FDIC Federal Register Citations

From: Henson, Jennifer B. [mailto:jbhenson@ResidentialCapitalCorp.com]
Sent: Tuesday, September 21, 2004 12:46 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

I oppose the FDIC's proposal to increase the asset threshold for the CRA "streamlined" exam to $1 billion. The proposal will harm low- and moderate-income communities across the country by reducing private capital for affordable housing and community and economic development. While I support a meaningful "Community Development Test" for all institutions as a way of increasing private capital for these important activities, the proposed "Community Development Criterion" is a poor substitute. I'm just a small business, but my mission is to utilize private capital to fulfill housing dreams and to do this, I need to focus on the financial institutions that are in smaller communities. If you increase the asset threshold, these smaller institutions won't have a reason to "put back" into their communities CRA-ish initiatives. Deposits from low-to-moderate income customers are just as valuable to these smaller institutions as they are to much larger ones. Don't make the CRA initiatives less important in these smaller communities only serviced by these smaller institutions.

Jen Henson
Residential Capital Corp.
191 W. Nationwide Blvd., Suite 600
Columbus, OH 43215
614-246-2424
jbhenson@residentialcapitalcorp.com