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Community Reinvestment Agreement Banc One, N.A. and the Chicago CRA Coalition upon the Aquisition of First Chicago NBD 1999 through 2004
Housing
Single Family Mortgage
Lending
Market Share - Increase
bank lending to low- and moderate-income (“LMI”) people and areas, including
expansion into un- and underserved markets.
- The
Bank concurs with a goal of reaching a cumulative metropolitan six county
area total of 35,879 LMI residential HMDA loans by the end of the year
2004 (attachment breaks down totals by year and product.)
- Progress
will be measured by number of loans, percentage increase and market share.
- Generally,
lending in low- and moderate-income areas should be commensurate with
lending increases to low-and moderate-income people over all. (Sub-prime lending should not be
included in these increases.)
- The
bank will work with community organizations to determine underserved
markets, and ways to penetrate these markets.
- The
bank will participate in the design and development of an analysis of
credit and service needs in LMI communities, and will contribute to its
implementation.
Credit Scoring - Ensure
that increased use of credit scoring does not become a barrier to accessing
credit for people with non-traditional or problematic credit histories.
- Applicants
with marginal credit scores will be offered another loan product, and
denied applicants will be given information on homeownership counseling
programs.
- The
bank will continue second reviews of all low/mod applications, as well as
second reviews of all minority loans which are received.
- The
bank's Community Outreach and Education Division (COED) will work with the
Credit Counseling Services of Chicago on credit repair workshops.
Other - Reduce
inappropriate subprime lending
- After
the merger, the bank will conduct credit analysis on all subprime
applicants and refer them to appropriate loan product.
- Increase
Downpayment Assistance (“DPA”) Pool
- The
bank will increase the DPA pilot to $150,000/yr. for 6 years, with $1,500
per borrower. 1/3 of these funds will be set aside for borrowers below 60%
of median income, with the remainder for those at 80%; areas will include
EZ, City EC, and all low/mod tracts in South Suburban Cook County.
- Within
the Downpayment assistance program, $2,500 will be offered for people with
disabilities, with no geographic limits on the home purchase, and income eligibility
extended up to 100% of median.
- The
geography and subsidy amounts are open to annual adjustment at the
suggestion of the bank or the Neighborhood Lending Review Board.
Multifamily Lending
Renew and increase the
Neighborhood Lending Program
- Targets
for multifamily lending are found in attachment.
- The
activities of the Neighborhood Lending Program will be continued.
- 1998
Goal - $65 million in loans closed, 1999 goal - 7.5% increase to $70
million.
Encourage mixed-income
development
- The
bank concurs with the importance of mixed-income development including
rental and for-sale units, and will encourage proposals for these.
Housing Policy
Partner with City of Chicago to preserve
affordable housing stock and expand home ownership opportunities
- The
bank will continue to partner with the City of Chicago and community organizations in
projects that support the goals of the new 5-year Department of Housing
Affordable Housing Plan.
- They
will partner with the Chicago Rehab Network to identify methods to finance
low income housing as described in the City’s 5 Year Plan, such as: family
housing prioritization; preservation; Section 8 & public housing; and,
capacity of non-profits.
Economic Development
Increase bank lending
to small businesses in low- and moderate-income areas.
- The
bank concurs with a goal of reaching a cumulative metropolitan six county
area total of 5,190 LMI small business loans by the end of the year 2004
(attachment breaks out totals by year and loans to very small businesses.)
- The
bank will continue to report small business lending to Neighborhood Review
Board.
- The
bank agrees to approach DCCA (with CRA Coalition members) for higher
matching levels in order to market CAP to small firms in minority
communities, if and where necessary.
- The
bank will increase the number of affordable lines of credit for working
capital that address customers rejected on the basis of current
underwriting criteria.
- The
bank introduced a small business credit card in the fall of 1997, and will
monitor the progress of this product.
The bank will increase the marketing of this product in LMI
communities.
- For
interested community organizations, the bank will partner on credit repair
programs.
- The
bank is investigating the listing of a technical assistance organization
name and contact on all rejection letters.
Increase Technical
Assistance (T.A.) to low- and moderate-income commercial areas in under-served
neighborhoods
- The
bank will work with community organizations and an appropriate T.A. organization
toward increasing T.A., esp. accounting, bookkeeping, computer systems in
LMI communities.
- The
bank will increase its funding of such activities by 10% for each of the
next two years, and agree to evaluate results regularly.
More flexible
underwriting
- The
bank will extend the owner-occupied mixed-use pilot program established in
1996, and will explore expanding it to include commercial industrial
properties contingent upon the continued performance of the portfolio.
Services Task Force Issues
Establish and market
lifeline accounts
- The
bank will convene a group to study the feasibility of offering an Access
Account, with the goal of implementing this account. The study will be completed by November 30, 1998. (Attached
letter from Chairman Istock describes more on this.)
- The
bank will monitor and review EFT guidelines when published this summer for the
development of an EFT account.
- The
bank will increase marketing of lifeline accounts to unbanked individuals
including EFT and/or EBT recipients.
The bank will ensure that this issue is discussed at the Chicago
Clearinghouse.
- The
bank will increase marketing of these accounts through various means and
will consider contracts or grants with community organizations.
Increase financial
literacy training
- The
bank will allocate $50,000/year for financial literacy training through
internal staff resources, workshops, publication of marketing and other
materials, and /or grants to qualified organizations.
- This
program will be evaluated every two years, with consideration of renewal
for another two years at the same level.
Branch Network
Increase the number of
full-service bank branches in under-served communities
- The
bank will open two new Dominick's full-service supermarket branches in
low/mod areas in 1998 and 1999.
- The
bank will open, in addition, two new full-service branches in low/mod
areas in the next four years.
Investments and Grants Issues
Community Development
Investments - Establish a base for yearly increases of community development
investments and grants, including bank CDC and equity investments in CDFIs.
- The
bank will establish the combined 1998 totals of Banc One and First Chicago
NBD as a baseline year for community development grants for the new corporation,
and will increase such grants in the Chicago area by 5% annually for the
next two years. The program will
then be evaluated, with the goal of extending these increases for an
additional two years.
- The
bank will set a goal of $16 million in funding commitments of the Bank CDC
for 1998.
- The
bank will provide $500,000 over three years in long-term, below market
equity equivalent investments or similar instruments, at which time the
program will be evaluated, with consideration for renewal for an
additional three years at the same level.
- The
bank will work with Chicago CDFIs on the development of credit
enhancement/letter of credit pools.
Housing Education and Counseling
- The
bank will continue to support homeownership education and counseling
programs, particularly in low- and moderate-income areas.
- If
there is demand for education on reverse equity mortgages, the bank will
work with organizations on its development.
Other Issues
Evaluation/Monitoring:
- The
bank will continue the quarterly meetings of the Neighborhood Lending Review Board
Vendor procurement:
- The
bank will maintain its Supplier Diversity Program.
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