FDIC Federal Register Citations

October 14, 2004

Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street NW Washington, DC 20429

RE: 12 CFR part 345 CRA (69FR51611)

Dear Mr. Feldman:

I 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 change would reduce lending, investments and services in low-moderate income communities in inner-city neighborhoods like Harlem, New York City.

The full CRA review of larger banks like Citibank forced this financial institution to make construction loans and other investments in Harlem that encouraged local entrepreneurs and developers to produce affordable housing for very low, low and moderate income families and existing residents.

With the full weight of the Community Reinvestment Act, Citibank provided our company with a $12.5 million construction loan which helped us perform gut rehabilitation on five city-owned multifamily buildings to produce 97 affordable housing apartment units.

It is absolutely necessary that the FDIC and other banking regulatory agencies require larger banks to comply with the full CRA review to maintain and expand the role that larger banks play in the local economy, commerce and affordable housing areas of low-moderate income inner city urban communities. I urge you and other members of the FDIC to preserve the Community Reinvestment Act to prevent the roll back of lending, investments and services.

I invite you and FDIC members to join us on December 7, 2004 for a ribbon cutting ceremony in Harlem to dedicate the newly rehabilitated affordable housing and see first hand the accomplishments of CRA working in our community.

Sincerely
Coy M. LaSister
President & CEO