FDIC Federal Register Citations

From: Ryan Cassell [mailto:rcassell@naht.org]
Sent: Thursday, September 16, 2004 8:53 AM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

To whom it may concern:

I urge you to not increase the threshold for enforcing the CRA on financial institutions to $1 Billion. Doing so will remove significant numbers of smaller banking institutions from needing to meet the CRA. The result will be that a lower amount of funding will be available to industries that try to promote affordable housing. Fewer institutions will be interested in investing in low-income housing tax credits or making permanent debt loans, often too small for major banking institutions to consider, in disinvested community housing projects.

Further, disinvested communities, many of whom are only served by the smaller financial institutions that will be exempted under the new CRA proposal, will have their communities wealth drained away.

Neither of these results are acceptable.

Thank you for this opportunity to comment.

Ryan C Cassell
National Affordable Housing Trust
2335 North Bank Drive
Columbus, OH 43220
PH: (614) 451-9929, 116
FAX: (614) 451-3370
A E-MAIL: rcassell@naht.org

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