FDIC Federal Register Citations

October 1, 2004

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

RE: RIN 3064-AC50

Dear Mr. Feldman:

The Calvert Social Investment Foundation lends to over 70 Community Development Financial Institutions in 38 states on behalf of over 2000 socially conscious investors. We are very concerned about a recent FDIC proposal that will significantly reduce the number) of Community Reinvestment Act (CRA) lenders. Specifically we refer to RIN 3064-AC50, which will raise the asset size threshold of small banks to $1 billion, and require banks with assets between $250 million and $1 billion to meet severely weekend CRA criteria.

Calvert Foundation knows first hand the tremendous impact that CRA has in poor, rural communities. Many regulated banks and credit unions increase their lending and investment activity in rural areas because of CRA. The FDIC proposal would eliminate comprehensive CRA reviews for 879 state-chartered banks with over $392 billion in assets, leaving fewer than 5% of FDIC regulated banks subject to the full CRA exam. Without this examination, these banks will no longer have to make efforts to provide affordable banking services or respond to the needs of these rural areas.

According to the US Department of the Treasury [Federal Register Volume 60, Number 86, Rules and Regulations, Page 22155-22223]

"The CRA is designed to encourage regulated financial institutions to help meet the credit needs of their entire communities, including low- and moderate-income neighborhoods.... The CRA has come to play an increasingly important role in improving access to credit in communities--both rural and urban--across the country. Under the impetus of the CRA, many banks and thrifts opened new branches, provided expanded services, and made substantial commitments to increase lending to all segments of society."

I believe a sincere and honest evaluation of the FDIC proposed changes could not find it in agreement with the spirit of the Act. For the benefit of less privileged Americans, I strongly urge you to withdraw the FDIC proposed change to the CRA regulations.

Very Truly Yours
Shari Berenbach
Executive Director
Calvert Foundation
Bethesda, MD