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Office of the Comptroller of the Currency SENT VIA EMAIL Federal Reserve System Deposit Insurance Corporation Office of Thrift Supervision Re: Community Reinvestment Act; Interagency Questions and Answers Regarding Investment; Notice OCC Docket ID: OCC-2007-0012 FRB No.: OP- 1290 FDIC RIN: RIN 3064-AC97 OTS Docket ID: OTS-2007-0030 To Whom It May Concern: On behalf of WNC & Associaies, Inc. (WNC), we thank you for the opportunity to share our views. This public comment letter responds to the notice and request for comments on new and revised Interagency Questions and Answers about community investment as published in the Federal Register of July 11, 2007. WNC & Associates. Inc. has been actively involved in the provision of affordable housing since 1971, and has been a vanguard in the development of the Community Reinvestment Act (CKA) and the Low Income Housing 'Tax Credit (LIHTC). WNC has been the industry leader in the use of the Low Income Housing Tax Credit for affordable housing development since before the program's official creation in 1986. Further, WNC was among the first entities to apply for and receive an allocation of New Markets Tax Credits in 2002. WNC currently has a portfolio of 900 properties in 42 States and the District of Columbia and has a client base of inore than 19,000 institutional and individual investors. WNC offers LIHTC equity funds that qualify under CRA's "investment" test. Our funds have never experienced a ...
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