citizens all around the country who will, undoubtedly, see less 
        willingness on the part of the banks to reach out and provide mortgages 
        for first time homebuyers, small business loans and other services vital 
        to our communities. This proposal is especially harmful to our rural 
        areas. How can this Administration be serious about the economic health 
        of our communities when they so actively and directly try to disrupt the 
        flow of capital we so desperately need? It is precisely the Community 
        Reinvestment Act (CRA) that has led banks in Pennsylvania like Altoona 
        First Savings Bank to form a partnership with Rural Opportunities, Inc. 
        (ROI) and with USDA Rural Development to provide home mortgages to 
        first-time homebuyers, or Clearfield Bank and Trust to design new and 
        exciting first mortgage products, or Farmers and Merchants Trust of 
        Chambersburg to directly support ROI's counseling and education course 
        for first-time homebuyers". Lee Beaulac, VP Housing And Economic 
        Development, Rural Opportunities, Inc.  Sincerely,Jean Marie Lipani
 Director of Homeownership
 Rural Opportunities, Inc.400 East Avenue
 Rochester, NY 14607
 585-340-3359
 585-340-3326 (fax)
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