FDIC Federal Register Citations

From: Stan Stradley [mailto:ucha@uci.net]
Sent: Thursday, September 02, 2004 6:28 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

DON'T CHANGE THE REQUIREMENTS AND LOWER THE STANDARDS!!!!!

As developers, managers and providers of affordable housing projects we are continuing to see less and less resources in providing this services to the citizens of this country. In the rural area's we are seeing local banks being gobbled up by the national chains where you once was a valued customer now are just an account number. There are really no new production programs for affordable housing other than tax credits. Local small banks have been willing to invest in small projects by buying the credits which in turn assist them in meeting their CRA requirements. With this change that will go away and medium and large institutions are not interested in the small deals as they refer to them. I urge you to reconsider your position on this and get back to what the CRA was intended for in the first place. In fact think about each branch of each institution being required to reinvest in the community they serve.

Stan Stradley
Executive Director
Umatilla County Housing Authority