FDIC Federal Register Citations

City of Dublin, CA

October 15, 2004

Robert Feldman
Executive Secretary
Attention: Comments/Legal ISS
Federal Deposit Insurance Corporation
550 17th St. NW
Washington, DC 20429-9990

RE: RIN 3604-AC50

Dear Mr. Feldman:

I am opposed to the watering down of the Community Reinvestment Act requirements for mid-sized banks. CRA is vital for increasing home ownership and economic development in lower-income communities. Your proposed changes will halt the progress that has already been made.

Your proposal would eliminate the investment and service requirements for all banks under one billion dollars in assets. This will result in significantly fewer loans and investments in affordable rental housing, health clinics, community centers and economic development projects.

The proposed exam would allow mid-sized banks to choose which community development activities they will undertake. Currently these banks must make community development loans, investments and services. Your proposed test allows banks to choose only one of the three activities. The obvious result will be less community development activity.

Your, proposal to eliminate publicly available data on the small business lending of mid-size banks does not seem appropriate. Without this data, community groups and citizens cannot hold banks accountable for lending to small businesses in their neighborhoods.

Your proposed changes directly oppose CRA's mandate to require lenders to meet community needs. Please drop your, proposal and recognize the harm it will, create for underserved communities.

Sincerely
Mayor Janet Lockhart
City of Dublin, CA