FDIC Federal Register Citations

From: Blair W. Sebastian [mailto:blair@ruralhousing.org]
Sent: Thursday, September 16, 2004 4:39 PM
To: Comments
Subject: RIN 3064-AC50, Community Reinvestment

The New York State Rural Housing Coalition is strongly opposed to your proposal to alter the definition of a small bank for purposes of the Community Reinvestment Act.

We believe that there are a significant number of institutions in New York State that would be impacted by this change and we believe that the action would be a serious set back for efforts to provide capital in the form of bank loans and investments to low and moderate income communities all across our state.

Our organization represents a network of over one hundred community based, not-for-profits serving rural areas in New York. These organizations find that many of the banks that are most active in rural areas are those with assets between $250 million and $1 billion. We find that these banks make significant investments in low and moderate-income communities and that they do so primarily because of the Community Reinvestment Act.

We are convinced that if these institutions are held to a lesser CRA standard, the result will be a serious and very damaging reduction in loans, investments and branches in rural areas. We urge you to withdraw this proposal.

Blair W. Sebastian
Executive Director
New York State Rural Housing Coalition
879 Madison Ave
Albany, NY 12208
(518) 458-8696