FDIC Federal Register Citations

The Charter Companies

From: Fred Bennett
Sent: Friday, August 27, 2004 10:52 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

I have been developing, building and managing affordable housing in the rural areas of Florida, Alabama, Georgia and Mississippi since 1969. The Community Reinvestment Act is essential to both rural and urban affordable housing development. Perhaps more than any single institutional change in the last 30 years, the CRA program has helped to bridge the "information and cultural gap" that heretofore has inhibited banks from lending in less affluent areas of the South.

We therefore strongly oppose any increase to the threshold of what is considered a "small bank." Small banks are the banks that presently lend in these communities, and in fact, are best positioned to make good loans in these areas. The proposed rule would exempt many of our community's critical partners from the effective and productive requirements currently in place at the point in time when most of them are now becoming truly comfortable with these requirements.

I pray that the FDIC will withdraw this proposed rule.

Fred Bennett
The Charter Companies