From: Marti Vatter-Grimm [mailto:grimm@caaofcc.org]
Sent: Tuesday, October 19, 2004 1:56 PM
To: Comments
Subject: RIN 3064-AC50, Community Reinvestment

October 19, 2004

Dear Mr. Feldman:

I am a housing counselor with the Community Action Agency of Columbiana
County and I strongly oppose your proposal to significantly weaken the
Community Reinvestment Act (CRA). You propose much easier CRA requirements
for banks between $250 million to $1 billion in assets. This proposal will
result in much fewer home and small business loans to low- and
moderate-income borrowers and much fewer community development loans and
investments in low- and moderate-income communities. In addition, you
propose that all FDIC-supervised banks can earn CRA points by financing
community development projects that benefit affluent residents in rural
areas, instead of low- and moderate-income consumers and communities in
rural America. This is directly contrary to CRA’s focus on meeting credit
needs of low- and moderate-income communities. In sum, your proposal to
change the CRA regulation will result in much fewer loans, investments, and
branches in low- and moderate-income communities. Our agency provides
consumers with housing counseling services and also small business training.
Although these consumers receive intense one on one counseling, without the
financial resources of our local lenders they will be unable to purchase
their asset. I ask that you please withdraw your harmful proposal.

Sincerely,

Martina Grimm
Financial Services Coordinator
Community Action Agency of Columbiana County, Inc.
7880 Lincole Place
Lisbon, Ohio