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BBT.Com Public Comment Letters Alexander, Mitzi From: Heidenreich, Suzanne Sent: Monday, February 26, 2018 8:43 AM To: Alexander, Mitzi Subject: FW: Federal Reserve Banks of Atlanta & Richmond Foster Racial Economic Exclusion: FMCRC Requests CRA Downgrade for BB&T and Citibank Follow Up Flag: Follow up Flag Status: Flagged ‐‐‐‐‐Original Message‐‐‐‐‐ From: Al Pina [[email protected]] Received: Sunday, 25 Feb 2018, 9:12AM To: 'Al Pina' [[email protected]] Subject: Federal Reserve Banks of Atlanta & Richmond Foster Racial Economic Exclusion: FMCRC Requests CRA Downgrade for BB&T and Citibank Florida Minority Community Reinvestment Coalition 4836 Tuscan Loon Drive Tampa FL 33619 February 26, 2018 Federal Reserve System Federal Reserve Bank of Atlanta Federal Reserve Bank of Richmond Ms. Lael Brainard Mr. Raphael Bostic Mr. Thomas Barkin Governor President President 20th & C Street NW 1000 Peachtree Street NE 701 E. Byrd St Washington D.C 20551 Atlanta, GA 30309 Richmond, VA 23219 RE: Request for CRA inquiry into lack of home lending to minorities and lack of construction lending for affordable housing development to minority led and focused nonprofits by Citibank and BB&T. Placement of “Need to Improve” into bank CRA file for lack of affordable housing construction lending to minority led and focused nonprofits. Request for Racial Housing Inclusion Studies by Reserve Banks of Atlanta and Richmond to follow Leadership of Reserve Bank of San Francisco “Color of Wealth in Los Angeles” Study (Sent via certified letter and email) Dear Ms. Brainard, Mr. Bostic and Mr. Barkin: 1 In the area of both home lending to minorities by BB&T and Citibank and providing access to capital to minority led and focused nonprofits for construction of affordable housing, these two banks (and many other banks you regulate) they should just place a sign on their bank building “White Need Only Apply”. The Federal Reserve Bank of San Francisco study “The Color of Wealth” clearly demonstrates that there is a vast and growing racial wealth gap that is driven by the lack of both minority home ownership and home equity. Most banks that you regulate, and in particular Citibank and BB&T, have failed miserably to provide capital to both minority home buyers and minority led and focused nonprofit affordable housing developers who wish to provide increased access to affordable housing that will increase minority household wealth. But this is a direct reflection of both the Federal Reserve Bank of Richmond and the Federal Reserve Bank of Atlanta desire and commitment towards racial economic inclusion. Your Banks can brag all you want about how you push for racial economic inclusion but in the end all that matters is the data and the data clearly shows both of your regulatory bodies have failed miserably in racial economic inclusion. There is national crisis in the lack of affordable housing in large urban cities throughout the United States. In Florida and Maryland this lack of affordable housing is now having a significant negative impact on the number of new minority home owners. Nonprofits must play a vital role in the development and construction of affordable housing. But these nonprofits are not able to become a vital supplier of affordable housing due to the lack of capital provided directly from major financial institutions. At the top of this list of banks not directly providing capital to nonprofits are BB&T and Citibank. We at FMCRC and the organizations we work with are requesting a formal CRA inquiry into this matter and if substantiated, that their current CRA rating be adjusted with a “needs to improve” in this area of direct lending to both minority home buyers and minority led and focused nonprofit home builders. Capitalism without capital is nothing more than an ISM. In the Latino and especially the African American community there is mostly ISM. The CRA act is squarely focused on “access to capital” and not charity or grant giving as this passage of the actual CRA act outlines: The Community Reinvestment Act (CRA) is a federal law that requires banks to meet the credit needs of their entire communities, including low-moderate income (LMI) neighborhoods. The CRA Act begins by reciting to Congress three findings. First, financial institutions are required to serve the “convenience and needs” of the communities in which they are chartered to do business. Second, “the convenience and needs of the communities include credit services.” Third, financial institutions have “continuing and affirmative obligation(s) to help meet the credit needs of the local communities in which they are chartered.” For the minority community, home ownership and home equity are vital to increasing household wealth that in turn bridges both social and economic inequality in our country. There must be more emphasis on home ownership capital and not rental capital. Investors target multi-family development due to the return on investment that is layered with tax credits. The banks finance these investments due to both profit and their ability to obtain significant CRA credit. In that rentals are also necessary, there must be a balance of For Sale affordable housing and rentals. Your CRA examiners have dramatically tipped the balance in favor of multifamily development that is now contributing to the ever growing racial wealth gap that is driven by home equity. The key to reversing this economic scale from rentals to home ownership is to develop and expand the number of minority led and focused nonprofit affordable housing developers. But without direct capital from banks to nonprofits this will not happen. We at FMCRC have proven in a very short time that with access to capital, and the right business model, a nonprofit can become a major player in affordable housing development. In a short period we have become Florida’s largest nonprofit affordable housing builder that does not use government 2 funding. Banks such as Regions, PNC, TD, Capital One and Fifth Third banks all have stepped up with programs that offer direct lending to minority led and focused nonprofits to build affordable housing. But when we attempted to access similar construction capital lines of credit at Citibank and BB&T we met nothing but resistance. This lack of access is very concerning to FMCRC and it should be to your regulatory agencies. The lack of racial relevant focused programs and studies by both of your Federal Reserve Banks has led to an environment in both of your service areas where white led (leadership and board) organizations dominate and monopolize housing programs and community economic development in minority communities. This in turn has led to a growing racial economic segregation mentality and environment. Just recently when we at FMCRC led a charge for Baltimore African American organizations to be allowed to lead housing and community economic development programs that impact their communities, I was met with calls by white nonprofit leaders, regulators and bankers that I was a “racist’. Your Federal Reserve Banks have allowed this “sense of white entitlement” to foster and grow. We at FMCRC demand that both of your Federal Reserve Banks follow the lead of the Federal Reserve Bank of San Francisco and conduct a “Color of Wealth” study for both of your markets. FMCRC is an economic civil rights organization and not a home builder. There are thousands of minority led and focused nonprofit affordable home builders (or those who wish to build) in our country that can overnight have a major impact on the availability of affordable housing to minority home buyers but will never be able to do so without access to capital directly from banks. It is our hope that your organizations can re-think your approach to this growing issue and formulate a CRA policy that will encourage, if not mandate, that financial institutions must have direct affordable housing construction capital available to nonprofits. There is thousands of minority led and focused nonprofits that are willing and able to begin building tomorrow but can only do so with access to capital from banks. We at FMCRC thank you for your consideration on this request. If there are any questions, please contact myself directly at (813) 598-6361. Sincerely, "There are those who say thus is the way of the world....I say NO thus we make it" "It is easy to sing when one sits upon a perch of privilege as compared to those who are drowning in a sea of neglect" Al Pina Chair/CEO FMCRC & Assets & Hope Interim Chair, National Minority Affordable Home Builders Coalition & Summit Committee Member, Baltimore African American Home Builders Cooperative Cell 813-598-6361 www.assetsandhope.org www.minorityhomebuilders.org www.fmcrc.org FAITH-HONOR-STRENGTH 3 Heidenreich, Suzanne From: Jeffries-Jones, Sharon Sent: Monday, April 02, 2018 12:06 PM To: Heidenreich, Suzanne Subject: FW: Federal Reserve Banks of Atlanta & Richmond Foster Racial Economic Exclusion: FMCRC Requests CRA Downgrade for BB&T and Citibank FYI. From: Jeffries-Jones, Sharon Sent: Monday, February 26, 2018 5:02 PM To: 'Al Pina' Cc: Schoonover, Heidi; Pascal, Craig; Freeman, Louis Subject: RE: Federal Reserve Banks of Atlanta & Richmond Foster Racial Economic Exclusion: FMCRC Requests CRA Downgrade for BB&T and Citibank Al, It is unfortunate that we are at this juncture. However, BB&T is in receipt of your request to the Federal Reserve Bank and they will proceed with gathering the necessary documentation for their review. Those results will outline BB&T’s performance in home loans to minorities, as well as, to dminority le and focused nonprofits in Florida and Maryland. BB&T is interested in continuing our discussion to address the training center development which will support minority led affordable housing. I am writing you today in order to request a time so we can schedule a conference call/visit to further discuss the community needs you have identified.
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