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September 10, 2007 Robert E. Feldman, Executive Secretary Attention: Comments Federal Deposit Insurance Corporation th550 17 Street, NW Washington, DC 20429 Via E-mail: Comments@FDIC.gov RE: Community Reinvestment Act; Interagency Questions and Answers Regarding ent (Docket OP-1290-Federal Reserve; RIN 3064-AC97(FDIC); Docket ID OCC-2007-0012 (OCC); Docket ID OTS-2007-0030 (OTS)) Dear Mr. Feldman: ShoreBank Corporation welcomes this opportunity to submit comments on the proposed Interagency Questions and Answers Regarding Community Development, referenced above. With assets of $2.1 billion, ShoreBank Corporation is the nation’s first and leading community development bank holding company. During its more than 30-year history, ShoreBank has made over $2.3 billion in mission investments in lower income communities in the urban Midwest, the Upper Peninsula of Michigan and the Pacific Northwest. In 2006 alone, we loaned $365 million for community development purposes, primarily in lower income neighborhoods in Chicago, Detroit and Cleveland. The holding company, the lead bank (ShoreBank, based in Chicago, with branches in Detroit and Cleveland), and its non-profit affiliates in the Upper Peninsula (Northern Initiatives) and Pacific Northwest (ShoreBank Enterprise Cascadia) are also certified Community Development Financial Institutions (CDFIs). This comment is submitted on behalf of those four organizations (collectively ...
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