FDIC Federal Register Citations

From: Cindy Tidball [mailto:ctidball@blacklightning.net]
Sent: Friday, September 24, 2004 12:36 PM
To: Comments
Subject: RIN 3064-AC50 - proposed changes to CRA

It is difficult for an average citizen to comment on regulation changes. Often we get confused in the technicalities of language. Nevertheless, I did wade through the entire posting on the FDIC website regarding the above mentioned proposed rule change. I have one general comment.

Err on the side of protecting the financial lives and futures of lower income individuals and rural communities. It particularly concerns me, with respect to the comments made regarding the change in asset threshold to $1 billion "regardless of holding company affiliation" that the assertion that these larger holding companies, at least as yet, have not moved to legally structure themselves so that subsidiaries fit under the less stringent rules for smaller institutions is taken at face value, without any level of suspicion or caution. Evaluating the potential gain in exploiting such loopholes is a primary reason for large organizations to have large and competent legal staffs. It is a disservice to all of us that FDIC, having such a loophole brought to its attention, would not propose regulations to guard against abuses.

So, I remain suspicious, believing that the proposed changes amount mostly to a smokescreen for lending agencies to avoid their responsibilities to the overall health and welfare of the communities that they serve in their pursuit of greater profit for themselves. I urge you again to err on the side of those whose economic weakness already puts them at a substantial disadvantage.

David Tidball
1650 W. Hwy. 36, #165
Roseville, MN 55113