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FCS Diversity and Inclusion - PROPOSED RULE - MARCH 2011


Dear Mr. Van Meter,

I am president of IFF, a nonprofit community development financial institution (CDFI) that makes alternative loans to a range of community development projects and entities targeting disinvested  neighborhoods and regions.  Borrowers include community health clinics, child care centers, supportive and affordable housing, youth recreationand support facilities, job training facilities, and most recently independant grocery stores. We have over $200 million in total assets and work in Illinois, Indiana, Iowa, Missouri and Wisconsin, in both urban and rural communities.

We and our colleague CDFIs across the country would make excellent partners to members of the Farm Credit System as you begin planning to reach a more diverse group of borrowers. Our loans tend to be higher risk than those of traditional financial institutions and in our case, we lend for pre-development, vehicles and equipment, and commercial real estate, and often at long terms and below market rates, as long as there is a community development impact of the loan.  Many CDFIs, IFF included, have gotten involved in the healthy foods/regional foods movement and we are learning how to underwrite grocery stores and aggregators. We can assist your members meet their goals by sharing loans, providing credit enhancement, or making a second position loan.  Members may also wish to invest in CDFIs to develop a portfolio for the member.  I am certain we could be of mutual benefit and would welcome the opportunity to meet with you to discuss participation in your planning process.

Please visit our web site at www.iff.org and the web site of our national association, www.opportunityfinance.net.

Thanks you and best regards,

Trinita Logue
President
IFF
312 596 5117
tlogue@iff.org

Trinita Logue
One North LaSalle
Chicago, IL 60602