FDIC Federal Register Citations

From: Jan Parke [mailto:janparke@turn.nu]
Sent: Tuesday, October 05, 2004 12:35 PM
To: Comments
Subject: RIN Number3064-AC50

May we add our voice to those who oppose any increase to the threshold of what is considered to be a small bank. Utah is a breeding ground for Independent Loan Banks as well as many Thrift and Savings quasi banks and many small home town units that currently meet the definition and have been involved in making CRA donations of significance to their communities BECAUSE of the CRA structure in place.

Changes that will dilute their responsibility to the communities in which they are chartered will negataively impact agencies such as ours that provide affordable housing to low income persons with disabilities and similarly challenged citizens.

Under the current CRA rules, we make make application and expect to receive assistance in improving the number and quality of housing and rental stock in each of our communities from CRA funds. Funds that cannot be borrowed by nonprofits on current LTV or cash flow basis.

We urge the FDIC to withdraw its proposed rule. The CRA funds coupled with HUD HOME, CDBG and Section VIII vouchers are the means for most of the disabled population to own or rent affordable, attractive and safe places to live.