FDIC Federal Register Citations

September 20, 2004

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

Subject: RIN 3064-AC50

Dear Mr. Feldman:

CDC Small Business Finance is strongly opposed to your proposal to significantly weaken the Community Reinvestment Act (CRA) by easing CRA requirements for banks between $250 million and $1 billion in assets. This proposal will result in fewer small business loans to low- and moderate-income borrowers and to small businesses in low-and moderate-income areas. It will diminish the ability to generate the necessary investments that help meet unmet small business credit needs and fuel new innovative small business programs and services.

For more than 25 years, CDC Small Business Finance has worked in partnership with dozens of banks, large and small, to meet the needs of small businesses for capital and assistance in communities throughout Southern California. CRA has been a critical factor in promoting this partnership. CDC has developed small business programs understanding the constraints faced by small banks and providing them the opportunity to meet their CRA obligations easily and effectively.

This has resulted in hundreds of small businesses receiving capital to grow their business and create jobs and investment in targeted communities. It is not broken and it does not require fixing. Please withdraw this misguided proposal.

Sincerely,
Kurt Chilcott
President & CEO
CDC Small Business Finance
2448 Historic Decatur Road, Suite 200 San Diego, CA 92106
2448 Historic Decatur Road, Suite 200, San Diego, CA 92106 • 800/611.5170 • 619/291.3594 • Fax 619/291.6954 www.cdcloans.com