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Public Meeting Transcripts

Public Meeting Regarding Banc One and First Chicago

Thursday, August 13, 1998

Transcript of Panel Twelve

 
         10       MR. BROMLEY:  My name is Charles Bromley.  I'm
 
         11   the Director of a statewide fair housing
 
         12   organization called Metropolitan Strategy Group
 
         13   based in Cleveland, Ohio.  I also serve as the
 
         14   Chair for the Ohio Community Reinvestment Project,
 
         15   a statewide coalition of community-based
 
         16   organizations committed to fair lending throughout
 
         17   the State of Ohio.
 
         18            Because a picture is worth a thousand
 
         19   words and I've been allocated five minutes, I've
 
         20   prepared some pictures that outline a snapshot of
 
         21   the lending behavior of Banc One and its affiliates
 
         22   in the State of Ohio.
 
         23            Let me first review Banc One's behavior in
 
         24   an area where they are ranked as a very large
 
 
 
 
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          1   volume lender, which is small business lending.
 
          2   They are third in the country.
 
          3            According to Ken Stevens, who is the head
 
          4   of this unit or retail lending, I guess it is, a
 
          5   small business customer doesn't care where the
 
          6   corporate headquarters are.  What they care about
 
          7   is local execution, are they doing a job for me, is
 
          8   my relationship manager serving my needs?
 
          9            Apparently, Mr. Stevens forgot to review
 
         10   his small business lending record with Blacks in
 
         11   greater Cleveland.
 
         12            Let me look at some of the statistical
 
         13   data in our first chart, which in theory -- the
 
         14   A.V. crew, if I remember them from junior high,
 
         15   always had problems.  Apparently, as adults, we are
 
         16   still struggling with this equipment.  Maybe
 
         17   eventually we'll get it right.  I don't know.
 
         18            But what you see here in terms of the
 
         19   picture of their lending in census tracts, this is
 
         20   the census tracts of greater Cleveland.  There are
 
         21   685 census tracts.  There are 185 census tracts
 
         22   that have a minority population of 50 percent or
 
         23   more.  The percent of tracts with no Banc One small
 
         24   business loans is 68 percent, nearly 70 percent,
 
 
 
 
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          1   and census tracts that are under ten percent
 
          2   minority, in other words, predominantly white, they
 
          3   have a percent of tracts with no Banc One loans of
 
          4   38.58.
 
          5            Now, when you look at the issue of the
 
          6   next chart which looks at stratification by income,
 
          7   and the percent of tracts with no Banc One loans is
 
          8   65.22.  As you go to the upper income part of the
 
          9   chart, you'll see it's 39.86.
 
         10            So this is a bank that has an affinity for
 
         11   wealthy, white census tracts in terms of their
 
         12   small business lending.  There is no question about
 
         13   that pattern as it occurs in greater Cleveland.
 
         14            Now, we mapped this data so you can see
 
         15   it, which should be the next -- I don't know if
 
         16   we're on the wrong -- okay.  Stop.  Okay.  There
 
         17   you go.  That's fine.
 
         18            This is the map of our standard
 
         19   Metropolitan statistical area.  In the middle of
 
         20   the map, there is kind of like a county, and you
 
         21   can't really see it, but it's the white area, and
 
         22   that's the area where there are no small business
 
         23   loans.
 
         24            Cuyahoga County has the largest percentage
 
 
 
 
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          1   of minorities in that statistical area.  The area
 
          2   that is predominantly blue is the area that is all
 
          3   white.  So you get a sense of where their small
 
          4   business lending is and also where it's not.
 
          5            Next.
 
          6            Now, that's just a highlight of Cuyahoga
 
          7   County.  So you can see specifically that in
 
          8   addition to red lining in Cuyahoga County, they
 
          9   also red line the first ring suburbs, which is
 
         10   those integrated communities, that which is closest
 
         11   to the City of Cleveland.  I hope a picture really
 
         12   does tell you something.
 
         13            It's difficult with small business lending
 
         14   because you don't know how many loans per tract.
 
         15   All you know is whether they made one or they could
 
         16   have made a dozen.  You do know where they made
 
         17   none.  So we do have that data there.
 
         18            Next.
 
         19            This is much less clear, I guess, in terms
 
         20   of coming out.  This is the data for Cuyahoga
 
         21   County, and the screen on this is low to moderate
 
         22   income tracts.  And you can see there's a strong
 
         23   correlation between the tracts and where their
 
         24   loans are.
 
 
 
 
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          1            I realize I have one minute left.  Maybe
 
          2   we can flip here to Toledo.
 
          3            It's hard to see, but in the stuff here,
 
          4   you can see this is their market share.  Their
 
          5   large product that they have in Ohio is home
 
          6   improvement lending, and as you go into the
 
          7   minority tracts, you find two things:  One, the
 
          8   lack of applications and, two, their market share
 
          9   shrinks to zero.  This is their major product.
 
         10   They seem to have an affinity to stay away from
 
         11   those neighborhoods.
 
         12            The last one is Cincinnati, and you can
 
         13   see the same pattern is seen there where their
 
         14   applications are very low in minority census
 
         15   tracts, and you can see that their market share is
 
         16   very low in those census tracts and very high in
 
         17   those other tracts.
 
         18            I've included in my testimony -- I just
 
         19   want to take 30 seconds.
 
         20            We have taken our testimony, we have
 
         21   turned it over to the Assistant Attorney General
 
         22   for Civil Rights at the Department of Justice.  We
 
         23   hope that they will give a thorough review.
 
         24            We believe there are serious fair lending
 
 
 
 
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          1   issues relative to Banc One in the State of Ohio.
 
          2            And before the Federal Reserve Bank acts
 
          3   on this merger, the Department of Justice should be
 
          4   given the opportunity to completely review the fair
 
          5   lending record of Banc One in the State of Ohio.
 
          6            Thank you so much.
 
          7       MS. SMITH:  Mr. McDermitt.
 
          8       MR. McDERMITT:  Good afternoon.  My name is
 
          9   Matt McDermitt.  I'm a Policy Specialist with the
 
         10   Chicago Coalition for the Homeless.
 
         11            The Coalition is a 17-year-old advocacy
 
         12   organization focusing on the root causes of
 
         13   homelessness and working to find permanent
 
         14   solutions to the problem.
 
         15            The Coalition has nearly 15,000 members in
 
         16   the greater Chicago area and nearly 800
 
         17   organizational members, shelters, churches and
 
         18   other organizations serving the homeless.
 
         19            The Coalition has very serious concerns
 
         20   about the proposed merger between Banc One and
 
         21   First Chicago NBD.
 
         22            We understand that Banc One has a very
 
         23   poor CRA record and a wavering commitment to the
 
         24   very important mortgage lending business, very
 
 
 
 
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          1   important to the housing market.
 
          2            In addition, Banc One has refused to
 
          3   negotiate directly with community groups and
 
          4   coalitions.  While they maintain all agreements
 
          5   made by other parties to the merger will be
 
          6   honored, there is unfortunately no guarantee of
 
          7   that.
 
          8            All three parties related to the merger,
 
          9   Banc One, First Chicago and NBD, also have less
 
         10   than admirable records of lending in African
 
         11   American and Latino communities.
 
         12            These shortcomings by major market
 
         13   institutions seeking to increase their market
 
         14   dominance have tragic consequences.
 
         15            The lack of capital in many communities --
 
         16   the lack of capital in many communities prevents
 
         17   the creation of new housing and new employment
 
         18   opportunities.
 
         19            While many of these potential
 
         20   opportunities might not directly be available to
 
         21   the people I represent, the absence of -- excuse me
 
         22    -- their absence is the beginning of a spiral that
 
         23   winds up impacting the poorest members of our
 
         24   communities, those who we don't often think of when
 
 
 
 
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          1   we think about banks, but homeless people.
 
          2            Because bank capital is not available to
 
          3   create these opportunities, we increasingly see a
 
          4   reliance on government funding for housing and job
 
          5   creation for middle and moderate income folks.
 
          6            This demand on government resources,
 
          7   usually a successful demand over those needs of
 
          8   very low income folks, truly -- I'm sorry.  Lost my
 
          9   place here.
 
         10            This demand on government resources
 
         11   competes against funding for projects for very low
 
         12   income and homeless people which truly cannot be
 
         13   served by market institutions like banks.
 
         14            With 80,000 homeless people in Chicago
 
         15   every year and more children among them every year,
 
         16   we have an average age of homeless people in
 
         17   Chicago and across the nation now of only nine
 
         18   years old.  Because we have so many children in the
 
         19   population today, we must have greater commitment
 
         20   from our banks to serve the entire community rather
 
         21   than profiting from creating more disparities in
 
         22   our country.  If we do not, the results will be
 
         23   even greater tragedy in the next generation.
 
         24            For this reason, the coalition opposes the
 
 
 
 
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          1   Banc One/First Chicago merger until all parties
 
          2   make direct community investment commitments.
 
          3            Thank you very much.
 
          4       MS. SMITH:  Thank you.
 
          5            I'm going to let you say your own name.
 
          6       MR. GIERUT:  My name is Father Casimir Gierut.
 
          7            As a consumer seeking banking services, I
 
          8   strongly oppose the proposal by Banc One
 
          9   Corporation to merge with First Chicago Corporation
 
         10   for the following reasons:  First, the merger will
 
         11   destroy competition between the two banks.
 
         12            Competition is a financial asset in the
 
         13   favor of all consumers.  We have the opportunity to
 
         14   compare different interest rates offered by the two
 
         15   banks.  The final decision is in our favor to
 
         16   accept a bank offering a higher interest rate in
 
         17   reference to the purchase of a Certificate of
 
         18   Deposit or to accept a bank offering the lowest
 
         19   interest rate toward a loan.
 
         20            This merger will force the consumer to
 
         21   deal only with one mega bank.  Our freedom to
 
         22   choose the other bank will be gone.  There will be
 
         23   no alternative but to accept whatever interest
 
         24   rates the bank wishes to offer to the public.  That
 
 
 
 
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          1   is not the right way to do business in a
 
          2   capitalistic society.
 
          3            To possess financial power at the hands of
 
          4   few bankers as a byproduct of merging banks into
 
          5   mega banks is to be feared.
 
          6            Secondly, I oppose the merger of Banc One
 
          7   with First Chicago because it will become a huge
 
          8   monopoly.
 
          9            The United States Attorney General, Janet
 
         10   Reno, should file suit, an antitrust suit, against
 
         11   this merger to stop this becoming the biggest
 
         12   monopoly in the United States.
 
         13            Banks are not an agency of the Federal
 
         14   Government which will exempt them from any
 
         15   antitrust laws.  Banks are privately-owned
 
         16   financial institutions.  The title corporation and
 
         17   the name following Banc One Corporation tells us it
 
         18   is a private corporation.  The title again
 
         19   corporation in the name following First Chicago
 
         20   corporation tells us again that this is a private
 
         21   corporation.
 
         22            It is not fair nor just to file an
 
         23   antitrust suit against Bill Gates' Microsoft
 
         24   Corporation merging with another giant computer
 
 
 
 
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          1   corporation because the merger is considered to be
 
          2   a monopoly and not applying the same antitrust suit
 
          3   against Banc One and the First Chicago which
 
          4   obviously is a monopoly.
 
          5            Justice is not served equally in the
 
          6   application of the antitrust laws to private
 
          7   corporations.  To allow Banc One and First Chicago
 
          8   to merge into a monopoly is unlawful, illegal and
 
          9   contrary to the antitrust laws.
 
         10            Thirdly, the mergers are not made for the
 
         11   good of consumers.  The bottom line is how much
 
         12   profit is made for the good of the bank, and this
 
         13   leads to greediness.
 
         14            I recall standing in line to open an
 
         15   account at the First Chicago.  As many tellers
 
         16   there are accounts for so many long lines of people
 
         17   standing patiently to be assisted by the teller.
 
         18   Instead of First Chicago being pleased to see long
 
         19   lines of people, the greedy bank decided to charge
 
         20   a fee of three dollars for a teller's assistance.
 
         21            I heard many complain that the three
 
         22   dollars may be a fee in the mind of the banker, but
 
         23   I call the three dollars an act of extortion.
 
         24   Either you turn over three dollars or you will not
 
 
 
 
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          1   be served by the teller.  Such a procedure is
 
          2   extortion and unacceptable in the lawful business
 
          3   world of finance.
 
          4            Lastly and the most important reason why I
 
          5   oppose the merger of Banc One with First Chicago is
 
          6   that this kind of a merger decreases the existence
 
          7   of any growth of banking.
 
          8            In the year 1985, there were 14,480
 
          9   banks.  Today, the year of 1998, the number of
 
         10   banks has dwindled down to 9,435 banks and
 
         11   decreasing in number with each new merger.
 
         12            For the power to be vested in the hands of
 
         13   a few bank presidents and bank directors is
 
         14   contrary to principles of capitalism which is the
 
         15   way of life for 231 million Americans.
 
         16            I want to quote Robert Hamphil, the former
 
         17   credit manager of the Federal Reserve Bank of
 
         18   Atlanta, Georgia, who said:  "We are completely
 
         19   dependent on commercial banks.  If the banks create
 
         20   ample supply of money, we are prosperous.  If they
 
         21   don't, we starve.  The banking problem is so
 
         22   important that our present civilization may
 
         23   collapse banking unless it is wisely understood and
 
         24   the defects remedied very soon."
 
 
 
 
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          1            Merging of banks is one of those defects
 
          2   will bring about a new kind of slavery.  Financial
 
          3   dominance in the hands of a few will create a
 
          4   financial enslavement of people and civilization.
 
          5            And this is why I oppose the merging of
 
          6   Banc One with First Chicago.
 
          7            Thank you.
 
          8       MS. SMITH:  Thank you very much for your
 
          9   comments.
 
         10            We'll go to Mr. Kamp.
 
         11       MR. KAMP:  On behalf of the Wisconsin Rural
 
         12   Development Center, I would like to thank the
 
         13   Federal Reserve Board for the opportunity to speak
 
         14   with you on the proposed merger of First Chicago
 
         15   and Banc One.
 
         16            We are a 300-member statewide community
 
         17   organization which has worked with family farmers
 
         18   and rural small businesses for over 15 years.
 
         19            Our mission is to support family farm
 
         20   agriculture, rural development and enhance economic
 
         21   opportunities for rural residents throughout the
 
         22   state.
 
         23            Our organization previously submitted
 
         24   formal comments on this application.  Specific
 
 
 
 
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          1   concerns cited in those comments included Banc
 
          2   One's low-level of originations to low and moderate
 
          3   income conventional home buyers, its lack of
 
          4   participation in state and federal guaranteed
 
          5   programs designed to assist LMI first-time home
 
          6   buyers, small farms and small businesses, its
 
          7   systematic targeting of loans to upper income
 
          8   borrowers and consequently the bank's disinvestment
 
          9   in low income and underserved rural communities.
 
         10            An analysis of 1997 HMDA and CRA aggregate
 
         11   data shows that Banc One continued to make
 
         12   significant cuts in conventional home ownership and
 
         13   small business originations in our state.
 
         14            Based on deposit share, Banc One is the
 
         15   third largest commercial institution in Wisconsin.
 
         16   Clearly, how it conducts its business and meets
 
         17   reinvestment obligations has a substantial impact
 
         18   on our state's economy and the communities it
 
         19   serves.
 
         20            Changes in lending policies and practices
 
         21   can often have devastating consequences, especially
 
         22   for a state's poor.
 
         23            According to 1997 data, these changes are
 
         24   beginning to occur.  Nationally, Banc One is the
 
 
 
 
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          1   second largest home mortgage lender.  However,
 
          2   fewer than two percent of all conventional home
 
          3   mortgages are originated by Banc One in our state,
 
          4   and that share appears to be declining.
 
          5            Between 1996 and 1997, conventional home
 
          6   ownership dropped by over 35 percent.  At the same
 
          7   time, loans to LMI borrowers were cut by nearly 43
 
          8   percent.
 
          9            In six of the seven MSAs which we looked
 
         10   at, LMI borrowers consistently received a
 
         11   disproportionately low share of one to four family
 
         12   conventional home mortgages while upper income
 
         13   borrowers consistently exceeded MSA share averages.
 
         14            Banc One also accounts for significant
 
         15   business lending in the state.  The bank is the
 
         16   third largest business lender in Wisconsin with 2.8
 
         17   billion in loans outstanding.  However, according
 
         18   to FFIEC small business data, substantial cuts were
 
         19   also reported in 1997.  Business originations
 
         20   declined by nearly 21 percent, over $90 million
 
         21   from the previous year.  Over one-third of those
 
         22   cuts were to businesses with gross revenues of less
 
         23   than one million.
 
         24            Although numerous studies have stressed
 
 
 
 
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          1   the need for small business development in the
 
          2   state, fewer than 49 percent of all loan numbers
 
          3   and 38 percent of all dollar amounts went to
 
          4   businesses with gross revenues of under
 
          5   $1 million.
 
          6            Of particular concern is Banc One's
 
          7   minimal use of state and federal guaranteed
 
          8   programs which are designed to serve the needs of
 
          9   LMI borrowers.  In 1997, less than eight percent of
 
         10   all conventional home loans were guaranteed under
 
         11   the Wisconsin Housing and Economic Development
 
         12   Authority's Home Ownership Mortgage Program, the
 
         13   WHEDA Home Program.
 
         14            Banc One's assessment areas include 11
 
         15   rural counties.  Deposits within these assessment
 
         16   areas represent 60 percent or 738 million of all
 
         17   Banc One deposits in the state.
 
         18            In our initial comments, we criticized the
 
         19   bank's low-level of lending in rural areas,
 
         20   specifically regarding small farm originations.
 
         21            In their written response, Mr. Steven
 
         22   Bennett and Ms. Julie Johnson stated that Banc One
 
         23   serves a predominantly urban market and they
 
         24   implied are under no obligation to meet all the
 
 
 
 
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          1   credit needs within rural areas.
 
          2            However, we believe this attitude raises
 
          3   serious questions about the bank's lack of
 
          4   commitment in meeting the convenience and needs of
 
          5   communities they are supposed to serve.
 
          6            Are we done?  30 seconds.
 
          7            Simply, a bank cannot ignore credit needs
 
          8   within its delineated area and then originate the
 
          9   same type of loan in other more affluent
 
         10   nonassessment areas.  However, according to the
 
         11   1997 FFIAC small farm data, over 21 percent of all
 
         12   farm loan numbers and 23 percent of all dollar
 
         13   amounts were originated outside of delineated
 
         14   assessment areas.  The eight highest income rural
 
         15   counties in the state received 78 percent of all
 
         16   Banc One small farm originations.
 
         17            In rural Wisconsin, the percentage of low
 
         18   income families often exceeds rates found in
 
         19   central cities.  Clearly, a need exists, however,
 
         20   the bank's use of federal and state programs is
 
         21   minimal.
 
         22            Based on Banc One's CRA performance in
 
         23   Wisconsin, we request that the Board of Governors
 
         24   deny the proposed merger until the bank can take
 
 
 
 
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          1   affirmative steps to address the deficiencies cited
 
          2   above.
 
          3            Thank you.
 
          4       MS. SMITH:  Thank you very much.
 
          5            Mr. VanTol is wearing a different hat.
 
          6       MR. VANTOL:  Yes.
 
          7            I want to thank you for allowing me to
 
          8   double dip here.  Now I get to speak my own piece
 
          9   instead of that of a coalition.
 
         10            My name is Hubert VanTol of Sparta,
 
         11   Wisconsin.  I am the President of Bank Watchers.
 
         12   We provide information and other services for
 
         13   community-based organizations on banking and
 
         14   community reinvestment issues.
 
         15            As I said, in speaking for John Taylor, I
 
         16   also serve as a board member of the National
 
         17   Community Reinvestment Coalition.
 
         18            I agree with most of the issues that have
 
         19   been raised about Banc One's deficient CRA record,
 
         20   and since I can't possibly do justice to those many
 
         21   complex issues in this short time, I'm going to
 
         22   focus just on the one issue of how CRA gets
 
         23   interpreted for rural areas.
 
         24            My colleague, Marv Kamp, has outlined some
 
 
 
 
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          1   of the concerns about how Banc One provides
 
          2   services and loans to rural Wisconsin.  I think his
 
          3   comments highlight the importance of the Federal
 
          4   Reserve giving more careful thought than it has in
 
          5   the past to how the Community Reinvestment Act
 
          6   should be enforced in rural areas.
 
          7            With mega mergers like these happening,
 
          8   they're transforming the shape of the banking
 
          9   industry, and it's very important that we think
 
         10   these issues through better.
 
         11            What does providing fair access to credit
 
         12   in rural America mean for huge institutions that
 
         13   are buying up the branches and the ability to
 
         14   provide services in suburban and in some cases
 
         15   inner city markets but are leaving the rural
 
         16   counties and particularly the lower income rural
 
         17   counties that span the areas between those urban
 
         18   areas completely out of the picture?
 
         19            You've heard that Banc One is providing
 
         20   agricultural loans at a much higher rate in some of
 
         21   the wealthier rural counties of Wisconsin than in
 
         22   the poorer ones, and you've heard that they've
 
         23   closed a number of rural branches in Ohio.
 
         24            In the enforcement of CRA, what is the
 
 
 
 
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          1   practical difference between an urban bank which
 
          2   draws a bright red line around the low to moderate
 
          3   income census tract in its local assessment area
 
          4   and says it won't provide services and loans within
 
          5   that area and a super regional bank like Banc One
 
          6   which draws an invisible line around the poorest
 
          7   rural counties in the several states that it
 
          8   operates in and then closes branches, does away
 
          9   with services, makes very little proactive effort
 
         10   to meet the credit needs of the residents of those
 
         11   areas?
 
         12            I live in a moderate income section of a
 
         13   rural Wisconsin, and we are seeing the same results
 
         14   of disinvestment that low income inner city
 
         15   neighborhoods have seen for a long time.
 
         16            The subprime and predatory lenders have
 
         17   started opening up shop.  It's becoming harder to
 
         18   get loans with a fair rate.  Indeed, it's becoming
 
         19   harder to get fair rates on related financial
 
         20   services like property insurance.
 
         21            This is happening because the largest
 
         22   institutions have decided that they can make more
 
         23   money meeting the credit needs of wealthy
 
         24   communities or putting money into derivatives or
 
 
 
 
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          1   whatever the current hot money fad is than they can
 
          2   make in communities like ours.
 
          3            It's not that they can't make money in our
 
          4   communities.  They just can't make enough to please
 
          5   Wall Street.
 
          6            As a result, we still have competition in
 
          7   financial services in our communities but not the
 
          8   kind of competition that middle and upper income
 
          9   suburbanites can count on.
 
         10            We have the competition between the very
 
         11   smallest financial institutions, the
 
         12   semi-legitimate, subprime lenders and the loan
 
         13   sharks, but if the Community Reinvestment Act were
 
         14   enforced with rural communities in mind, we could
 
         15   enjoy the same fruits of real competition in the
 
         16   same way that suburbanites do.
 
         17            I think the testimonies of the various
 
         18   people have given you a clear picture of different
 
         19   ways in which community reinvestment needs can be
 
         20   met, the very promising road we can do down, the
 
         21   Chicago and Detroit road, or the negative road that
 
         22   some of the other communities have testified to.
 
         23            So if this mega merger provides for
 
         24   specific agreements with measurable and reasonable
 
 
 
 
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          1   targets similar to what the Chicago Reinvestment
 
          2   Coalition negotiated with First Chicago for each of
 
          3   the urban and rural sections of the state, most of
 
          4   us wouldn't be here today.  Most of my colleagues,
 
          5   I'm sure, would watch such a merger happen without
 
          6   the outrage that we feel now.
 
          7            In this case, however, it seems clear what
 
          8   the dominant philosophy that survives in the
 
          9   surviving bank will be.
 
         10            So we ask you to go ahead and make our
 
         11   day, surprise us and do the right thing.
 
         12       MS. SMITH:  Thank you very much.  Thank you
 
         13   very much for coming.
 
         14       MR. ALVAREZ:  Can I ask a quick question?  I am
 
         15   sorry.
 
         16            Mr. Kamp, and Mr. Bromely in particular,
 
         17   you had further remarks than the time allowed and
 
         18   you had a lot of statistics.  Are all of these
 
         19   statistics in your packages and explained in the
 
         20   material?
 
         21       MR. KAMP:  Yes.
 
         22       MR. ALVAREZ:  And the numbers that you put
 
         23   together for your comparisons of loans in low to
 
         24   moderate income neighborhoods versus other areas,
 
 
 
 
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                         McCORKLE COURT REPORTERS, INC.
                       CHICAGO, ILLINOIS - (312) 263-0052
  
 
 
 
          1   is that based on number of loans or dollar amounts
 
          2   or --
 
          3       MR. KAMP:  For my analysis, both number and
 
          4   dollar.
 
          5       MR. BROMLEY:  We had numbers.
 
          6       MR. ALVAREZ:  And you used the numbers?
 
          7       MR. BROMLEY:  Yes.
 
          8            And ours, the home improvement lending was
 
          9   aggregated.  We rolled up all the Banc Ones in Ohio
 
         10   and made one master file.  So they have a number of
 
         11   Banc Ones, and we put them all together.  I think
 
         12   corporately, they rounded them up in
 
         13   '97 so you can see it, and it's applications and
 
         14   then it's market share.
 
         15       MR. ALVAREZ:  Thank you very much.
 
         16       MR. KAMP:  Market share is also.
 
         17       MR. ALVAREZ:  Okay.
 
         18       MS. SMITH:  All right.  We are ready to start,
 
         19   Ms. Carrillo.
Last update: December 3, 2010