Updated December 5, 2005
December 5, 2005
Military personnel on
active duty are being overcharged on high interest loans by some of the
largest banks in the United States, a new investigation of compliance
with the Servicemembers’ Civil Relief Act (SCRA) by Inner City Press /
Fair Finance Watch has uncovered. Through documents obtained under the
Freedom of Information Act, ICP had documented widespread violations of
the SCRA, defrauding and overcharging of those in active military
service, and regulatory inertia in dealing with the abuses.
The nation’s largest
bank, Citigroup,
is described in consumers’ complaints as demanding original copies of
initial deployment orders, of refusing to deal by telephone with
servicemembers’ immediate relatives, and of reporting adversely to
credit agencies. HSBC
/ Household is described as seeking to narrow SCRA’s interest rate
reductions to only those “in a hostile zone,” leaving that term
undefined. Other banks most complained-of include
JP Morgan Chase,
Wells Fargo, MBNA
and Bank of America.
Regarding these last two, ICP has asked the
Federal Reserve
to collect and consider the evidence of SCRA violations before ruling on
the Bank of America – MBNA merger application.
The Servicemembers’ Civil Relief Act,
at 50 USCS Appendix Section 527(1)(a)
provides that “An obligation or liability bearing interest at a rate in
excess of 6 percent per year that is incurred by a servicemember, or the
servicemember and the servicemember's spouse jointly, before the
servicemember enters military service shall not bear interest at a rate
in excess of 6 percent per year during the period of military service.”
The purpose of the SCRA, formerly known as the Soldiers’ and Sailors’
Civil Relief Act, is to provide interest rate relief and other
protections “to servicemembers of the
United States to enable such persons to devote their entire energy to
the defense needs of the Nation.” Section 502.
The above-named banks, however,
routinely seek to deny the SCRA protections to servicemembers.
Citigroup, for example, beyond deployment orders has demanded original
enlistment papers, as reflected in this complaint to
Citigroup’s AT&T
Universal credit card unit in Jacksonville, Florida, now placed online
at
www.innercitypress.org/citiscra4.jpg
“We received your letter
telling us that you could not process [REDACTED]’s request to reduce the
Annual Percentage Rate (APR) under the Soldiers and Sailors Civil Relief
Act of 1940. We understand that you need another document to show when
exactly she enlisted in the Army. We, her husband and children,
regretfully inform you that we do not have access to any of her
documents that pertain to her military career. As she is already in
Kuwait, there is no way that she can send these documents to you until
her return home. She is not expected to return for six months to a
year.”
Using prior military service as an
excuse to maintain high interest rates despite the SCRA appears to the
strategy as other Citibank units as well, as reflected by the complaint
to Citibank’s regulator, the Office of the Comptroller of the Currency (OCC),
now online at
www.innercitypress.org/citiscra4.jpg
“I am writing in
regards to a dispute with The Associates credit card company of Citicorp
Credit Services, Inc. (USA). The dispute pertains to my eligibility to
receive the interest credit from the Sailors’ and Soldiers’ Relief Act (SSCRA)
(50 U.S. App. Sec. 526).
“I first contacted The
Associates in May of 2002. At that time I was denied enrollment. I was
told that because I originally entered the military in 1989, I was
ineligible. However, my tour of duty was over in 1993. I opened my
account with The Associates in 2000. At that time, I was a civilian and
had no intentions of signing back up with the military. Yet, in March of
2002, I entered into the US Army on full-time, active military duty. As
the law states, the SSCRA regulates the amount of interest I am to be
charged for any credit accounts I opened before entry into military
service.
"I have disputed this
matter with The Associates to no avail. I have sent them copies of my
original orders showing my current enlistment date, as well as a copy of
the law. Still I was denied. I was then forced to go to my JAG office on
base to seek legal counsel. From there I was directed to the Attorney
General’s office in Irving, TX, the headquarters for the aforementioned
party. The Attorney General’s office then put me in touch with the legal
representatives of the [REDACTED] County, where I received contact
information for the OCC Customer Assistance Group.
"The Associates have
repeatedly denied my claims based on prior service. Yet, I have found
nowhere in the law where it states this as a deciding factor. So I write
to you now, to examine the law and enforce the necessary actions. I have
enclosed all pertinent documents in regard to this matter. I have been
enrolled in a debt consolidation company, and have made payments to The
Associates monthly for the last year.”
The attachment, on
Department of the Army stationary, reflects Citigroup’s Associates
charging 12.99% interest. In April 2005, a mother wrote to the OCC, in
a letter now online now online at
www.innercitypress.org/citiscra12.jpg
“Enclosed is a copy of my son’s military orders
calling him to active duty, a copy of the affidavit designating me as
his authorized representative, and a copy of my letter to Citibank,
Sioux Falls, SD, dated 8 December, 2004. Citibank has given me all kinds
of excuses for not acting on this matter. First they wanted an affidavit
specifically addressed to them. They desisted on their request once I
explained to them that the military do not have the time and manpower to
prepare affidavits in the manner Citibank wanted. Then they told me that
my son’s active duty orders were not with the correspondence I had
mailed them. Then they said I needed to prepare a document which they
were going to mail to me; I have never received such document. Last time
I called I was told that they were still investigating!”
Another mother
complained:
…”His unit was deployed
to the Middle East. In February 2003 his fiancé and I applied to
Citibank to have his finance charges reduced under the Soldier’s and
Sailor’s Relief Act of 1940. (Account # [REDACTED]). We have supplied
Citibank with several letters of proof of my son’s service (copy of one
enclosed) with no satisfaction. We recently received a letter requesting
a “Proof of Service Letter” from Citibank. While the people at Citibank
that I have spoken with are polite and helpful, nothing has been
accomplished. Telephone calls to the customer service number are no help
as the group that handles Soldier’s and Sailor’s Act requests are in
Jacksonville, FL and can’t be reached by telephone, only by mail. I
think the enclosed letter (which Citibank already has) from the
Headquarters of II MEF should be sufficient proof of my son’s service
and that Citibank’s foot dragging is nothing more than an attempt on
their part to make the process so long and drawn out so that we will
give up as they do not want to lose the 24.24% interest that is being
paid on the account.”
Even when compliance is belatedly obtained from
Citigroup,
accounts are still turned over to collection agencies, and credit
ratings impacted, as reflected in this complaint to the FDIC, placed
online at
www.innercitypress.org/citiscra5.jpg
“My husband enlisted in
the United States Marine Corps during the recent war in Iraq. Upon the
advice of his recruiter, I requested relief from our creditors in
accordance with the Soldiers’ and Sailors’ Civil Relief Act of 1940.
Citibank finally responded and complied with the Act. However, they ALSO
have turned this account over to TWO COLLECTION AGENCIES (copy of letter
enclosed).
“I am filing a complaint
against Citibank because they are ruining our credit rating by ignoring
my requests regarding relief and selling this account to collection
agencies.”
The attached notice – even the name of the
collection agency has been redacted by the Office of the Comptroller of
the Currency – reflects a balance of $1,937.13. It begins: “This is to
advise you that Citibank (South Dakota) Na (P) has transferred your
delinquent account to our office for pre-legal collection.”
HSBC’s subprime
consumer finance units, operating under names including Household, HFC,
Beneficial and Orchard Bank, also stretch to find excuses to maintain
high interest rates contrary to the SCRA, as reflected by this sample
complaint now online at
www.innercitypress.org/hsbcscra15a.jpg and
www.innercitypress.org/hsbcscra15b.jpg
“My husband reenlisted
into the US Navy on 12/[ ]/02. I have placed all of our pre-existing
financial obligations under the Sailors and Soldiers Civil Relief Act
which sets the maximum finance charge of 6% on all of our debts. Every
one of our creditors have placed our accounts under this Act and lowered
our interest rate, except for Household Bank. Household Bank told me
that my husband’s reenlistment was only a ‘formality’ and that they are
not going to honor the Act or my request to have our account placed at
6%. They continue to charge us 15.90%.”
Contrary to the above-quoted language of the SCRA
(applying to “the period of military
service”),
HSBC’s Household came up with the novel argument, reflected in the
complaint now online at
www.innercitypress.org/hsbcscra18.jpg that the interest
rate must only be reduced if the soldier is in a “hostile zone” –
“All phone calls and
faxes from 2-26-2004 have been ignored, misplaced and denied by
Household Credit Services. One customer service rep stated that Buper
orders could not be used in accordance to the SSCRA and unless the
‘soldier was in a hostile zone, the lowering of the APR would not be
enforced.’”
Even to those in “hostile zones,” HSBC sends
bill collection notices over the Internet, as reflected in the May 2005
complaint now online at
www.innercitypress.org/hsbcscra22.jpg
“I am currently deployed
for operation Iraqi freedom serving FOB [REDACTED]. I am having a
problem with one of my creditors and am requesting assistance. I was
mobilized on October 16, 2004 and have since paid off an account with
Household Bank / Orchard Bank (same company) I had 2 accounts with them.
I have sent in my TCS orders, my mobilization orders, a letter from my
commander, my promotion orders to 1LT, and a personal memo from my
explaining my situation and specific requests according to the SSCRA.
Since then, I have sent this information 4 times to the company and they
continue to harass me via internet for payment. They tell me that I owe
$30 and form October they have charged me an inflated interest rate and
given me late fees. They actually owe me money from the 2 accounts since
they had not ever reduced my interest rates nor stopped the fees. I do
not have regular phone lines however I have a DNVT line [REDACTED] or
via email…. Your soldier in arms.”
Wells Fargo’s
practices are reflected in the complaint to the OCC now online at
www.innercitypress.org/wellsscra54.jpg
“On [ ] January 2003, my
Army Reserve Unit, the [REDACTED] received notification of mobilization
and deployment to the Persian Gulf area. Within days I received my
individual mobilization order, which specifically stated I was mobilized
in accordance with Title 10, a Presidential call up, in support of
Operation Enduring Freedom. I contacted Wells Fargo whom I had 2 home
equity accounts with, and advised of my mobilization and the fact that I
was eligible to receive a reduced interest rate of 6% on my two
outstanding home equity accounts per the Soldiers and Sailors Civil
Relief Act of 194[0]… In mid July 2003 I returned to my residence from
the Persian Gulf at which time I learned from my wife that Wells Fargo
never reduced our interest rate to 6% as is required by Federal law…”
Wells Fargo is also,
like JP Morgan Chase and Bank of America, a funder of payday lenders,
including targeters of military personnel like Armed Forces Loans.
JP Morgan Chase’s
practices, and their impact on front-line military personnel, are
reflected in the complaint now online at
www.innercitypress.org/jpmcscra47a.jpg and
www.innercitypress.org/jpmcscra47b.jpg
“I am writing you from
Baghdad, Iraq asking, once again, for Bank One to drop my interest rate
on these three cards to 6%. I have phoned in and spoken with your
customer service on two previous occasions, once in May 2004 when my
deployment began, and again in September 2004, before I actually
deployed to Iraq. Both times I was instructed by the customer service
that because the three accounts in question were for Overdraft
Protection, they did not qualify under the Soldiers and Sailors Relief
Act. This makes no sense to me, considering the accounts are clearly
operated like a credit card. I have used these accounts to complete
balance transfers, operate as a Visa credit card, and for overdraft
protection. It is clear that even though the account functions as a
credit card, Bank One is using the technicality of it being classified
as an Overdraft Protection to ensure that soldiers like me cannot
benefit from the Soldiers and Sailors Relief Act on these type of
accounts. I am asking you to please reconsider. The following three
accounts in question are as follows:
Account 1 [REDACTED]
13.99% interest
Account 2 [REDACTED]
28.99% interest
Account 3 [REDACTED]
13.99% interest
…In November 2004 my
wife, pregnant with twins, had a miscarriage due to increased stress
from the deployment and current financial burdens. She has also had to
sell my car to help meet current financial responsibilities. Right now,
in Baghdad, I am responsible for the well being of 117 soldiers.
Everyday we are facing multiple threats every time we leave the gate. In
60 days my soldiers and I have been hit by 31 roadside bombs. I,
personally, do not have the time to get involved, nor do I need to be
worrying about the bills back home.”
The purpose of the Servicemembers’
Civil Relief Act is to provide interest rate relief and other
protections “to servicemembers of the
United States to enable such persons to devote their entire energy to
the defense needs of the Nation.”
50 USCS Appendix Section 502. Given the lack of compliance with
the SCRA by the above-named largest banks and bank holding companies,
Inner City Press / Fair Finance Watch has formally petitioned for action
from both the Office of the Comptroller of the Currency and the
Federal Reserve,
including by submitted copies of complaints of SCRA violations by Bank
of America and MBNA, and demanding that they be pursued prior to any
ruling other than denial on
Bank of America’s
application to acquire MBNA. ICP will be pursuing these issues
further.
For further information, click here to contact us
* * *
A related Inner City Press text:
Rights Force
A previous report, September 2005: The Federal Reserve
has announced the availability of final and aggregate 2004 Home Mortgage
Disclosure Act data.
www.ffiec.gov/hmcrpr/hm091305.htm The Fed also put forth its spin on
the data, in the form of 51-page study by staff members Bob Avery, Glenn
Canner and Robert Cook.
www.federalreserve.gov/pubs/bulletin/2005/3-05hmda.pdf While
the prose of the Fed's study is typically dense, here's the conclusion
the Fed reaches on the final page of its study:
…”black and Hispanic
borrowers taken together are much more likely than non-Hispanic white
borrowers to obtain credit from institutions that report a higher
incidence of higher-priced loans. On the one hand, this pattern may be
benign and reflect a sorting of individuals into different market
segments by their credit characteristics. On the other hand, it may be
symptomatic of a more serious issue. Lenders that report a lower
incidence of higher-priced products may be either less willing or less
able to serve minority neighborhoods. More troubling, these patterns may
stem, at least in part, from borrowers being steered to lenders or to
loans that offer higher prices than the credit characteristics of these
borrowers warrant. Reaching accurate determinations among these
alternative possible outcomes is one goal of the supervision system.”
What the Fed doesn’t say in this is that
these disparities are most stark some of the largest conglomerates in
the country, including in their headquarters cities (where they have
Community Reinvestment Act duties). As two example, with the largest
bank and thrift in the United States:
Citigroup in the
New York City Metropolitan Statistical Area in 2004 confined African
Americans seven times more frequently than whites to higher cost, rate
spread loans. The largest savings bank in the country,
Washington Mutual,
confined African American couples to high cost loans 4.5 times more
frequently than white couples, on nationwide basis. How could such
patterns be plausibly described as “benign” or as reflecting “a sorting
of individuals into different market segments”?
Where the rubber will meet the road will be in
how the Federal Reserve and other agencies act on specific disparities
at specific lenders, including as these are formally raised to them in
timely comments on merger applications. See, Inner City Press / Fair
Finance Watch's other studies of the 2004 HMDA
data: first second third fourth fifth. For or
with more information, contact us.
May 9, 2005
Inner City Press / Fair Finance Watch Completes
Analysis, by Gender as well as Race and Ethnicity, of Ten Large Lenders’ Mortgage
Disparities
May 9 -- ICP has
now comprehensively reviewed the 2004 Home Mortgage Disclosure Act data of the ten largest
lenders, by gender as well as race and ethnicity. ICP has compared each of these,
including not only denial rates but also the new information concerning which loans are
subject to a rate spread (3% higher than comparable Treasuries on a first lien, and 5% on
a subordinated lien, below referred to as subprime or high cost loans), and has found the
following:
At Washington Mutual, African American men were confined to high cost
loans 3.34 times more frequently than white men -- the largest disparity for this
comparison.
At Royal Bank of Canada / Centura, African American women were
confined to high cost loans 4.52 times more frequently than white men -- the largest
disparity. Wells Fargo was second most disparate to African American women, confining them
to high cost loans 4.31 times more frequently than white men.
At Bank of America, Hispanic men were confined to high cost loans
2.10 times more frequently than white men. White women were confined to high cost loans
2.04 times more frequently than white men -- the largest disparity for this comparison.
Again at Washington Mutual, Hispanic women were confined to high cost
loans 2.53 times more frequently than white men -- the largest disparity for this
comparison.
At Citigroup, for home purchase loans, African American
women were confined to high cost loans 4.06 times more frequently than white men. Hispanic
men were confined to high cost loans 2.15 times more frequently than white men; at Wells
Fargo, the disparity between Hispanic and white men was 1.78.
ICP has also provided evidence of
Citigroup’s violation of its commitment to have stopped, from January 2003
onward, making loans covered by the Home Ownership and Equity Protection Act of 1994
(eight full percent over Treasuries on a first lien mortgage, ten percent over Treasuries
on a subordinate lien). In the 2004 data, ICP
found that Citigroup reported fully 837 HOEPA loans. ICP
raised this to Citigroup’s senior management at the April 19 shareholders’
meeting at Carnegie Hall in Manhattan. Neither Citigroup chairman Sandy Weill nor CEO
Charles Prince would directly answer the question. Citigroup chief operating officer
Robert Willumstad directly denied that Citigroup had reported HOEPA loans in its 2004
data. Finally,
the New York Times of May 4, 2005, reported that “Citigroup lenders made
hundreds of high-cost home loans to customers with poor credit histories in 2004, even
though the company had adopted a policy a year earlier to no longer issue such loans, the
bank acknowledged yesterday.” ICP has now submitted
the specifics of Citigroup’s 837 HOEPA loans to the attorneys general in the states
in which these super high cost loans were made. See, www.innercitypress.org/citi.html
“The
largest bank is also the most duplicitous,” said ICP’s executive director
Matthew Lee. “Predatory and discriminatory lending are central to Citigroup’s
compliance problems, and we have asked for enforcement actions in more than twenty five
states.”
Regarding
Wells Fargo, ICP has received more and more complaints about Wells Fargo, including about
Wells’ stealth America’s Servicing Company unit. Wells Fargo is also a major
funder of payday lenders, including targeters of military personnel like Armed Forces
Loans. ICP has raised this directly to Wells Fargo, and to the Federal Reserve on Wells’
proposal to acquire First Community Capital Corp., which was announced back on September
2, was challenged by ICP on November 1, and which still remains pending, more than five
months later.
Regarding HSBC,
ICP’s filings with the states have also asked them to expand their $486 million
predatory lending enforcement action against HSBC / Household International to cover HSBC’s
Decision One unit, which made more subprime loans in 2004 than either HFC or Beneficial,
which are covered by the states’ settlement. ICP
has asked the attorneys general in more than thirty states to reopen their $486 million
predatory lending settlement with Household, and for example to make sure that it expands
to cover and require reforms from Household’s, now HSBC’s, Decision One subprime
lending unit.
ICP has also
now analyzed, because of the disparities identified above, the nationwide lending of he
Royal Bank of Canada:
Whites: 74,387
applications, leading to 5740 denials (7.72% denied) and 58,173
originations; 1971 [or 1.84 percent] exceeded rate spread.
African Americans: 4767 applications, leading to 612 denials (12.84% denied, 1.66
times higher than whites) and 3451 originations; 255 [or
7.39 percent] were at rate spread [3.99 times higher / more likely to be over rate spread
than whites].
Latinos: 8376 applications, leading to 870 denials (10.39% denied, 1.35 times
higher than whites) and 6105 originations; 163 [or 2.67
percent] at rate spread [1.45 times higher / more likely to be over rate spread than
whites].
ICP’s Matthew Lee said, “Royal Bank of
Canada bungled into buying Centura Bank, then a mortgage company based in Illinois, but
now runs both of them in a clearly disparate fashion.”
ICP has also
produced and submitted upon request to to New York State elected prosecutorial officials a
list of the largest subprime lenders in New York State, including among others New
Century, H&R Block / Option One, American Home Mortgage as well as the belownamed,
KeyCorp and other banks. Number one on the list is Ameriquest. ICP has also specifically
analyzed Ameriquest’s lending to Native Americans. Ameriquest confined over sixty
percent of Native American home purchase borrowers to higher cost subprime loans.
The
fact that Ameriquest, the increasingly discredited subprime lender admittedly under
investigation by twenty five states, in 2004 made the most loans to African Africans, both
over the high cost rate spread and overall, is a reflection of a two-tier financial
system, one which is separate and unequal, including as to interest rate. We have asked
for more than twenty five states to take action on Ameriquest.”
ICP has provide
this and other analysis to the regulators and state attorneys general, demanding
investigation and action. ICP has also requested action, from federal regulators and now
fifty state attorneys general, on lenders who have refused to provide data, and who
otherwise enable predatory lenders: Royal Bank of Scotland
and other subprime facilitators and securitizers (as reported in the London Sunday Times
of May 1), Lehman Brothers, Fifth Third, Delta Funding and AIG / American General (these
four and others have refused to provide their data in analyzable form), as well as Fremont
Investment and Loan, which is trying to require ICP to sign a confidentiality agreement to
view its public data. ICP has refused, and has filed complaints.
Methodology, Scope of Review
and Results
ICP Fair Finance
Watch reviewed the 2004 mortgage records (defined by the gender and race / ethnicity of
the primary applicant) of the above-named lenders, including the top five banks:
Citigroup
White men: 169,992 originations of which 37,974 (or 22.34%) were at
rate spread
White women: 67,291
originations of which 21,689 (or 32.23%) exceeded the rate spread (1.44 times higher /
more likely to be rate spread than white men)
African American men: 16,512 originations of which 8499 (or 51.47%)
exceeded the rate spread (2.30 times higher / more likely to be rate spread than white
men)
African American women: 16,116 originations of which 9099 (or 56.46%)
exceeded the rate spread (2.53 times higher / more likely to be rate spread than white
men)
Hispanic men: 22,757 originations of which 7393 (or 32.25%) exceeded
the rate spread (1.44 times higher / more likely to be rate spread than white men)
Hispanic women: 9241 originations of which 3649 (or 39.49%) exceeded
the rate spread (1.77 times higher / more likely to be rate spread than white men)
JP Morgan Chase
White men: 241,337 originations of which 12,594 (or 5.22%) were at
rate spread
White women: 92,764 originations of which 6899 (or 7.44%) exceeded
the rate spread (1.43 times higher / more likely to be rate spread than white men)
African American men: 16,654 originations of which 2306 (or 13.85%)
exceeded the rate spread (2.65 times higher / more likely to be rate spread than white
men)
African American women: 14,684 originations of which 2263 (or 15.41%)
exceeded the rate spread (2.95 times higher / more likely to be rate spread than white
men)
Hispanic men: 32,669 originations of which 2188 (or 6.70%) exceeded
the rate spread (1.28 times higher / more likely to be rate spread than white men)
Hispanic women: 13,490 originations of which 1021 (or 7.57%) exceeded
the rate spread (1.45 times higher / more likely to be rate spread than white men)
Bank of America
White men: 270,5012 originations of which 4854 (or 1.79%) were at
rate spread
White women: 110,816 originations of which 2259 (or 2.04%) exceeded
the rate spread (1.14 times higher / more likely to be rate spread than white men)
African American men: 15,843 originations of which 588 (or 3.71%)
exceeded the rate spread (2.07 times higher / more likely to be rate spread than white
men)
African American women: 14,352 originations of which 561 (or 3.91%)
exceeded the rate spread (2.18 times higher / more likely to be rate spread than white
men)
Hispanic men: 49,884 originations of which 1875 (or 3.76%) exceeded
the rate spread (2.10 times higher / more likely to be rate spread than white men)
Hispanic women: 18,598 originations of which 783 (or 4.21%) exceeded
the rate spread (2.35 times higher / more likely to be rate spread than white men)
Wells Fargo
White men: 554,755 originations of which 36,012 (or 6.49%) were at
rate spread
White women: 196,396 originations of which 21,514 (or 10.95%)
exceeded the rate spread (1.69 times higher / more likely to be rate spread than white
men)
African American men: 29,858 originations of which 6357 (or 21.29%)
exceeded the rate spread (3.28 times higher / more likely to be rate spread than white
men)
African American women: 25,278 originations of which 7067 (or 27.96%)
exceeded the rate spread (4.31 times higher / more likely to be rate spread than white
men)
Hispanic men: 55.126 originations of which 5763 (or 10.45%) exceeded
the rate spread (1.61 times higher / more likely to be rate spread than white men)
Hispanic women: 19,276 originations of which 2843 (or 14.75%)
exceeded the rate spread (2.27 times higher / more likely to be rate spread than white
men)
Wachovia
White men: 92,209 originations of which 3428 (or 3.72%) were at rate
spread
White women: 36,684 originations of which 1806 (or 4.92%) exceeded
the rate spread (1.32 times higher / more likely to be rate spread than white men)
African American men: 9011 originations of which 926 (or 10.28%)
exceeded the rate spread (2.76 times higher / more likely to be rate spread than white
men)
African American women: 7912 originations of which 827 (or 10.45%)
exceeded the rate spread (2.81 times higher / more likely to be rate spread than white
men)
Hispanic men: 7400 originations of which 390 (or 5.27%) exceeded the
rate spread (1.42 times higher / more likely to be rate spread than white men)
Hispanic women: 3462 originations of which 253 (or 7.31%) exceeded
the rate spread (1.97 times higher / more likely to be rate spread than white men)
Beyond its
filings with fifty state attorneys general, ICP is also commenting to, and also litigating
Freedom of Information Act issues against, federal agencies like the Federal Reserve
Board, in connection with Wachovia’s support of payday lenders and other fringe
financial institutions, see, e.g., Dow Jones of
October 25, 2004, “Community Group: Fed Must Reconsider Wachovia-SouthTrust”).
ICP's book on these topics, "Predatory Bender"
CL
Review order / Amazon
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