Bank of America and Fleet: Anticompetitive Merger, Predatory Lending and Redlining, a State-by-State Review by ICP's Fair Finance Watch (and Predatory Bender), Nov. 2003

    Brief preamble (more is available in ICP's Bank of America Watch) -- below, Bank of America, N.A.'s direct mortgage lending, as reported in 2002 Home Mortgage Disclosure Act (HMDA) data, is analyzed, state-by-state.  But it is important to recognize that Bank of America is still assisting and enabling controversial subprime lenders, and is in fact purchasing loans from, for example, Option One, Superior Federal Bank FSB, and working with Accredited Home Lenders, Inc. and New Century.  Certain of these BofA-enabled lenders are analyzed, particularly in the (few) states where Bank of America does not have bank branches and does not report geographically-specific HMDA data.  For or with more information, contact us.  We'll begin with the A's --


Arizona

    A is for Arizona (and also for Arkansas) -- in the Phoenix, Arizona MSA in 2002, for conventional home purchase loans, BofA denied the applications of Latinos 3.49 times more frequently than those of whites, and denied the applications of African Americans 2.46 times more frequently than whites.

  On the predatory lending legislative front, in February 2003, House Bill 2414, "Home loans; prohibited activities," was introduced.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its nine offices in Arizona into branches of a federal savings bank, Chase FSB, to escape state laws... On the state regulatory front:

Arizona State Mortgage bank Regulator link: Arizona State Banking Department


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Arkansas

     BofA Watch:  in the Little Rock, Arkansas MSA (where BofA acquired a major franchise along with Boatmen's Bancshares), BofA for conventional home purchase loans in 2002 denied the applications of African Americans 3.29 times more frequently than whites, and denied the applications of Latinos 4.03 times more frequently than whites.

   On the predatory lending legislative front, the Arkansas Home Loan Protection Act, House Bill 2598, became effective on July 16, 2003, as "Act 1348 of 2003." On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its three offices in Arkansas (Little Rock, Springdale and Bentronville) into branches of a federal savings bank, Chase FSB, to escape state laws...Land of  Wal-Mart, and one of the states, like Delaware, which limits access to documents under FOIA to citizens of the state.  ICP will soon (12/03) be litigating this issue, in at least one of the four states... And finally, for this space, on the regulatory front: Arkansas Securities Department


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Alabama

    BofA did not in 2002 report MSA-specific HMDA data in Alabama since it does not (yet) own banks here. ICP is analyzing the lending in this and other states of subprime lenders assisted and enabled by Bank of America, including Accredited Home Lenders, Inc., New Century and Option One.

   On the predatory lending legislative front, a proposed Alabama Predatory Lender's Act, a/k/a "Consumer Equity Protection Act," House Bill 29, Senate Bill 204 -- was introduced March 4, 2003, got referred to committee - and was then apparently forgotten. Here are some related proposals, --House Bill 529; Senate Bill 273; HB 206 (all in pdf format) and the Alabama State Legislature. On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its office in Alabama (709 Azalea Road in Mobile) into a branch of a federal savings bank, to escape state laws...

  ICP/Fair Finance Watch has for example fought Birmingham-based AmSouth, when it made a move on First American / Deposit Guaranty (see “Groups Say Loan Denial Rates High,” The Tennessean), which later settled (see  “Bank settles 'unfair lending' claims,” The Tennessean).

  In Predatory Bender, Tom Bain tracks Amsouth.  Jack Bender and his daughter Zalie, starting from their days together in Charlotte, North Carolina, have always liked Waffle House.  What's not to like?


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Alaska

State Mortgage bank Regulator:
Alaska Division of Banking Securities & Corporations

  Here ICP/Fair Finance Watch, along with Alaska PIRG, fought Wells Fargo Financial, see, “Watchdogs Challenge Wells Fargo's Alaska Plans,” by Ron Leuty, San Francisco Business Times, April 24, 2000, and, from grassroots newspaper not on the Web, “Groups Want to Halt Wells Fargo Merger,” by E. Burkett, Mat-Su Valley Frontiersman (Alaska), April 25, 2000, Pg. A1; “Move to Delay National Bank of Alaska Takeover,” Kodiak (AK) Daily Mirror, April 19, 2000, etc.. The town of Homer, on the Kenai peninsula, helped inspired Inner City Press' Alaska Report.


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California

State Mortgage bank Regulator(s):
California Department of Corporations
California Department of Real Estate

  California: land now of the Terminator,once the headquarters of Bank of America; world's sixth largest economy and its celluloid dream-space, to which Jack Bender with his daughter flees, burning rubber and more ways than one... In and around that commercial soap box,  Los Angeles, in 2002 for conventional home purchase loans, BofA denied the applications of Latinos 3.13 times more frequently than those of whites, and denied the applications of African Americans 2.81 times more frequently than whites. BofA's denial rate disparities are much higher than the industry's (1.62 for Latinos and 1.95 for African Americans). Again, for refinance loans, BofA's record is even worse: BofA in 2002 denied the refinance applications of Latinos 3.90 times more frequently than those of whites, and denied the applications of African Americans 4.23 times more frequently than whites - both disparities much higher than the industry's (1.81 for Latinos and 2.18 for African Americans).  Beyond the Los Angeles data set forth above, in the San Francisco MSA for refinance loans in 2002, BofA denied the applications of Latinos 2.45 times more frequently than those of whites -- and denied the applications of African Americans a whopping 4.48 times more frequently than whites.

  Los Angeles passed a predatory lending ordinance, 01-1476, available here (in pdf).  Oakland passed Ordinance 001299a. Statewide, there's AB 489, adopted as Chapter 732 of 2001, and effective July 1, 2002.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 54 offices in California into branches of a federal savings bank, Chase FSB, to escape state laws... The 2002 fight against Citigroup - Golden State Bancorp (another ICP collaboration with CRC) unearthed much dirt from Citigroup's closet, including for example about the ROCopoly compensation scheme, "incenting" employees to hard-sell insurance... 


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Colorado


Colorado Department of Law

     C is for Colorado - in the Denver, Colorado MSA for refinance loans in 2002, BofA denied the applications of Latinos 2.32 times more frequently than those of whites -- and denied the applications of African Americans a whopping 3.41 times more frequently than whites.  New predatory lending regulations are effective in Colorado on January 1, 2003 - click here for the guidelines, published by the Colorado Attorney General; also, 2003 Session Laws, Chapter 295.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its ten offices in Colorado into branches of a federal savings bank, Chase FSB, to escape state laws... Meanwhile, Colorado is another battleground with Wells Fargo Financial, see "Wells Fargo Accused of Predatory Lending," Denver Post, July 29, 2003, and "Wells Fargo Accused of Unfair Lending," Rocky Mountain News, July 29, 2003, Pg. 6B.


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Connecticut

State Mortgage bank Regulator:
Connecticut Department of Banking

  BofA did not in 2002 report MSA-specific HMDA data in CT since it does not (yet) own banks here. ICP is analyzing the lending in this and other states of subprime lenders assisted and enabled by Bank of America, including Accredited Home Lenders, Inc., New Century and Option One.

The Connecticut Abusive Home Loan Lending Practices Act became effective on October 10, 2001...  The Banking Commissioner has sued Wachovia -- but then (Nov. 2003) sought to deny a FOIA fee waiver. ICP appealed, and on Nov. 18 ICP was informed that it will get a fee waiver.


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Delaware

State Mortgage bank Regulator:
Delaware Office of the State Bank Commissioner

    BofA did not in 2002 report MSA-specific HMDA data in DE since it does not (yet) own banks here. ICP is analyzing the lending in this and other states of subprime lenders assisted and enabled by Bank of America, including Accredited Home Lenders, Inc., New Century and Option One.   Given the flocking of corporations, water-craft and credit card companies to Delaware, ICP has an ongoing Delaware Watch, click here to view... On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its three offices in Delaware (Dover, Newark and Dehoboth Beach) into branches of a federal savings bank, Chase FSB, to escape state laws. On October 30, 2003, the state banking commissioner approved -- in part because Chase FSB would be based in Delaware... The state's lucky to have advocates, less lucky to have an insurance commissioner who's elected, and who takes campaign contributions from the industry, including Household and Citigroup... Meanwhile, state agencies claim that Delaware's FOIA is only for state residents - something about to be challenged. Developing...


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District of Columbia

State Mortgage bank Regulator:
District of Columbia Office of Banking & Financial Institutions

 

   The 2002 Home Mortgage Disclosure Act (HMDA) data reported by Bank of America, N.A. (BofA) show that BofA disproportionately excludes African Americans and particularly Latinos from its lending. In 2002 in the Washington, DC, Metropolitan Statistical Area ("MSA"), for example, for conventional home purchase loans, BofA denied the applications of Latinos 3.53 times more frequently than those of whites, and denied the applications of African Americans 3.29 times more frequently than whites. These BofA denial rate disparities is worse than those of the industry aggregate in the Washington DC MSA. For example, for conventional home purchase loans, the aggregate denied Latinos 2.38 times more frequently than whites, and African Americans 3.04 times more frequently than whites -- both significantly lower than BofA's disparities, of 3.53 for Latinos and 3.29 for African Americans.

  In Washington DC and in most other MSAs, BofA's disparities for refinance loans were even worse. In 2002 in this MSA, BofA denied the refinance applications of Latinos 5.15 times more frequently than those of whites, and denied the refinance applications of African Americans 4.72 times more frequently than whites. The aggregate, less disparate, denied Latinos 2.62 times more frequently than whites (compared to BofA's 5.15), and denied African Americans 3.06 times more frequently than whites (significantly lower than BofA's disparity of 4.72).

The DC Home Loan Protection Act became effective March 6, 2002; there's also the regulation, Title 26A of the DC Code, Chapter 20 of 2002. This is governmental ground-zero, and base of NCRC, and yet the predators run wild. See, for example, Hargraves v. Capitol City Mortgage Corp. (D.D.C.), the summary and/or a DOJ amicus brief...  


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Florida

State Mortgage bank Regulator:
Florida Department of Banking & Finance

   In 2002 in the Tallahassee MSA for conventional home purchase loans, BofA denied the applications of African Americans 2.08 times more frequently than those of whites,  In this as in most other MSAs, BofA's disparities for refinance loans were even worse. In 2002 in this MSA, BofA denied the refinance applications of African Americans 2.31 times more frequently than those of whites...

    The Florida Fair Lending Act, formerly known as Senate Bill 2262, "provides legislative findings; specifies prohibited acts re high-cost home loans; specifies required disclosures for high-cost home loans; requires lenders of high-cost home loans to provide notice to borrowers prior to taking foreclosure actions; allows borrower to cure default; provides that lender who violates this act forfeits interest in high-cost home loan; " etc.. Effective Oct. 2, 2002, its main purpose is to preempt all municipalities' and counties' anti-predatory lending legislation...

  Among various Florida campaigns, there are these, of predatory lending, redlining, and even money-laundering: "Group Targets Meritage Loan Practices," by Mark Gordon, Florida Times-Union (Jacksonville), January 15, 2002, Pg. F1;  "SunTrust buy challenged: Bronx jeer: NYC group questions minority lending, terrorist accounts in Florida," Orlando Business Journal, December 10, 2001

  Despite hoopla about Florida's open records law, and the availability of autopsy photos of crashed NASCAR drivers, ICP found the Florida Attorney General's Office to be among the least responsive...


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Georgia

State Mortgage bank Regulator:
Georgia Department of Banking & Finance

  This was the locus of showdown, because democracy (and the state legislature) and the subprime lenders, including Chase Manhattan, which is trying to convert its twelve offices in Georgia into branches of a federal savings bank, Chase FSB, to escape state laws... The rating agencies, Standard & Poor's and Fitch, conspired to overturn legislation by threatening to refuse to rate pools of loans made in the state.  HB 1361, October 2002, preempted all municipalities' and county's legislation (for example, Tlanta's Ordinance 01-O-0843 and 01-O1488, and DeKalb County's Predatory Lending Ordinance of 2001. "How does it feel," some asked Georgians, "to be treated with a Third World country?"

  G is for Georgia - in the Atlanta, Georgia MSA, BofA for refinance loans in 2002 denied the applications of African Americans 2.66 times more frequently than whites, and denied the applications of Latinos 3.45 times more frequently than whites.


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Hawaii

State Mortgage bank Regulator:
Hawaii Department of Commerce and Consumer Affairs

Introduced on the same day - Feb. 10, 2003 -- were HB 374 - the :Hawaii Home Loan Protection Act to protect the homes and equity of individual borrowers," and HB 1438 - (prohibiting mortgage brokers from engaging in predatory lending practices)...


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Idaho

State Mortgage bank Regulator:
Idaho Department of Finance

  Idaho, or at least its Attorney General's Office, shamelessly accommodated Household in late 2002, allowing Household to jettison its subprime credit card-lending Orchard Bank, to Panhandle State Bank, connoting either change-begging or pancakes.  ICP commented -- see, "Group Challenging Purchase by Panhandle: Complaint Seeks Review of Banks' Lending Practices," The Spokesman-Review (Spokane, WA), November 27, 2002 -- but the Idaho regulator hauled off and approved the sale, while the Idaho attorney general's office withheld virtually all documents about the settlement with Household... Click here to view HB 28, "A Bill to Amend the Licensing Practices For Mortgage Brokers Or Mortgage Bankers."

In the Boise, Idaho MSA in 2002 for refinance loans, BofA denied the applications of Latinos 2.36 times more frequently than whites (refinance loans to African Americans are not analyzed, since BofA did not make any such loans to African Americans in this MSA).


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Illinois

State Mortgage bank Regulator:
Illinois Office of Banks & Real Estate

  On August 20, 2003, the High Risk Home Loan Act became law. Click  here for the text of SB 1784 / PL 93-0561, in pdf format (together, as enacted, they are Public Act 93-0561); click here for an analysis. There were also Cook County Ordinance 240684 of 2001 and Chicago Ordinance SO2000-2145. On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 18 offices in Illinois into branches of a federal savings bank, Chase FSB, to escape state laws...

In the Chicago MSA in 2002, for conventional home purchase loans, BofA denied the applications of Latinos 3.67 times more frequently than those of whites, and denied the applications of African Americans 2.12 times more frequently than whites. For refinance loans, BofA's record is even worse: BofA in 2002 denied the refinance applications of Latinos 3.80 times more frequently than those of whites, and denied the applications of African Americans 3.45 times more frequently than whites - both higher than the industry's.


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Indiana

State Mortgage bank Regulator:
Indiana Department of Financial Institutions

  Home of Conseco, which bought the subprime lender Greentree then blew up. Click here to view Senate Bill 478, concerning among other things predatory lending.  Inner City Press appealed the Indiana AG's denial of access to Household-related documents to the state's Public Access Counselor, resulting in this decision (html).   On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its five offices in Indiana into branches of a federal savings bank, Chase FSB, to escape state laws...


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Iowa

State Mortgage bank Regulator:
Iowa Division of Banking

   In the Des Moines, Iowa MSA in 2002 for refinance loans, BofA denied the applications of Latinos 2.70 times more frequently than whites.

   Headquarters of Wells Fargo Financial, which shook the taxpayers down for corporate welfare and "incentives" in 2003.  Surprisingly unfriendly on FOIA, too, at least the state AG's Office, on fees...


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Kansas

State Mortgage bank Regulator:
Kansas Office of State Bank Commissioner

  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its three offices in Kansas (two in Wichita and one in Overland Park) into branches of a federal savings bank, Chase FSB, to escape state laws...ICP presented (Household) predatory lending exhibits to the Kansas Attorney General's office...

In the Topeka, Kansas MSA in 2002, BofA denied the conventional home purchase loans of African Americans 7.89 times more frequently than whites.

 


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Kentucky

State Mortgage bank Regulator:
Kentucky Department of Financial Institutions

  HB 287, enacted as Acts Ch. 64 of 2003, concerns predatory lending -- the rating agencies S&P and Fitch don't like the law, refused to rate mortgage backed securities involving Kentucky properties. Also, Kentucky's AG's Office circled the wagons to protect Household International -- so ICP appealed:

Dear Attorney General Chandler, and Assistant Attorney General Harold J. Turner:

   On behalf of the Inner City Press/Community on the Move and its members, and of the Fair Finance Watch (collectively, "ICP"), this is an appeal from Assistant Attorney General Turner's Feb. 10, 2003, letter (the "Denial") partially denying access to records responsive to ICP's Jan. 10, 2003, request for records related to your Office's recent Settlement with Household International, Inc. ("Household"), and denying ICP's request for a fee waiver. This is a formal appeal under both KRS 61.880(2) and (4)... Other states' Attorney General's Offices have provided us with certain inter- and intra-agency communications, and with certain of their communications with Household (which they've deemed not covered by the identical confidentiality provisions of their Consent Judgments, see below, and with memos from the investigation of Household, including one the provides this description of Household's practices:

"The use of a large range of discount points on the GFE is misleading to consumers. HFC's claims that borrowers had a 'choice' of rates and discount points has proven to be false.. A significant number of consumers from across the country have complained that they were promised an approximate 7% rate when the rate was far greater (11% to 14%... HFC's practice is to hard sell insurance products. These practices break down into four categories: i) aggressive sales tactics, ii) inclusion of insurance without customer knowledge, iii) making borrowers believe insurance is a requirement, and iv) forgery of signatures on acceptance documents...

HFC has charged excessive and unconscionable fees including unlawful increases to charges by third party providers (e.g. title report fees)... HFC has routinely made loans to borrowers in which there is no tangible benefit. A consistent practices appears to be the requirement of a high rate second mortgage behind a high rate first mortgage that leaves the borrower in a far worse position than before they transacted business with HFC... The characteristics of HFC's home equity line of credit are those of a closed end, rather than open end. The result is the avoidance of required RESPA and TILA disclosures... Numerous occurrences of failure to make GFE and TIL disclosure have been noted... Loan-to-values in excess of 100% are intended to lock borrowers into loans with principal amounts so high compared with the value of the borrowers' homes that the borrowers are unable to refinance with another lender. Because these loans are under collateralized, where these loans go into foreclosure there will almost certainly be a deficiency... Household has engaged in the practice of mailing 'live' checks to potential borrowers... These live check loans are marketing tools and persons who case the 'live' checks are placed on a 'hot list' for 'target practice' and are aggressively marketed to consolidate the live-check loan with the consumer's other credit obligations in a home equity loan with a slightly smaller interest rate but a much larger principal balance secured by the borrowers' residences."

   Suffice it to say that not all of these practices were addressed or reformed by the Settlements or by your Office's Consent Judgment with Household.

   Nor have these practices since been addressed...


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Louisiana

State Mortgage bank Regulator:
Louisiana Office of Financial Institutions


  Here's a social initiative in New Orleans to combat predatory lending. Much exhortation: House Resolution 103 asks the Office of Financial Institutions to promulgate rules and regulation to increase public awareness of predatory lending practices.  These can be found, for example, at offices of CitiFinancial, Household, Wells and American General... Meanwhile House Bill 817, which would require expanded disclosures on high cost loans, remains bottled up in the Committee on Commerce, or dead, depending who you ask... On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its eleven offices in Louisiana into branches of a federal savings bank, Chase FSB, to escape state laws...Here's just three of the CitiFinancials in Louisiana:

8309 W Judge Perez Dr, Chalmette, LA 70043 - 504-276-6330
3501 N. Causeway Boulevard, Metairie, LA 70002 - 504-837-8980
601 Terry Parkway, Gretna, LA 70056 - 504-362-3923


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Maine

State Mortgage bank Regulator:
Maine Department of Professional & Financial Regulation - Office of Consumer Credit Regulation
Maine Department of Professional & Financial Regulation

  When you pass a weak law (like Maine's LD 494 -- "An Act To Enhance Consumer Protections in Relation to Certain Mortgages" -- later S&P pats you on the head, saying it will continue to rate "structure finance transactions" in your state...


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Maryland

State Mortgage bank Regulator:
Maryland Division of Financial Regulation

  Senate Bill 574 and House Bill 864 died and were withdrawn. Subsequently, the same Maryland Commissioner who ruled on (and approved) HSBC's applications to acquire Household, Mary Louise Preis, left less than a year later, going to work for CitiFinancial...  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 11 offices in Maryland into branches of a federal savings bank, Chase FSB, to escape state laws... ICP's Maryland campaigns have included T. Rowe Price Thrift Application Challenge (“N.Y. Consumer Group Opposed T. Rowe Price Plan for Thrift,” Baltimore (and Washington) Business Journals)...

  M is for Maryland - in the Baltimore, Maryland MSA in 2002, for conventional home purchase loans, BofA denied the applications of Latinos 3.12 times more frequently than those of whites, and denied the applications of African Americans 2.54 times more frequently than whites. For refinance loans, BofA in 2002 denied the applications of Latinos 2.23 times more frequently than those of whites, and denied the applications of African Americans 3.02 times more frequently than whites


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Massachusetts

State Mortgage bank Regulator:
Massachusetts Division of Banks

  BofA did not in 2002 report MSA-specific HMDA data in Massachusetts since it does not (yet) own banks here. ICP is analyzing the lending in this and other states of subprime lenders assisted and enabled by Bank of America, including Accredited Home Lenders, Inc., New Century and Option One.

  Here's a good proposal: a bill "to establish community reinvestment obligations for mortgage lenders," SB 4.   Also, the anti-predatory lending regulations at 209 CMR 40.00 et seq. of 2000.   On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its eight offices in Massachusetts into branches of a federal savings bank, Chase FSB, to escape state laws... The Division of Banks holds hearings -- ICP attended one in September 2003 -- but rarely follows-up.  Shawmut, BayBanks, Bank of Boston -- where did they go?  See, e.g., “Fleet, BankBoston Plan to Lend $14.6 Billion For Low-Income, Small-Business Loans,” by John Hechinger, Wall Street Journal, June 28, 1999, Pg. A6. Here's just three of the CitiFinancials in Massachusetts:

1598 Hancock Street, Quincy, MA 2169 - 617-479-6850
Rte 114 300 Andover Street, Peabody, MA 1960 - 978-538-9215
500 Providence Highway, Norwood, MA 2062 - 781-769-3436


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Michigan

State Mortgage bank Regulator:
Michigan Financial Institutions Bureau

  Concerning the drafting, industry lobbying against, and redrafting of Detroit's Anti-Predatory Lending Ordinance, click here for a summary, here for full text, both in pdf format.  The Mayor vetoed it two days after Christmas, 2002.   On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 11 offices in Michigan into branches of a federal savings bank, Chase FSB, to escape state laws. In the Detroit MSA in 2002 CMMC denied the refinance applications of African Americans 2.58 times more frequently than whites; in the Benton Harbor MSA, CMMC denied the refinance applications of African Americans 2.36 times more frequently than whites... ICP's work in the Motor City goes back to at least 1995 -- see, e.g., "Group Says NBD's Loan Record Should Void Merger," by Joel J. Smith, Detroit News, October 3, 1995 -- and gave rise to and ICP Detroit Watch Report.


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Minnesota

State Mortgage bank Regulator:
Minnesota Department of Commerce

  Here's an attempt to combat the marketing of predatory lenders in the Twin Cities area.   The proposed Minnesota Home Loan Protection Act of 2003 was referred to the Committee on Commerce and Utilities, where it essentially died (offically, it was "laid over").  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its six offices in Minnesota into branches of a federal savings bank, Chase FSB, to escape state laws... Minneapolis, historically, was the headquarters of Norwest, which bought finance companies, including Puerto Rico-based Island Finance.  Under Norwest, Island Finance opened a storefront in the South Bronx, charging everyone who walked in 25% interest, without even checking people's credit histories.  Pricing by risk?


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Mississippi

State Mortgage bank Regulator:
Mississippi Department of Banking and Consumer Finance

  Stomping ground -- and we mean that literally -- of the old Deposit Guaranty Bank, later bought by AmSouth. ICP raised issues (see, e.g., “Groups Say Loan Denial Rates High,” The Tennessean (Nashville, TN), July 27, 1999), and soon AmSouth settled with the Department of Justice, charges of discriminatory lending.  See, e.g., “Bank settles 'unfair lending' claims,” The Tennessean, September 30, 1999. But AmSouth has improved little since then...


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Missouri

State Mortgage bank Regulator:
Missouri Division of Finance


  Watchdogging is constant in the Show-Me State. NationsBank-Boatmen's ("NationsBank-Boatmen's Merger," Associated Press, December 17, 1996), Shelter Mutual Insurance (see, “Shelter Insurance Is Accused of Housing Bias: Company Denies N.Y. Group’s Charges,” Jim Gallagher, St. Louis Post-Dispatch, October 7, 1998, Pg. C1), Citigroup - Associates: ICP's fought 'em tooth and nail, filing suit in Jefferson City, walking the downtown of St. Louis by The River, across to the other side, weedy East St. Louis...

M is also for Missouri - in the St. Louis, Missouri MSA (where BofA acquired a major franchise along with Boatmen's Bancshares), BofA for conventional home purchase loans in 2002 denied the applications of African Americans 2.23 times more frequently than whites, and denied the applications of Latinos 3.06 times more frequently than whites.

On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its eight offices in Missouri into branches of a federal savings bank, Chase FSB, to escape state laws...


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Montana

State Mortgage bank Regulator:
Montana Division of Banking & Financial Institutions

  Here's SB 402, the Montana "Mortgage Broker and Loan Originator Licensing Act," signed by Gov. Judy Martz in May 2003, in pdf format.  


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Nebraska

State Mortgage bank Regulator:
Nebraska Department of Banking & Finance

   Here's LB 218, signed by the Governor March 20, 2003. It prohibits predatory practices in the mortgage loan industry and increases the authority of the Nebraska Department of Banking and Finance to take action against persons engaged in predatory lending practices.    


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Nevada

State Mortgage bank Regulator:
Nevada Department of Business & Industry

  Gold, sun, casinos and retirees -- this was the venue for a fight against Wells Fargo (“Wells Fargo Merger Target of Las Vegas, N.Y. Critics,” by Richard N. Velotta, Las Vegas Sun, August 15, 2000), and soon after, against Citigroup - Associates: "Activist Seeks Nevada Hearing,"  Las Vegas Sun, October 24, 2000. The anti-predatory lending AB 284 was signed by the Governor on June 10, 2003, as Chapter 465, and became effective on October 1, 2003. On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its two offices in Nevada (Reno, and 500 N. Rainbow Blvd. in Las Vegas) into branches of a federal savings bank, Chase FSB, to escape state laws...

  N is for Nevada - in the Las Vegas, Nevada MSA in 2002, for conventional home purchase loans, BofA denied the applications of Latinos 2.23 times more frequently than those of whites, and those of African Americans 2.22 times more frequently than whites.


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New Hampshire

State Mortgage bank Regulator:
New Hampshire Bank Commissioner's Office

  Here ICP fought KeyBank, while it bought Champion Mortgage.  We tip our cap to the Granite State CRA Coalition... On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its two offices in New Hampshire (Portsmouth, and 1750 Elm St. in Manchester) into branches of a federal savings bank, Chase FSB, to escape state laws...


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New Jersey

State Mortgage bank Regulator:
New Jersey Department of Banking & Insurance

  An ever-shifting, late-passed law, AB 75, slated to go into effect on November 27, 2003, was subject to much rating agency sniping; there's also the loss of all big banks headquartered in the state, and almost non-functioning FOIA regime. Still we love Trenton, Camden, Jersey City and Newark too -- having seen the First Fidelity Merger Aftermath.  In 2002 in the Newark MSA,  for conventional home purchase loans, Citibank (Citibank FSB and CitiMortgage together) denied loan applications from African Americans a whopping 30.8 times more frequently than applications from whites. Citibank denied Latinos 15.2 times more frequently than whites. This is much, much worse than other lenders in this MSA: the denial rate disparities for the industry as a whole in 2002 were 3.43 for African Americans, and 2.33 for Latinos. Citibank's higher-than-aggregate denial rate disparities are certainly not explained by any greater-than-normal outreach with normal-priced credit to African Americans or Latinos. For these three groups, the aggregate made 10.0% of its loans to African Americans, and 10.3% to Latinos. For Citibank, the figures were 4.8% of loans to African Americans, and 4.8% to Latinos...  

   BofA did not in 2002 report MSA-specific HMDA data in New Jersey since it does not (yet) own banks here. ICP is analyzing the lending in this and other states of subprime lenders assisted and enabled by Bank of America, including Accredited Home Lenders, Inc., New Century and Option One.


Return to Fair Finance Watch U.S. Map, @ Inner City Press



New Mexico

State Mortgage bank Regulator:
New Mexico Financial Institutions Division

Ah, Nuevo Mexico, venue of fights against NationsBank - Boatmen's (see, "NationsBank-Boatmen's Merger," Associated Press, December 17, 1996), and NationsBank buying Montgomery. Thereafter forgotten by NationsBank-turned Bank of America... On January 8, 2003, the Santa Fe city council passed Resolution 2003-4, calling for a state anti-predatory lending law; on April 11, 2003, SB 449, the "Home Loan Protection Act,"  was signed into law, becoming effective on the first day of 2004.

In the Santa Fe NM MSA in 2002, for conventional home purchase loans, BofA denied the applications of Latinos a whopping 4.94 times more frequently than those of whites.


Return to Fair Finance Watch U.S. Map, @ Inner City Press



New York

State Mortgage bank Regulator:
New York Banking Department

  There's too much to say, in this space -- state laws (SB 11856 / Chapter 626 of 2002: for loans of $300,00 or less--

If the APR is 8 points higher on the first trust deed than yield on appropriate treasury securities which have an equivalent term, or

if the APR is 9 points higher on a second trust deed that the yield on the treasury securities which have an equivalent term, or

The total points and fees are more than 5%.predatory lending--

  the NYC ordinance (67A of 2002, Local Law No. 36); and the NYBD's Part 41. Headquarters to sleazy Citigroup and Chase, five boroughs and eight million stories. And those are just in New York City -- there's also Buffalo (see, e.g., “Acquisition of Republic Could Face Court Challenge,” Business First Buffalo), Rochester, Syracuse, Albany (for example, see "Complaint Alleges Violations" [of NY Elections Law by Household], by Elizabeth Benjamin, Albany Times Union, February 3, 2003). 

In the Long Island, New York MSA in 2002, for conventional home purchase loans, BofA denied the applications of Latinos a whopping 4.66 times more frequently than those of whites...  For more, click here for ICP's Weekly Bronx Report...


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North Carolina

State Mortgage bank Regulator:
North Carolina Commissioner of Banks

  More predatory lending action than you can shake a stick at -- a model statute (click here to view, in pdf format); competing studies; home to Wachovia and B of A, and the smaller RBC Centura and BB&T.

  In the Greensboro NC MSA in 2002, for conventional home purchase loans, BofA denied the applications of Latinos 4.03 times more frequently than those of whites, and denied the applications of African Americans 2.62 times more frequently than whites. For refinance loans, BofA in 2002 denied the applications of Latinos 2.56 times more frequently than those of whites, and denied the applications of African Americans 2.49 times more frequently than whites.

  In the Raleigh-Durham NC MSA in 2002, for conventional home purchase loans, BofA denied the applications of Latinos 3.32 times more frequently than those of whites, and those of African Americans 2.15 times more frequently than whites. For refinance loans, BofA in 2002 denied the applications of Latinos 4.32 times more frequently than those of whites, and denied the applications of African Americans 3.50 times more frequently than whites. For refinance loans in the Charlotte NC MSA, BofA in 2002 denied the applications of Latinos 3.37 times more frequently than those of whites, and denied the applications of African Americans 2.43 times more frequently than whites.

 See also. as a blast from the past, "NationsBank Merger Spurs Probe Requests," Triangle Business Journal.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 11 offices in North Carolina into branches of a federal savings bank, Chase FSB, to escape state laws...


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North Dakota

State Mortgage bank Regulator:
North Dakota Department of Banking & Financial Institutions

Home to U.S. Bancorp's sleazy credit card and home equity lending operation, and bad on FOIA to boot:

Dear Ms. Brocker, and Attorney General Stenehjem:

   On behalf of the Inner City Press/Community on the Move and its members, and of the Fair Finance Watch (collectively, "ICP"), this regards Ms. Brocker's Jan. 15, 2003, constructive denial (the "Denial") of ICP's request, under North Dakota's open records laws and otherwise, for records related to your Office's recent Settlement with Household International, Inc. ("Household"), etc..

   The context of ICP's request, in brief, is that Household has been charged in all fifty states with predatory lending, has entered a settlement that many consumers' organizations including FFW contend is too limited, and has now proposed to be acquired by the London-based Hongkong Shanghai Banking Corporation ("HSBC"). It is in the public interest to disclose the specifics of all complaints against Household (and, for comparison's sake, certain of its peers) in North Dakota, and to disclose the specifics of the Settlement in North Dakota. We note again that on Dec. 19, 2002, Household issued a press release stating that "[a]ll 50 states and the District of Columbia have agreed to participate in the program." For your information, numerous Attorney General's Offices in other state have provided ICP, without cost, with copies of complaints and other records in response to nearly identical Jan. 10, 2003, requests from ICP.

  The Denial provided not a single document. Rather, the Denial claims that all responsive records would be exempt, and threatens to require an advance payment of costs... The Denial states that "there were no Household branch offices in North Dakota." That does not mean that Household International does not do business in North Dakota, in a variety of ways -- including but not limited to through brokers, with tax Refund Anticipation Loans (at interest rates over 100%) through H&R Block and others, through credit cards including subprime / secured credit cards (under the brand name "Orchard Bank") and/or credit insurance in connection with these (collectively, the "Other Household Practices").

   Household and HSBC are now claiming that the Settlement addresses all of Household's allegedly predatory practices except RALs; so we are request documents reflecting your Office's consideration of, and action on, the Other Household Practices.

  But no such documents were every provided...


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Ohio

State Mortgage bank Regulator:
Ohio Department of Commerce

  A history of fair housing beyond compare: Cleveland (Ordinances 372-02, 737-02, 45-03), Dayton (29990-01) and Toledo (click here for August 2003 Toledo anti-predatory lending ordinance, No. 271-03). Ohio HB 386 purports to preempt all municipalities' anti-predatory lending legislation....  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its nine offices in Ohio into branches of a federal savings bank, Chase FSB, to escape state laws...ICP's fought Charter One, Bank One, Fifth Third (see, "Group Seeks to Stop Fifth Third Merger," by John Nolan, Associated Press, Cincinnati Post, January 23, 2001) and PNC. In 2003,. ICP filed suit in Franklin County against HSBC-Household...

BofA did not in 2002 report MSA-specific HMDA data in Ohio since it does not (yet) own banks here. ICP is analyzing the lending in this and other states of subprime lenders assisted and enabled by Bank of America, including Accredited Home Lenders, Inc., New Century and Option One.


Return to Fair Finance Watch U.S. Map, @ Inner City Press



Oklahoma

State Mortgage bank Regulator:
Oklahoma Department of Consumer Credit

  HB 1574, the Oklahoma Home Ownership and Equity Protection Act, , was approved May 29, 2003.  Here's a 2002 report on predatory lending in Oklahoma. On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its four offices in Oklahoma into branches of a federal savings bank, Chase FSB, to escape state laws...  In 1999,  ICP opposed Wal-Mart, when they tried to enter banking, in Oklahoma. See, e.g.,  "Wal-Mart’s Banking Plans Opposed,” Tulsa (OK) World, July 24, 1999. 

  O of for Oklahoma, another state where Boatmen's was bought: in the Oklahoma City MSA for conventional home purchase loans, BofA in 2002 denied the applications of Latinos 3.73 times more frequently than those of whites, and denied the applications of African Americans 4.27 times more frequently than whites. For refinance loans, BofA in 2002 denied the applications of Latinos 2.82 times more frequently than those of whites, and denied the applications of African Americans 2.98 times more frequently than whites



Return to Fair Finance Watch U.S. Map, @ Inner City Press



Oregon

State Mortgage bank Regulator:
Oregon Department of Consumer & Business Services

  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 12 offices in Oregon into branches of a federal savings bank, Chase FSB, to escape state laws...Here, HB 3088 got buried, and the state AG wants $2000 for documents about Household...

For refinance loans in the Portland, Oregon MSA, BofA in 2002 denied the applications of Latinos 3.22 times more frequently than those of whites, and denied the applications of African Americans 2.23 times more frequently than whites...




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Pennsylvania

State Mortgage bank Regulator:
Pennsylvania Department of Banking

  The Philadelphia ordinance was preempted by HB 1703.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its seven offices in Pennsylvania into branches of a federal savings bank, Chase FSB, to escape state laws... In 2002 in the Philadelphia MSA, CitiMortgage denied the conventional home purchase loan applications from African Americans 4.55 times more frequently than applications from whites, higher than the aggregate's disparity (3.11)...  Meanwhile, AG Mike Fisher, and the departments of banking and insurance, claim that their Right-to-Know Act is only for Pennsylvania citizens -- making PA one of the few states to do this, like Delaware (more on this anon). 

BofA did not in 2002 report MSA-specific HMDA data in Pennsylvania since it does not (yet) own banks here. ICP is analyzing the lending in this and other states of subprime lenders assisted and enabled by Bank of America, including Accredited Home Lenders, Inc., New Century and Option One.




Return to Fair Finance Watch U.S. Map, @ Inner City Press



Rhode Island

State Mortgage bank Regulator:
Rhode Island Banking Division

   They lost the headquarters of Fleet, the Providence television show, and now everything else. On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its office in Rhode Island (300 Centerville Road in Warwick) into a branch of a federal savings bank, Chase FSB, to escape state laws...

BofA did not in 2002 report MSA-specific HMDA data in Rhode Island since it does not (yet) own banks here. ICP is analyzing the lending in this and other states of subprime lenders assisted and enabled by Bank of America, including Accredited Home Lenders, Inc., New Century and Option One.


Return to Fair Finance Watch U.S. Map, @ Inner City Press



South Carolina

State Mortgage bank Regulator:
South Carolina Department of Consumer Affairs

  Here's SB 438 / Act 42 - "High-Cost And Consumer Home Loans Act" (click here, in pdf) -- and, in html, a (lenders') lawyer's article about the law.  It becomes effective January 1, 2004.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its three offices in South Carolina (Greenville, Piedmont and Columbia) into branches of a federal savings bank, Chase FSB, to escape state laws...

S is for South Carolina - in the Columbia SC MSA, for conventional home purchase loans, BofA in 2002 denied the applications of Latinos 3.26 times more frequently than those of whites, and denied the applications of African Americans 2.29 times more frequently than whites. For refinance loans, BofA in 2002 denied the applications of Latinos 2.88 times more frequently than those of whites -- and denied the applications of African Americans a whopping 3.55 times more frequently than whites.


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South Dakota

State Mortgage bank Regulator:
South Dakota Department of Commerce & Regulation

  In fighting Citi-Associates, the SD regulator held a hearing; at the 11th hour, Citigroup tried to prevent ICP for participating:

Dear Mr. Duncan, Dept. of Commerce and Regulation

  On the evening of October 9, 2000, Columbus Day, at 11 p.m., I was informed by a staff member of Inner City Press/Community on the Move ("ICP") that counsel to Citigroup, Inc. had just faxed a letter to ICP's office, purporting to oppose ICP's party status for the October 10, 2000 hearing in the above-captioned matter.

   As you know, ICP's request for party status was granted, by letter dated October 2, 2000. In our phone conversation on October 5, you agreed to allow ICP to participate as a full party, by telephone, at the hearing on October 10 at 10 a.m. CST. There should be no need for ICP to respond to Citigroup's counsel's eleventh hour opposition. However, having reviewed Citigroup's counsel's letter, and its one-sided (and misleading) presentation of case law, at 2, ICP is submitting this response.

  Citigroup's counsel devotes the longest paragraph of the letter to a one-sided presentation of federal appeals court litigation under the Community Reinvestment Act ("CRA") -- which is not the statute at issue here. In any event, note that New York State courts have held that ICP has standing, to seek judicial review of decisions by the New York State banking regulator. See, e.g., Inner City Press / Community on the Move v. New York State Banking Bd., 170 Misc. 2d 684, 657 N.Y.S.2d 275, 1996 N.Y. Misc. LEXIS 397, which held inter alia that

Petitioner Inner City Press meet the test [for standing]... Banking Law Section 142... sets forth certain criteria that the Banking Board must consider in determining whether or not to approve a merger application, including... 'primarily, the public interest and the needs and convenience thereof."... The court finds that petitioners have legally cognizable interests that are encompassed by such statutes... Petitioners also are the appropriate organization to represent the interests of low to moderate income predominantly minority neighborhoods... For all of these reasons, petitioners have standing to maintain this action.

  I look forward to participating in the hearing...

   And did.


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Tennessee

State Mortgage bank Regulator:

  Hard to get documents, not the height of compliance. On October 30, 2003, the proposed  "Tennessee Home Loan Protection Act" was introduced - click here (in pdf format). Previously, HB 21, the "Tennessee Predatory Lending Prevention Act," died in the Utilities and Banking Subcommittee... On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its three offices in Tennessee (Hermitage, Brentwood and Nashville)   into branches of a federal savings bank, Chase FSB, to escape state laws...

T is for Tennessee - in the Nashville TN MSA, for conventional home purchase loans, BofA in 2002 denied the applications of Latinos 5.22 times more frequently than those of whites, and denied the applications of African Americans 4.64 times more frequently than whites. For refinance loans, BofA in 2002 denied the applications of Latinos 2.47 times more frequently than those of whites, and denied the applications of African Americans 3.02 times more frequently than whites.



Return to Fair Finance Watch U.S. Map, @ Inner City Press



Texas

State Mortgage bank Regulator:
Texas Savings and Loan Department
Texas Office of Consumer Credit Commissioner

  Ground Zero of independent predators, especially in Irving.  Here's the beginning of an anti-predatory lending initiative in San Antonio.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 14 offices in Texas into branches of a federal savings bank, Chase FSB, to escape state laws. In  the Dallas MSA in 2002, CMMC denied conventional home purchase loan applications from African Americans 2.4 times more frequently than those from whites.. ICP in 2003 won a FOIA decision (click here); here's pending applications.   SB 1067 passed -- but requires an amendment to the state's constitution to become effective...

For refinance loans in the Houston TX MSA, BofA in 2002 denied the applications of Latinos 2.24 times more frequently than those of whites, and denied the applications of African Americans 2.40 times more frequently than whites.


Return to Fair Finance Watch U.S. Map, @ Inner City Press



Utah

State Mortgage bank Regulator:
Utah Department of Financial Institutions
Utah Real Estate Division

   On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its two offices in Utah (South Ogden, and 2180 S. 1300 East in Salt Lake City) into branches of a federal savings bank, Chase FSB, to escape state laws...Home of the predatory servicer Fairbanks Capital (controlled by the PMI Group - which ICP raised, see, e.g., "Financial Guaranty Insurance Co. Sale to PMI Group Sparks Protest," by Bonnie McGeer, Asset Securitization Report, September 15, 2003); bad experience with defeatist from the Utah AG's Office:

  On Jan. 10, 2003, ICP requested such records from the Utah Office of the Attorney General (the "AG's Office"). Under cover letter dated Jan. 14, 2003 (the "First Denial"), Mr. Wayne Klein of the AG's Office sent ICP certain very limited records; on Jan. 27-28, 2003, ICP faxed a letter and exhibits in response: in essence, an appeal.

  Mr. Klein's Feb. 5, 2003, letter (the "Second Denial") inter alia sought to impose fees on even the initial response, and denied access to numerous records which we believe should be released, both because they are not exempt from disclosure, and in the public interest. We are concerned that some of the withholdings are made in light of the Confidentiality provisions of the AG's Office's settlement with Household; in connection with this appeal, we ask the State Records Committee to consider whether paragraph 39 of the Consent Judgment is consistent with Utah law (including but not limited to Utah Code Ann. 63-2-201(2), which provides that "[a]ll records are public unless otherwise expressly provided by statute"), with principles of open government, or whether it should be voided or modified as contrary to public policy...

  To put this appeal in context, we note a letter by Mr. Klein, to a complainant whose name has apparently been redacted, stating inter alia that "Utah does not have laws making these practices illegal and there is no agency that oversees companies like [Household]. The Division of Consumer Protection has no authority over home loans. The Division of Real Estate has limited powers to require a license of mortgage companies, but does not regulate their practices. The Department of Financial Institutions has little authority over first mortgage loans. In sum, the legislature has not found a need to impose regulatory oversight over this industry." But see, the Salt Lake Tribune of February 10, 2003, at B3, reporting that House Bill 189, "to impose consumer-friendly restrictions on so-called 'predatory lenders' got the go-ahead Friday from House members." While the AG's Office may still technically claim that "the legislature has not found a need to impose regulatory oversight" on high-rate, allegedly predatory mortgage lenders, the knee-jerk rejection of a good-faith appeal, such as the Third Denial (and the Second Denial's attempt to begin imposing fees because Inner City Press continued to seek records regarding the AG's Office's settlement with Household), is inconsistent with law (see above), with open government and with the public interest.
For the reasons set forth in the letter and exhibits we faxed to Mr. Klein, the AG's Office's lead lawyer in the Household Settlement, on Jan. 27-28, ICP is concerned that the Household Settlement is too narrow (being limited to branch-originated real estate loans); we are additionally concerned that Household may already be violating the spirit and/or letter of the Settlement, and that HSBC might move even further in this regard.

  And they have...And HB 249  died on the vine...


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Vermont

State Mortgage bank Regulator:
Vermont Department of Banking, Insurance, Securities and Health Care Administration

  Here's an Anti-Predatory Lending bill that was introduced in the Vermont Senate, BX 230 (click here, in pdf format). SB 83 was referred to the Senate Finance Committe back on February 11, 2003...


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Virginia

State Mortgage bank Regulator:
Virginia Bureau of Financial Institutions

  Among other things,  Pat Robertson's base (click here for ICP's Report on Pat's ill-conceived proposed partnership with Bank of Scotland). Senate Bill 1103, based on recommendations by the Virginia Housing Study Commissioner, was signed by the Governor on March 16, 2003.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 12 offices in Virginia into branches of a federal savings bank, Chase FSB, to escape state laws...

  V is for Virginia - in the Richmond VA MSA, BofA for refinance loans in 2002 denied the applications of African Americans 3.19 times more frequently than whites, and denied the applications of Latinos 3.51 times more frequently than whites.


Return to Fair Finance Watch U.S. Map, @ Inner City Press



Washington

State Mortgage bank Regulator:
Washington Department of Financial Institutions

  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its ten offices in Washington State into branches of a federal savings bank, Chase FSB, to escape state laws. ICP wrote in, and the Department of Financial Institutions' legal counsel, Joe Vincent, then explained his understanding that CMMC is a subsidiary of Chase Manhattan Bank USA N.A. (actually, it isn't) -- and then stated, "I wish to express on behalf of our Director, Helen Howell, appreciation for your concerns... It is not, however, within the purview of the DFI to speculate on or officially comment on the application of CMMC to become a federal savings bank, a matter solely within the jurisdiction of the OTS and FDIC."  Ms. Howell similar prevaricated with regard to Wells Fargo...

W is for Washington State - in the Seattle WA MSA, for conventional home purchase loans, BofA in 2002 denied the applications of Latinos 2.82 times more frequently than those of whites, and denied the applications of African Americans 2.53 times more frequently than whites. For refinance loans, BofA in 2002 denied the applications of Latinos 2.82 times more frequently than those of whites, and denied the applications of African Americans 2.79 times more frequently than whites.



Return to Fair Finance Watch U.S. Map, @ Inner City Press


West Virginia

State Mortgage bank Regulator:
West Virginia Division of Banking - and W. Virginia Code

  Mountain State Justice -- the (satellite TV dish) avengers...(Click here, c/o W. Virginia Legal Services).


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Wisconsin

State Mortgage bank Regulator:
Wisconsin Department of Financial Institutions

   Another ICP venue - see, e.g., "Minorities Might Pay Cost of Firstar Merger, Group Says," by Paul Gores, Milwaukee Journal Sentinel, December 5, 2000,  Pg. 3D; "Fed Requests More Information on Banks' Minority Lending Practices," by Paul Schwab, The Business Journal of Milwaukee, December 15, 2000. On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its three offices in Wisconsin (two in Brookfield, and 4050 W. Spencer St. in Appleton) into branches of a federal savings bank, Chase FSB, to escape state laws...


Return to Fair Finance Watch U.S. Map, @ Inner City Press



Wyoming

State Mortgage bank Regulator:
Wyoming Division of Banking

ICP challenged Chase Manhattan and U.S. Trust of Wyoming, for breaking the law. Here's a long decision.


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American Samoa

State Mortgage bank Regulator:


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Guam


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Puerto Rico

State Mortgage bank Regulator:
Puerto Rico Commissioner of Financial Institutions - file complaints

  La Isla del Encanto


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U.S. Virgin Islands

Department of Licensing and Consumer Affairs



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