FDIC Federal Register Citations

From: Patrick Sullivan [mailto:psullivan@nycedc.com]
Sent: Thursday, September 16, 2004 3:11 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

I oppose the FDIC's proposal to raise the threshold for defining "small" banks under the Community Reinvestment Act. This proposal would leave too few banks subject to the CRA's requirements. I have worked in the community development field for 10 years, in both the private sector and in local government agencies, and in my experience the "stick" of CRA review is a critical factor in motivating banks to participate in community lending activities. Banks of all sizes have developed innovative approaches to satisfying the CRA, and have become involved in important ways in their local communities. This proposal would only reverse much of that progress.

Patrick Sullivan
New York City