Public Meeting Regarding Norwest Corporation and Wells Fargo & Company
Thursday, September 17, 1998
Transcript of Panel Five
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17 CHAIRPERSON SMITH: Thank you very much. 11:28:48
18 Any questions from the panel? We thank you for 11:28:48
19 coming. You came a long way and we appreciate your 11:28:54
20 being here to present your testimony. 11:28:58
21 With that, we'll go on to the next panel, Panel 11:29:02
22 5. We'll start with Ms. Kalant. 11:30:30
23
24 MS. KALANT: My name is Amelia Kalant, and 11:30:40
25 I'm a member of the New Mexico Community 11:30:42
104
1 Reinvestment and Development Task Force or Credit. 11:30:44
2 Credit is a coalition of nonprofit housing and 11:30:48
3 community development organizations. 11:30:50
4 Today I want to briefly address two issues. 11:30:52
5 The first is a recently announced community lending 11:30:56
6 initiative by Norwest and Wells Fargo Banks, and the 11:31:00
7 second is an increasingly serious failure in the 11:31:02
8 CRA. 11:31:08
9 First, Credit is pleased that Wells Fargo and 11:31:10
10 Norwest have just made a $1.3 billion community 11:31:12
11 lending commitment in New Mexico. This resulted 11:31:18
12 from a series of meetings between our organizations 11:31:22
13 and the following bank officers: Norwest-New 11:31:24
14 Mexico's president, Larry Willard, and CRA officer 11:31:28
15 Patricia Nye, Karen Wegman, and Sharon Gerber of 11:31:32
16 Wells Fargo, and Karen Olnus of Norwest Corporation, 11:31:36
17 as well as several others. 11:31:40
18 The $1.3 billion commitment includes 11:31:42
19 $90 million for mortgage lending for low or moderate 11:31:44
20 income or minority borrowers, and $850 million for 11:31:50
21 loans to small businesses and small farms. In 11:31:54
22 addition, the banks made other specific commitments. 11:31:58
23 They will make a $10 million investment in a special 11:32:02
24 mortgage program designed to meet the needs of low 11:32:04
25 and moderate income first-time home buyers. 11:32:08
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1 The bank's foundations will continue their 11:32:12
2 commitments to funding home buyer training and 11:32:14
3 counseling programs sponsored by not-for-profit 11:32:18
4 community development organizations. And, they 11:32:20
5 promise that there will be no changes in the bank's 11:32:24
6 New Mexico branch network as a result of the merger, 11:32:28
7 except in the City of Santa Fe. 11:32:32
8 President Willard of Norwest-New Mexico 11:32:34
9 affirmed the bank's continued commitment to serving 11:32:38
10 rural communities and to relationship banking. 11:32:40
11 These are extremely important to New Mexico, which 11:32:44
12 is largely rural and majority minority population. 11:32:46
13 Credit looks forward to working out with the banks a 11:32:52
14 detailed plan for accomplishing the CRA objectives 11:32:58
15 and to helping the banks improve their capacity to 11:33:00
16 meet the needs of Native Americans in Native 11:33:04
17 American communities. 11:33:06
18 Credit specifically commends the work of Larry 11:33:10
19 Willard and Patricia Nye. Both from New Mexico, 11:33:14
20 they have shown sensitivity to and awareness of the 11:33:16
21 unique needs of the New Mexico communities, and have 11:33:20
22 demonstrated respect for community leaders. 11:33:22
23 We urge the banks to continue to entrust 11:33:26
24 decision-making to local officials who are best 11:33:30
25 suited to identify and respond to local needs. 11:33:32
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1 Credit also very strongly urges the banks to make 11:33:36
2 similar specific appropriate CRA commitments in all 11:33:40
3 other states where the banks do business. 11:33:44
4 Now a word about the CRA. With the increasing 11:33:48
5 number of bank mergers, nationwide banking has 11:33:52
6 become the norm. The policy of assigning to each 11:33:56
7 bank a single CRA rating when the bank's CRA 11:33:58
8 performance can vary widely from state to state is 11:34:02
9 thoroughly untenable. It renders the rating 11:34:06
10 meaningless. In cases where a bank receives a high 11:34:08
11 rating in California, for example, but a low rating 11:34:12
12 in New Mexico, it is awarded an overall high rating. 11:34:16
13 For New Mexico and other rural, less populated 11:34:20
14 states, this is unacceptable. 11:34:24
15 In conclusion, we thank the Federal Reserve for 11:34:26
16 holding these hearings, but feel that the federal 11:34:28
17 banking regulators must address this serious flaw in 11:34:30
18 the CRA. And to reiterate, we urge the banks to 11:34:34
19 negotiate appropriate community lending initiatives 11:34:36
20 in every state where they do business. Thank you. 11:34:40
21
22 CHAIRPERSON SMITH: Thank you. Mr. Kamp. 11:34:44
23
24 MR. KAMP: My name is Marv Kamp. On 11:34:46
25 behalf of the Wisconsin Rural Development Center, 11:34:48
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1 the following comments are submitted in opposition 11:34:50
2 to the application of Norwest Bank to acquire Wells 11:34:54
3 Fargo Bank. 11:34:58
4 On August 3, 1998, our organization submitted 11:35:00
5 comments on this proposed application. Specific 11:35:02
6 concerns cited in those comments included Norwest's 11:35:08
7 low level of originations to low to moderate income 11:35:10
8 conventional home buyers, its lack of participation 11:35:14
9 in state and federal guarantee programs designed to 11:35:18
10 assist LMI first-time home buyers, small businesses 11:35:20
11 and small farms, and its inadequate reinvestment of 11:35:26
12 deposit dollars back into low income communities in 11:35:30
13 underserved rural areas. 11:35:32
14 Based on asset share, Norwest is the fifth 11:35:34
15 largest commercial institution in Wisconsin with 11:35:40
16 over two billion in assets. Clearly, how it 11:35:42
17 conducts business and meets its reinvestment 11:35:46
18 obligations has a substantial impact on our state's 11:35:48
19 economy and, in particular, the communities it 11:35:52
20 serves. Changes in lending policies and practices 11:35:54
21 can often have devastating consequences, especially 11:35:58
22 for our state's poor. 11:36:02
23 In our initial comments we raised concerns 11:36:04
24 about Norwest's low level of reinvestment dollars 11:36:08
25 back into the community, not only in Wisconsin but 11:36:10
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1 nationally. Norwest has -- currently has a 56.6 11:36:12
2 percent loan to deposit ratio in Wisconsin, the 11:36:18
3 lowest loan to deposit ratio of any of the largest 11:36:22
4 financial institutions serving the state, or any 11:36:24
5 state bank, for that matter. The average loan to 11:36:28
6 deposit ratio of similar institutions of similar 11:36:30
7 size and resources is over 97 percent in Wisconsin. 11:36:34
8 In 22 of the 28 markets served by Norwest 11:36:40
9 nationally, the bank is below average in their 11:36:44
10 reinvestment of deposit dollars back into these 11:36:46
11 markets, let's face it, when a number of our state's 11:36:48
12 community credit needs are going unmet and over 40 11:36:52
13 percent investments and securities is clearly 11:36:54
14 unacceptable. These are dollars which are 11:36:58
15 desperately needed to revitalize low income inner 11:37:02
16 city neighborhoods and rural communities. 11:37:04
17 Also in our comments we attempted to raise 11:37:08
18 concerns about Norwest's lack of participation in 11:37:10
19 state and federal credit enhancement programs which 11:37:12
20 are designed to meet the needs of low to moderate 11:37:16
21 income borrowers. We find their participation in 11:37:18
22 these programs substantially lacking. Of the 236 11:37:20
23 million in conventional home mortgages originated by 11:37:24
24 Norwest in 1996, less than one percent were under 11:37:28
25 Wisconsin Housing Economic Development Home 11:37:32
109
1 Guarantee, a highly successful state program which 11:37:34
2 is designed to assist first-time LMI conventional 11:37:38
3 home buyers. 11:37:44
4 This morning Mr. Hazen talked about Wells 11:37:44
5 Fargo' commitment to rural lending. However, we 11:37:50
6 find Norwest investment in rural areas of our state 11:37:52
7 abysmal. Despite the fact that rural branch 11:37:56
8 deposits represent over ten percent of the system's 11:38:00
9 total deposit base, few loans are being originated 11:38:02
10 to LMI borrowers. 11:38:06
11 In rural Wisconsin, the percentage of low 11:38:08
12 income families often exceeds rates found in central 11:38:10
13 cities. The bank's lack of participation in 11:38:16
14 programs which serve this population excludes large 11:38:18
15 numbers of LMI and limited resource borrowers. 11:38:20
16 Regarding rural credit enhancement programs, 11:38:24
17 Norwest originated no farm service agency guarantees 11:38:28
18 in 1995, 1996 or 1997. Also, for the Credit Relief 11:38:32
19 Outreach Program, which is a highly successful state 11:38:40
20 program for farm production loans, they originated 11:38:44
21 no loans in 1995, 1996 or 1997. No S.B.A. loans 11:38:48
22 were originated in 1996 or 1997. 11:38:56
23 This morning Mr. Biller talked about Norwest 11:39:00
24 development programs in the Navajo nation. In 11:39:02
25 Wisconsin, Norwest has drawn a big red line around 11:39:06
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1 the Ojibwe tribal lands of Menomonie County. 11:39:08
2 Given both banks' market presence in rural 11:39:14
3 areas, the merger will make Norwest the nation's 11:39:18
4 number one agricultural lender. The lack of any 11:39:20
5 specific mention by the bank relating to 11:39:24
6 reinvestment plans for rural areas is especially 11:39:28
7 troubling. To date no disclosure of CRA or 11:39:30
8 community development plans has been made. The only 11:39:34
9 commitment we are currently aware of is the 11:39:36
10 mega-pledge for mostly urban areas of California. 11:39:38
11 Although we have met several times with Norwest in 11:39:40
12 Wisconsin to discuss reinvestment plans, there has 11:39:44
13 been no specific disclosure of how this merger will 11:39:46
14 affect our state or a willingness to pledge any 11:39:50
15 similar commitments to Wisconsin. 11:39:54
16 We believe that the lack of any CRA community 11:39:56
17 development plans, any application, is not only a 11:40:00
18 violation of the Federal Reserve rules and grounds 11:40:02
19 for denial of the application by itself, but an 11:40:06
20 insult to the citizens of Wisconsin and our nation. 11:40:08
21 Thank you. 11:40:12
22
23 CHAIRPERSON SMITH: Thank you. Ms. 11:40:14
24 LaBlanc will be wearing two hats today. She's 11:40:16
25 speaking on her own behalf, and then will be 11:40:18
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1 speaking on behalf of the Washington Reinvestment 11:40:20
2 Alliance.
3
4 MS. LA BLANC: Right. Iowa Citizens for 11:40:24
5 Community Improvement is a state-wide grassroots 11:40:26
6 community organization, including both rural and 11:40:30
7 urban chapters, that has been working on lending 11:40:32
8 since 1977 and on rural lending since 1981 during 11:40:34
9 the farm crisis. These efforts have focused on the 11:40:38
10 policies and practices of the Farmers Home 11:40:42
11 Administration, Farm Credit Services, commercial 11:40:46
12 banks, and bank regulatory agencies. 11:40:46
13 We got our first family farm lending program 11:40:48
14 with Norwest in January 1989. By 1991, we had 11:40:50
15 agreements with Firstar and Brenton Banks. 11:40:56
16 Currently our three farm loan programs cover 27 11:40:58
17 banks in 26 communities across Iowa, and we estimate 11:41:04
18 that these programs have helped over 12 hundred 11:41:06
19 small and mid-sized farmers obtain nearly $27 11:41:08
20 million in credit for annual operating and crop 11:41:12
21 input expenses, machinery, and real estate 11:41:14
22 purchases, and other agricultural needs. 11:41:18
23 We have also used the CRA to help farmers set 11:41:20
24 up debt restructuring agreements which -- and during 11:41:24
25 the farm crisis kept a lot of farmers on the farm 11:41:26
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1 and kept them from losing everything they had. 11:41:30
2 Our concerns about this merger include customer 11:41:32
3 service, commitment to communities, and rural 11:41:36
4 service. On customer service. Wells Fargo has a 11:41:38
5 poor customer service reputation. A web site was 11:41:42
6 set up by and for unhappy customers that has been so 11:41:46
7 well visited that several magazine articles have 11:41:52
8 been written about it. 11:41:54
9 According to a study done by United 11:41:56
10 Steelworkers of America, between June 1996 and March 11:41:58
11 1998, there was a disproportionate decline in the 11:42:02
12 relative share of branches in nonmetropolitan areas. 11:42:02
13 For example, in Nevada, Wells Fargo increased its 11:42:06
14 metropolitan branches by 29 percent while its 11:42:08
15 nonmetropolitan branches declined by five percent. 11:42:12
16 And in California, the decline was 34 percent in 11:42:16
17 nonmetropolitan areas and only nine percent in 11:42:18
18 metropolitan areas. 11:42:22
19 On rural service. In response to Question 4 of 11:42:22
20 the Federal Reserve Board's August 21st letter, 11:42:26
21 Wells Fargo's rural programs and initiative were all 11:42:30
22 contributions in investments in other people's 11:42:34
23 programs. Wells Fargo showed no initiative on their 11:42:38
24 own. While the states that they are in include 11:42:40
25 rural areas, they could show nothing that they were 11:42:42
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1 doing to serve the needs in those areas except 11:42:44
2 giving money to other people to do something for 11:42:48
3 them. Rural people should be able to expect to use 11:42:50
4 banks like everyone else, not nonprofits and special 11:42:54
5 programs. Remember, CRA is about lending and doing 11:42:58
6 business with people. It's not about charity and 11:43:00
7 philanthropy.
8 We're also concerned about a statement made by 11:43:04
9 Tom Unger in a newspaper report announcing Wells 11:43:06
10 Fargo's closure of 14 branches in Washington, 26 in 11:43:10
11 Oregon, 10 in Idaho, and 12 in other western rural 11:43:12
12 areas that "urban areas provide better growth 11:43:16
13 prospects. We want to offer a complete network of 11:43:20
14 services in our locations, but that was not possible 11:43:24
15 in rural communities where there is simply not 11:43:26
16 enough people." We have no reason to believe that 11:43:30
17 this philosophy will not carry over into the new 11:43:32
18 company. 11:43:36
19 On mortgage lending. In our urban chapters 11:43:36
20 mortgage lending has been a key issue, and Wells 11:43:40
21 Fargo has not been doing mortgage lending. In the 11:43:42
22 documents sent by Norwest and Wells Fargo in 11:43:44
23 response to Question 2 in the August 21st letter 11:43:46
24 from the Board of Governors, Norwest and Wells Fargo 11:43:50
25 did not adequately explain their plans for mortgage 11:43:52
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1 lending products post-merger. Mortgage lending is 11:43:56
2 the backbone of CRA. It was the driving force 11:43:58
3 behind the CRA legislation and is vital to community 11:44:02
4 development. Wells Fargo's lack of mortgage lending 11:44:04
5 in low-mod income areas, originating only 253 loans 11:44:10
6 in low-mod income census tracts in 1997 nationwide, 11:44:16
7 is a clear violation of CRA. 11:44:20
8 In contrast, Norwest Bank made 85 loans in 11:44:20
9 low-mod income census tracts in Des Moines alone in 11:44:24
10 1997. That's 34 percent of Wells Fargo's nationwide 11:44:28
11 total. That's the Iowa CCI testimony. 11:44:32
12 I know nothing about this, but I'm reading it 11:44:38
13 for Washington Reinvestment Alliance. 11:44:42
14 Honorable Governors of the Federal Reserve: 11:44:46
15 The Washington Reinvestment Alliance (WRA) offers 11:44:48
16 testimony regarding the merger of Wells Fargo and 11:44:50
17 Norwest Mortgage. The WRA is concerned that 11:44:52
18 Norwest's poor record of mortgage lending to low- 11:44:56
19 and mod income communities within Washington State 11:44:58
20 will result in this merger's negative effect on 11:45:00
21 these communities. 11:45:04
22 Wells Fargo's presence in Washington has been 11:45:04
23 marked by honest efforts to expand services to 11:45:08
24 low-mod income communities. When the bank acquired 11:45:10
25 First Interstate in 1996, Wells made contact with 11:45:14
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1 the WRA to discuss the merger's impact. In addition 11:45:20
2 Wells has made investments and contributions that 11:45:22
3 First Interstate had previously avoided, 11:45:24
4 concentrating on corporate giving and investments 11:45:26
5 for community economic development. 11:45:30
6 Norwest's mortgages performance has not been so 11:45:32
7 praiseworthy. This subsidiary of Norwest Bank makes 11:45:34
8 only nominal corporate contributions within the 11:45:38
9 state. Unlike its mortgage branches in states with 11:45:42
10 Norwest Bank branches, Norwest Mortgage does not 11:45:44
11 widely offer mortgage products to Washington 11:45:48
12 borrowers that help the bank earn credit under the 11:45:52
13 CRA. In 1997, the company made 50 percent more down 11:45:54
14 payment assistance programs in loans in South 11:45:58
15 Dakota -- where it originated at least six times 11:46:00
16 fewer loans to low and moderate income borrowers -- 11:46:04
17 than in Washington. 11:46:08
18 Analysis conducted by the Freemont Public 11:46:08
19 Association, a HUD-certified agency that provides 11:46:10
20 mortgage default counseling to at risk borrowers in 11:46:14
21 the Seattle area, shows that Norwest's default rate 11:46:18
22 is much higher than area lenders in proportion with 11:46:22
23 its market share. The FPA concludes that Norwest 11:46:26
24 borrowers are much more likely to lose their homes 11:46:28
25 than customers of nearly any other mortgage company. 11:46:30
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1 Norwest's unsatisfactory record is replicated on a 11:46:32
2 state-wide level. Norwest originated 2,223 11:46:36
3 FHA-insured mortgage loans in the Spokane 11:46:42
4 jurisdiction in the year 1997, ranking second in the 11:46:46
5 number of FHA loans made; yet, Norwest's default 11:46:48
6 rate on these loans was higher than 12 of the 24 11:46:52
7 lenders surveyed. In Seattle the record is worse. 11:46:56
8 Norwest Mortgage ranked 34th out of 43 lenders in 11:46:58
9 loss mitigation performance in 1997. 11:47:02
10 Based on these facts, the WRA can only conclude 11:47:04
11 that Norwest is using its giant market share and its 11:47:06
12 plentiful supply of HUD-insured mortgages to 11:47:12
13 originate loans without supporting its low and 11:47:14
14 moderate income borrowers. 11:47:16
15 To ensure that mortgage lending becomes more 11:47:18
16 supportive of the community in the wake of the 11:47:22
17 merger, the WRA recommends the following measures be 11:47:22
18 taken by the combined company. 11:47:26
19 One, lending officers and loan servicing agents 11:47:28
20 employed by Norwest Mortgage-Washington State 11:47:32
21 branches receive training to provide more customer 11:47:36
22 centered servicing of their loans, including 11:47:38
23 specific instruction in preparing loss mitigation 11:47:42
24 plans in cooperation with borrowers at risk in 11:47:44
25 mortgage default. 11:47:48
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1 Two, the combined company make a significant 11:47:48
2 new lending target on single-family home loans to 11:47:52
3 low and mod income individuals and census tracts and 11:47:56
4 minority home buyers. The commitment should 11:47:58
5 anticipate Norwest's expanded market share due to 11:48:00
6 customers that currently shop for home loans through 11:48:04
7 Wells Fargo. 11:48:08
8 Three, the combined company contribute $1.25 11:48:08
9 million to home pre-purchase and mortgage default 11:48:12
10 counseling agencies over the next five years. Thank 11:48:16
11 you for your consideration. 11:48:18
12
13 CHAIRPERSON SMITH: Thank you. We'll go 11:48:20
14 to Ms. Wegner.
15
16 MS. WEGNER: Good morning. My name is 11:48:24
17 Ferol Wegner. I'm a board member of the Citizens 11:48:26
18 for Community Improvement of Des Moines, Iowa. 11:48:30
19 Citizens for Community Improvement of Des Moines has 11:48:32
20 been working on the CRA in Des Moines' neighborhoods 11:48:36
21 since 1977. Our work has resulted in over $50 11:48:38
22 million in loans and grant money being brought into 11:48:42
23 our low and moderate income neighborhoods. 11:48:44
24 Citizens for Community Improvement of Des 11:48:46
25 Moines has three main concerns with the merger of 11:48:50
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1 Wells Fargo and Norwest Bank. These concerns are 11:48:52
2 customer service, mortgage lending, and commitment 11:48:54
3 to communities. 11:48:58
4 There's a real concern that services will be 11:49:00
5 drastically reduced in low to moderate income 11:49:02
6 neighborhoods as well as in smaller urban and rural 11:49:06
7 communities. Norwest stresses people are their 11:49:08
8 greatest asset for growth, while Wells Fargo closed 11:49:10
9 hundreds of branches, eliminated 7,000 jobs in the 11:49:14
10 hostile takeover of First Interstate Bank, slashing 11:49:18
11 a total of 12,600 jobs to date. This can and 11:49:20
12 probably will occur again with this proposed merger. 11:49:24
13 Wells Fargo uses ATM machines and other 11:49:26
14 technology where there are fewer flesh and blood 11:49:28
15 bankers. People like to see and talk to a friendly 11:49:32
16 face, someone they can trust and feel comfortable 11:49:34
17 with, knowing their concerns can be addressed by the 11:49:36
18 bank's president or CEO. They still want 11:49:38
19 old-fashioned customer service with ATMs and 11:49:42
20 Internet banking services as an extra amenity. 11:49:44
21 We all know that technology plays a major role 11:49:48
22 in our daily lives today. What's wrong with 11:49:50
23 traditional banking made better? It appears to me 11:49:54
24 that it all boils down to the bottom line: profits 11:49:56
25 versus the human factor. Where does that leave the 11:49:58
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1 other part of the equation, the human factor, and 11:50:02
2 when does the steamroller stop? 11:50:04
3 In the documents sent by Norwest and Wells 11:50:08
4 Fargo in response to Question 2 in the August 21st 11:50:10
5 letter from the Board of Governors, Norwest and 11:50:12
6 Wells Fargo did not explain their plans for mortgage 11:50:16
7 lending products post-merger. Mortgage lending is 11:50:18
8 the backbone of CRA. It was the driving force 11:50:22
9 behind the CRA legislation, and is vital to 11:50:26
10 community development. Wells Fargo's lack of 11:50:28
11 mortgage lending in low to mod income areas, 11:50:32
12 originating only the 253 loans in low to moderate 11:50:36
13 income census tracts in 1997, is a clear violation 11:50:40
14 of the CRA. 11:50:44
15 CCI is very concerned and uncomfortable in 11:50:50
16 regard to the response from -- in from Norwest and 11:50:54
17 Wells Fargo. We are not satisfied that they 11:50:58
18 neglected to explain their plans for mortgage 11:51:04
19 lending products after the proposed merger. We and 11:51:06
20 other groups across the nation have worked and 11:51:08
21 fought too long and hard to abandon our CRA efforts 11:51:10
22 and the impact that CRA has done in our 11:51:14
23 neighborhoods. None of us want to return to the 11:51:16
24 days of red lining. Our low and moderate income 11:51:20
25 areas in our communities will suffer, and our 11:51:22
120
1 struggling inner cities will surely die. 11:51:24
2 This issue is a serious one and it must be 11:51:28
3 addressed in this merger and subsequent proposed 11:51:30
4 mergers. Citizens of Community Improvement Des 11:51:32
5 Moines has been working with lenders on reinvestment 11:51:36
6 since 1977. We have lending agreements with several 11:51:38
7 local lenders. While we have worked with Norwest 11:51:42
8 since 1992, when we asked for a meeting and written 11:51:44
9 commitment with Norwest that would include national 11:51:48
10 decision-makers, we were offered a meeting with 11:51:52
11 local people only during the day when many of our 11:51:54
12 task force members are at work. We were also told 11:51:58
13 that there was no need for a written, signed 11:52:02
14 agreement. There is no reason not to sign a 11:52:04
15 commitment unless you have no intention of honoring 11:52:06
16 it. 11:52:10
17 Our task force must ensure that the positive 11:52:10
18 things that have happened in our communities 11:52:14
19 continue to happen. And with banks merging and 11:52:16
20 decisions made farther and farther away, we need 11:52:18
21 written commitments from lenders more than ever so 11:52:22
22 we can be sure that our communities continue to 11:52:24
23 grow. 11:52:28
24 Local banking institutions should be able to 11:52:30
25 make their own decisions locally, not by those 11:52:32
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1 decision-makers in another state halfway across the 11:52:36
2 country. The financial needs in Iowa, which is an 11:52:38
3 agricultural state, is much more different than in 11:52:40
4 North Carolina or California. We have been 11:52:44
5 monitoring our local lenders and note that as 11:52:46
6 mergers continue, it has become increasingly 11:52:48
7 difficult to obtain written agreements with them; 11:52:52
8 however, our local banks have no qualms about this. 11:52:56
9 They want to do this. This indicates to us that as 11:53:00
10 banks merge, becoming larger and not locally owned, 11:53:02
11 written agreements are crucial for our continued 11:53:06
12 community growth in cities such as Des Moines, Iowa. 11:53:10
13 Thank you very much for your time. 11:53:14