FDIC Federal Register Citations

From: Joseph L. Flatley [mailto:flatley@mhic.com]
Sent: Wednesday, October 20, 2004 3:36 PM
To: Comments
Subject: Community Reinvestment -- RIN 3064-AC50

I am writing to express my strong opposition to the proposed rule that would have the effect of exempting financial institutions with assets between $250 million and $1 billion from meeting the current requirements of the Community Reinvestment Act (CRA). While there might be ways to improve the current CRA regulations, the proposed rule will dramatically alter the incentives for the vast majority of banks to participate in community reinvestment initiatives. Moreover, the rule is being considered with far too little deliberation and input from the constituencies that CRA was designed to serve - clearly contrary to legislative intent.

If we have learned anything about community reinvestment over the last three decades, it is that success depends fundamentally on consultation with the communities affected - in terms of their needs and the best way to meet those needs. This requirement extends not only to banks - but also to the FDIC itself as it considers this radical change to the way in which CRA is being implemented.

Our organization has raised over $750 million in capital from our member banks to finance affordable housing and community development. That capital has served critical community needs, while earning a reasonable return to our member banks - all with zero loan losses. It would not have been possible for us to raise that capital if the proposed rules
had been in effect.

Joe Flatley
President and CEO
Massachusetts Housing Investment Corporation
70 Federal Street
Boston, MA 02110