FDIC Federal Register Citations

From: Ed Talbot [mailto:ed-t@ci.arvada.co.us]
Sent: Friday, October 15, 2004 5:47 PM
To: Comments
Subject: RIN 3064-AC50

Subject: RIN 3064-AC50

Dear Sir or Madam:

The CRA has been an important tool to encourage and frame the responsibility of the lending community to participate in efforts within communities to serve all the needs of those communities. This intention would be significantly reduced by proposed amendments and these changes would significantly impact smaller rural areas where the participation of the lending community is of the utmost importance.

Having worked for local jurisdictions in the housing and community development field since 1975, I have seen how a strong CRA is well used to serve community needs. The changes proposed should not be included: Do not raise the asset threshold from $250 million to $1 billion of financial institutions that have to undergo the omprehensive CRA examination.

Do not add language allowing banks to balance their community lending investing and service activities based on opportunities in the market and the banks own strategic strengths.

These modifications not only decrease the number of banks that would face the comprehensive compliance exams, but would also affect the examination itself by removing the requirements on the investment and service elements and instead making them options under the lending test. These would not be beneficial for the CRA.

Thank you for your attention.

Sincerely,
Edward G. Talbot
Arvada, Co. 80004