FDIC Federal Register Citations

From: Mark Milligan [mailto:PassageMgmt@msn.com]
Sent: Wednesday, October 20, 2004 8:58 AM
To: Comments
Subject: Reduction of CRA Requirements

I was disheartened to learn of the proposed reduction of CRA requirements for institutions under $1 billion in assets. While these institutions are often the most responsive to the credit needs of their communities, the lessening of regulatory and examination emphasis can only result in some institutions reducing their focus on this vital role. All banks and thrifts hold public charters to do business, and it does not seem logical that the requirements of the Community Reinvestment Act should vary by institution size. If regulatory burden is the issue, there must be ways to balance that without reducing fundamental requirements of the Act.

As an aside, I also marvel at how credit unions continue to avoid any CRA requirements whatsoever. It is, I suppose, a tribute to their political influence; but it defies logic.

Thank you for assessing public comments before proceeding.

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Mark K. Milligan
Passage Management
Passage Capital