Annual Report on Lending to Minority-Owned Small Business an Analysis of 2008 SBA Lending to Minorities

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Christian Gonzalez-Rivera Program Manager, Research

annual report on lending to minority-owned small business An Analysis of 2008 SBA Lending to Minorities

December 2008 Table of Contents

The Best And The Worst In SBA Lending To Minorities page 1 Introduction and Recommendations Significant Decline in SBA Lending An Improved SBA is Poised to Become a Major Player in Restoring Our Economy Overall Rankings page 4 Rankings Lending Goals SBA Lending to All Minorities: Data And Grades page 6 Ranking By Number Of Loans Ranking By Number Of Loan‐to‐Asset Ratio Ranking By Percentage Of All Loans Made Ranking By Total Dollar Amount SBA Lending to African Americans: Data And Grades page 11 Ranking By Number Of Loans Ranking By Number Of Loan‐to‐Asset Ratio Ranking By Percentage Of All Loans Made Ranking By Total Dollar Amount SBA Lending to Asian Americans: Data And Grades page 16 Ranking By Number Of Loans Ranking By Number Of Loan‐to‐Asset Ratio Ranking By Percentage Of All Loans Made Ranking By Total Dollar Amount SBA Lending to Latinos: Data And Grades page 21 Ranking By Number Of Loans Ranking By Number Of Loan‐to‐Asset Ratio Ranking By Percentage Of All Loans Made Ranking By Total Dollar Amount Change In Performance 2007‐2008 page 26 Change in Performance in Lending to All Minorities Change in Performance in Lending to African Americans Change in Performance in Lending to Asian Americans Change in Performance in Lending to Latinos Is Big Financial Serving Small Business? page 31 Commitment To Minorities Is More Important Than Bank Size Smaller Banks Outperform Larger Banks Special Section: SBA Lending to Minorities by Bailout Banks page 33 Methodology page 37 References page 38

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 2 Introduction: The Best and the Worst in SBA Lending to Minorities

he recent collapse of private credit provides a Administrator take the following steps to ensure that the strong argument for the importance of a agency remains an effective advocate for minority T continued role of government in private entrepreneurship and innovation: enterprise. Now, as during the Great Depression, the • The Obama Administration should restore the SBA United States government is the only entity whose budget to its 1978 level of $12 billion. (It is presently guarantee of credit has the power to reopen the under $1 billion, and the 1978 figure of $3.8 billion investment pipeline and revive the economy. Small after adjustment for inflation amounts to $12 billion.) businesses comprise 98% of all US businesses, and This will allow it to provide technical assistance and provide 95% of the jobs in this country. capacity building to small businesses, particularly In poor, underserved communities where even chain for micro‐businesses. supermarkets owned by large companies can be difficult • The SBA should provide incentives for financial to find, and homeownership levels are considerably institutions to immediately triple their SBA lending. below average, small businesses represent the only source of economic activity, and one of the only sources • Congress and Secretary of Commerce Bill Richardson should encourage Secretary of the Treasury Tim Geithner, the chair of Federal Reserve, and Larry Summers, chair of President Obama’s Small businesses represent 99% of all National Economic Council to make available $50 businesses in inner city disadvantaged communities, and provide 80% of all the jobs billion of bailout funds for small businesses, in these areas. including minority‐ and women‐owned businesses. Significant Decline in SBA Lending SBA loan data for the year 2008 acquired by the Greenlining Institute through a Freedom of Information of wealth creation. In fact, small businesses represent 99 Act request to the SBA demonstrate that lending volume percent of all businesses in inner city disadvantaged at the SBA has decreased, creating problems for communities, and provide 80 percent of all the jobs in entrepreneurs, who have always turned to SBA‐backed these areas. Therefore, a tightening of credit for small loans when they cannot access conventional credit. businesses will have a crippling effect on US economic Specifically, there was a 30.3% decline in total number of growth and innovation, and in no place will the effect be SBA‐backed loans nationally, including 39.3% decline in more pronounced than in our nation’s growing lower‐ California. Disaggregated by race, SBA lending to: income and minority communities. • Latino(a)‐owned businesses decreased 45.3% SBA lending has substantially declined in the last year, nationally and almost half (48.4%) in California. particularly for small minority owned businesses. This has occurred despite minority‐owned businesses • Asian American‐owned businesses decreased 30.8% growing at a rate two to three times greater than all us nationally and 40% in California. businesses. • African American‐owned businesses decreased Recommendations 19.7% nationally and 20.8% in California. The Greenlining Institute recommends that the incoming Obama Administration, through the next SBA The number of Latino‐owned businesses grew 31%

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 3 between 1997 and 2002, the last years for which fundamental changes in SBA personnel, purpose, vision, comprehensive information was collected. This rate of and leadership that fundamental change will not occur. growth is three times the national average. The number In addition to continued work to improve the Disaster of Black‐owned businesses was up 45% in the same Loan Program, the agency should continue to ensure period, while the number of Asian‐owned businesses that the small business loans it guarantees go only to grew 24%. The number of minority‐owned small small businesses, and not to large corporations that have businesses in the United States in 2002 was acquired small businesses or subsidiaries of large approximately 4 million, yet given the rate of growth of companies. In recent years it has been uncovered that these businesses, Greenlining estimates that the current large corporations had been acquiring SBA‐backed loans number of minority‐owned small businesses is now close that the agency had been improperly categorized, and to 5 million. federal agencies were counting many contracts with The growth in minority‐owned small businesses large corporations as part of the statutory requirement increases wealth and human capital in underserved that 23 percent of their contracts go to small businesses. communities, and also creates job opportunities. A credit crunch to small businesses would not only most negatively affect job growth, but would also have a most This year there has been a 30.3% decline in pernicious effect on inner‐city and rural communities of total number of SBA-backed loans nationally, color, where locals depend on small businesses for their including 39.3% decline in California, everyday needs. compared to last year.

An Improved SBA is Poised to Become a Major Player in Restoring Our Economy

President‐elect Barack Obama has proposed an economic The Obama Administration has strongly supported stimulus plan that is likely to exceed $500 billion, with government investment in infrastructure projects, which the intention of creating $2.5 million new jobs. SBA would create high wage jobs across the country. By lending, properly targeted, is one of the most efficient renewing enforcement of its business size limitations and ways creating new jobs, as well as protecting existing continuing to improve its Disaster Loan Program, the ones. For example, if the SBA were to provide needed SBA will ensure that more small businesses will receive financing for one million small businesses hardest hit by government contracts to engage in this effort to rebuild the recession, it would save two to three million jobs. our country, and that its programs remain relevant in the new economy. Obama has already outlined a Small Business Emergency Rescue Plan, recognizing the importance of Overall, any programmatic changes in the SBA should be maintaining a healthy environment for small business to considered in the context of the great importance of the health of the overall economy. One of the main small businesses to the health of the United States’ provisions detailed in the plan is that the SBA lend economy. directly to small businesses that cannot access other sources of capital through its Disaster Loan Program. This program had come under heavy criticism in the wake of Hurricane Katrina for its gross inability to respond to the crisis. Although the agency has since taken steps to strengthen its disaster preparedness, Greenlining has reservations that without more

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 4 Overall Rankings

lthough the SBA is the largest single small $5 billion in assets to each of the race categories, plus the business financial backer in the nation, SBA‐ “all minorities” combined race category. The grades in A backed loans represent a very small proportion each of the sections are based on the financial of total small business lending by financial institutions. institution’s performance relative to lending targets that This means that most bank lending to small businesses is we and our minority business association members have being done by means of the financial institutions’ developed for each institution based on its flexibility, its proprietary credit products, which are the ones that fall access to resources, and its performance relative to its under the information collection restrictions of peers. Regulation B. This report therefore focuses on SBA Lending Goals lending because it is the only piece of the small business Greenlining has asked both the Small Business lending pie for which information on lending to Administration and the CEOs of major financial minorities is available. institutions to set competitive goals to substantially This report recognizes that Bank of America and J.P. increase both the volume and dollar amount of SBA Morgan Chase have maintained their lead from last year loans. Based on the growth of the number of minority‐ in lending to minority entrepreneurs, while KeyCorp owned firms, national goals should be set to at least 20 and M&T Bank Corp. trail the list of the top twenty percent for African American‐owned businesses, 20 lenders. percent for Latino‐owned businesses, and 20 percent for Asian American‐owned businesses, for a total of 60 These rankings represent the sum of the ranks for the percent of all SBA loans going to minorities overall. number and percentage of loans, as well as the loans per

OVERALL RANKING Rank Financial Institution 1 Bank of America 2 JP Morgan Chase & Co. 3 Citigroup Inc. 4 Wells Fargo & Co. 5 PNC Financial Services Group 6 Capital One Financial Corp. 7 US Bancorp 8 Comerica Inc. 9 SunTrust Banks, Inc. 10 Wachovia Corp. 11 Sovereign Bancorp, Inc. 12 BB&T Corp. 13 Huntington Bancshares Inc. 14 National City Corp. 15 Marshall & Ilsley Corp. 16 M&T Bank Corp. 17 KeyCorp

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 5 SBA LENDING TO ALL MINORITIES DATA AND GRADES

The following tables provide the data on lending to all minorities. The grades in the last column of each table are calculated based on the percent of lending target the bank reached, and its position relative to its competitors. The graphs below the data tables illustrate the disparity among the banks in their rates of lending. The banks studied represent the top twenty lenders in the United States, defined as banks with $50 billion in assets or greater, and that have made more than 200 SBA loans in fiscal year 2008.

The Best and the Worst: Lending to All Minorities

JP Morgan Chase & Co. 2,418 TOP TWO Bank of America 1,560 Number of Loans BOTTOM KeyCorp 84 TWO Marshall & Ilsley Corp. 56

Citigroup Inc. 57.5% TOP TWO Bank of America 46.6% Percent of Loans BOTTOM KeyCorp 13.0% TWO M&T Bank Corp. 12.4%

Wells Fargo & Co. $658,902,100 TOP TWO US Bancorp 503,922,300 SBA Lending Volume BOTTOM Sovereign Bancorp, Inc. $36,570,100 TWO SunTrust Banks, Inc. 33,190,686

Huntington Bancshares Inc. 17.68 TOP TWO Loan‐to‐Asset Ratio: US Bancorp 15.08 Number of Loans per $5 billion in Assets BOTTOM Sovereign Bancorp, Inc. 0.37 TWO SunTrust Banks, Inc. 0.32

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 6

Ranking of Nationʹs Largest SBA Lenders* by Number of Loans to All Minorities

Rank Bank # Loans Total Assets Grade 1 JP Morgan Chase & Co. 2,418 $1,642,862,000,000 A 2 Bank of America 1,560 1,743,478,291,000 B 3 US Bancorp 729 241,781,000,000 B‐ 4 Wells Fargo & Co. 709 595,221,000,000 B‐ 5 Capital One Financial Corp. 334 150,608,527,000 C+ 6 PNC Financial Services Group 298 140,026,464,000 C+ 7 Citigroup Inc. 286 2,199,848,000,000 C+ 8 Huntington Bancshares Inc. 198 55,985,225,000 C 9 Wachovia Corp. 156 808,575,000,000 C 10 National City Corp. 152 155,046,667,000 C 11 BB&T Corp. 143 136,417,064,000 C 12 Sovereign Bancorp, Inc. 121 81,906,412,000 C‐ 13 Comerica Inc. 113 67,167,320,000 C‐ 14 SunTrust Banks, Inc. 106 178,986,947,000 C‐ 15 M&T Bank Corp. 100 66,085,573,000 C‐ 16 KeyCorp 84 101,596,381,000 D 17 Marshall & Ilsley Corp. 56 63,432,326,000 D TOTAL 7,563 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall

Number of SBA Loans Originated to All Minorities, 2008

JP Morgan Chase & Co. Bank of America US Bancorp Wells Fargo & Co. Capital One Financ ial Corp. PNC Financ ial Services Group Citigroup Inc . Huntington Bancshares Inc . Wachovia Corp.

National City Corp.

BB&T Corp. Sovereign Bancorp, Inc . Comerica Inc . SunTrust Banks, Inc . M&T Bank Corp. KeyCorp Marshall & Ilsley Corp.

0 500 1,000 1,500 2,000 2,500

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 7

Ranking of Nationʹs Largest SBA Lenders* by Percentage of Loans Made to All Minorities

Rank Bank % To Minorities # Loans to Minorities Total SBA Loans Grade 1 Citigroup Inc. 57.5% 286 497 A 2 Bank of America 46.6% 1,560 3,351 B+ 3 SunTrust Banks, Inc. 34.2% 106 310 B 4 JP Morgan Chase & Co. 33.5% 2,418 7,218 B 5 Sovereign Bancorp, Inc. 31.4% 121 385 B 6 Comerica Inc. 29.6% 113 382 B‐ 7 PNC Financial Services Group 29.3% 298 1,018 B‐ 8 Wells Fargo & Co. 25.5% 709 2,775 B‐ 9 Wachovia Corp. 22.6% 156 689 B‐ 10 Capital One Financial Corp. 19.9% 334 1,682 C+ 11 BB&T Corp. 18.8% 143 762 C+ 12 US Bancorp 18.4% 729 3,955 C+ 13 Marshall & Ilsley Corp. 17.3% 56 323 C 14 Huntington Bancshares Inc. 14.7% 198 1,348 D 15 National City Corp. 14.1% 152 1,078 D 16 KeyCorp 13.0% 84 644 F 17 M&T Bank Corp. 12.4% 100 808 F TOTAL 27.8% 7,563 27,225 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall.

Percent of SBA Loans Originated to All Minorities, 2008

Citigroup Inc . Bank of America SunTrust Banks, Inc . JP Morgan Chase & Co.

Sovereign Bancorp, Inc . Comerica Inc . PNC Financ ial Services Group Wells Fargo & Co. Wachovia Corp. Capital One Financ ial Corp. BB&T Corp. US Bancorp Marshall & Ilsley Corp. Huntington Bancshares Inc . National City Corp. KeyCorp M&T Bank Corp.

0% 10% 20% 30% 40% 50% 60%

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 8 Ranking of Nationʹs Largest SBA Lenders* by Total Dollar Amount to All Minorities

Rank Bank SBA Lending Volume 1 Wells Fargo & Co. $658,902,100 2 US Bancorp 503,922,300 3 JP Morgan Chase & Co. 444,830,700 4 Wachovia Corp. 382,205,300 5 Comerica Inc. 189,797,200 6 BB&T Corp. 157,028,795 7 PNC Financial Services Group 154,090,600 8 Huntington Bancshares Inc. 152,942,100 9 Bank of America 120,260,926 10 KeyCorp 104,026,300 11 M&T Bank Corp. 90,730,600 12 National City Corp. 85,170,800 13 Capital One Financial Corp. 78,045,000 14 Citigroup Inc. 44,977,600 15 Marshall & Ilsley Corp. 40,329,037 16 Sovereign Bancorp, Inc. 36,570,100 17 SunTrust Banks, Inc. 33,190,686 TOTAL $3,277,020,144 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall.

Total Dollar Amount of SBA Loans Originated to All Minorities, 2008

Wells Fargo & Co. US Bancorp JP Morgan Chase & Co. Wachovia Corp. Comerica Inc . BB&T Corp. PNC Financial Services Group Huntington Bancshares Inc . Bank of America KeyCorp M&T Bank Corp. National City Corp. Capital One Financ ial Corp. Citigroup Inc . Marshall & Ilsle y Corp. Sovereign Bancorp, Inc . SunTrust Banks, Inc .

$0 00 00 00 00 0 0 0 0, 0, 0, 0 0 0 0,0 400,0 60 $100,000,000 $200,0 $300,000,000 $ $500,000,000 $ $700,000,0

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 9 Ranking of Nationʹs Largest SBA Lenders* by Loan‐to‐Asset ratio to All Minorities

# of SBA Loans Per Rank Bank $5 Billion in Assets # Loans Total Assets 1 Huntington Bancshares Inc. 17.68 198 $55,985,225,000 2 US Bancorp 15.08 729 241,781,000,000 3 Capital One Financial Corp. 11.09 334 150,608,527,000 4 PNC Financial Services Group 10.64 298 140,026,464,000 5 Comerica Inc. 8.41 113 67,167,320,000 6 M&T Bank Corp. 7.57 100 66,085,573,000 7 JP Morgan Chase & Co. 7.36 2,418 1,642,862,000,000 8 Bank of America 4.47 1,560 1,743,478,291,000 9 Marshall & Ilsley Corp. 4.41 56 63,432,326,000 10 KeyCorp 4.13 84 101,596,381,000 11 Wells Fargo & Co. 2.16 709 595,221,000,000 12 Wachovia Corp. 0.96 156 808,575,000,000 13 Citigroup Inc. 0.65 286 2,199,848,000,000 14 National City Corp. 0.46 152 155,046,667,000 15 BB&T Corp. 0.44 143 136,417,064,000 16 Sovereign Bancorp, Inc. 0.37 121 81,906,412,000 17 SunTrust Banks, Inc. 0.32 106 178,986,947,000 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall

Number of SBA Loans Originated to All Minorities Per $5 Billion of Bank Assets, 2008

Huntington Bancshares Inc . US Bancorp Capital One Financ ial Corp. PNC Financial Services Group Comerica Inc . M&T Bank Corp. JP Morgan Chase & Co. Bank of America Marshall & Ilsley Corp. KeyCorp Wells Fargo & Co. Wachovia Corp. Citigroup Inc . National City Corp. BB&T Corp. Sovereign Bancorp, Inc . SunTrust Banks, Inc .

024681012141618

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 10 SBA LENDING TO AFRICAN AMERICANS DATA AND GRADES

The following tables provide the data on lending to African Americans, which, as the data will show, are the racial group most underserved by financial institutions. The grades in the last column of each table are calculated based on the percent of lending target the bank reached, and its position relative to its competitors. The graphs below the data tables illustrate the disparity among the banks in their rates of lending. The banks studied represent the top twenty lenders in the United States, defined as banks with $50 billion in assets or greater, and that have made more than 200 SBA loans in fiscal year 2008.

The Best and the Worst: Lending to African Americans

JP Morgan Chase & Co. 717 TOP TWO Bank of America 308 Number of Loans BOTTOM Sovereign Bancorp, Inc. 11 TWO Marshall & Ilsley Corp. 9

SunTrust Banks, Inc. 14.8% TOP TWO Citigroup Inc. 10.7% Percent of Loans BOTTOM Marshall & Ilsley Corp. 2.8% TWO KeyCorp 2.3%

JP Morgan Chase & Co. $32,950,500 TOP TWO Wachovia Corp. 21,032,200 SBA Lending Volume BOTTOM Marshall & Ilsley Corp. $1,030,000 TWO Sovereign Bancorp, Inc. 540,000

JP Morgan Chase & Co. 2.18 TOP TWO Loan‐to‐Asset Ratio: Bank of America 0.94 Number of Loans per $5 billion in Assets BOTTOM Sovereign Bancorp, Inc. 0.03 TWO Marshall & Ilsley Corp. 0.03

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 11 Ranking of Nationʹs Largest SBA Lenders* by Number of Loans to African Americans

Rank Bank # Loans Total Assets Grade 1 JP Morgan Chase & Co. 717 $1,642,862,000,000 A‐ 2 Bank of America 308 1,743,478,291,000 B‐ 3 US Bancorp 115 241,781,000,000 C 4 Wells Fargo & Co. 104 595,221,000,000 C 5 Capital One Financial Corp. 76 150,608,527,000 D 6 PNC Financial Services Group 70 140,026,464,000 D 7 BB&T Corp. 67 136,417,064,000 D 8 Huntington Bancshares Inc. 56 55,985,225,000 D‐ 9 Citigroup Inc. 53 2,199,848,000,000 D‐ 10 SunTrust Banks, Inc. 46 178,986,947,000 F 11 Wachovia Corp. 43 808,575,000,000 F 12 M&T Bank Corp. 33 66,085,573,000 F 13 National City Corp. 32 155,046,667,000 F 14 Comerica Inc. 17 67,167,320,000 F 15 KeyCorp 15 101,596,381,000 F 16 Sovereign Bancorp, Inc. 11 81,906,412,000 F 17 Marshall & Ilsley Corp. 9 63,432,326,000 F TOTAL 1,772 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall.

Number of SBA Loans Originated to African Americans, 2008

JP Morgan Chase & Co. Bank of America US Bancorp Wells Fargo & Co. Capital One Financ ial Corp. PNC Financ ial Services Group

BB&T Corp.

Huntington Bancshares Inc . Citigroup Inc . SunTrust Banks, Inc . Wachovia Corp. M&T Bank Corp. National City Corp. Comerica Inc . KeyCorp Sovereign Bancorp, Inc .

Marshall & Ilsley Corp.

0 100 200 300 400 500 600 700 800

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 12

Ranking of Nationʹs Largest SBA Lenders* by Percentage of Loans Made to African Americans

% to African # to African Total SBA Rank Bank Americans Americans Loans Grade 1 SunTrust Banks, Inc. 14.8% 46 310 B 2 Citigroup Inc. 10.7% 53 497 B‐ 3 JP Morgan Chase & Co. 9.9% 717 7,218 B‐ 4 Bank of America 9.2% 308 3,351 B‐ 5 BB&T Corp. 8.8% 67 762 B‐ 6 PNC Financial Services Group 6.9% 70 1,018 C 7 Wachovia Corp. 6.2% 43 689 C 8 Capital One Financial Corp. 4.5% 76 1,682 D 9 Comerica Inc. 4.5% 17 382 D 10 Huntington Bancshares Inc. 4.2% 56 1,348 D 11 M&T Bank Corp. 4.1% 33 808 D 12 Wells Fargo & Co. 3.7% 104 2,775 F 13 National City Corp. 3.0% 32 1,078 F 14 US Bancorp 2.9% 115 3,955 F 15 Sovereign Bancorp, Inc. 2.9% 11 385 F 16 Marshall & Ilsley Corp. 2.8% 9 323 F 17 KeyCorp 2.3% 15 644 F TOTAL 6.5% 1,772 27,225 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall.

Percent of SBA Loans Originated to African Americans, 2008 SunTrust Banks, Inc . Citigroup Inc . JP Morgan Chase & Co. Bank of America BB&T Corp. PNC Financ ial Services Group Wachovia Corp. Capital One Financ ial Corp. Comerica Inc . Huntington Bancshares Inc . M&T Bank Corp. Wells Fargo & Co. National City Corp. US Bancorp Sovereign Bancorp, Inc .

Marshall & Ilsley Corp. KeyCorp

0% 2% 4% 6% 8% 10% 12% 14% 16%

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 13 Ranking of Nationʹs Largest SBA Lenders* by Total Dollar Amount to African Americans

Rank Bank SBA Lending Volume 1 JP Morgan Chase & Co. $32,950,500 2 Wachovia Corp. 21,032,200 3 Wells Fargo & Co. 18,713,400 4 BB&T Corp. 13,455,400 5 US Bancorp 11,478,900 6 Huntington Bancshares Inc. 9,041,800 7 Bank of America 8,651,800 8 PNC Financial Services Group 8,217,000 9 Citigroup Inc. 5,507,300 10 Comerica Inc. 5,482,700 11 M&T Bank Corp. 4,973,000 12 SunTrust Banks, Inc. 4,844,086 13 Capital One Financial Corp. 3,455,000 14 KeyCorp 2,330,400 15 National City Corp. 1,671,400 16 Marshall & Ilsley Corp. 1,030,000 17 Sovereign Bancorp, Inc. 540,000 TOTAL $153,374,886 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall.

Total Dollar Amount of SBA Loans Originated to African Americans, 2008

JP Morgan Chase & Co. Wachovia Corp. Wells Fargo & Co. BB&T Corp. US Bancorp Huntington Bancshares Bank of America PNC Financ ial Services Citigroup Inc . Comerica Inc . M&T Bank Corp. SunTrust Banks, Inc . Capital One Financial Corp. KeyCorp National City Corp. Marshall & Ilsley Corp. Sovereign Bancorp, Inc .

0 $0 00 00 0 0 ,00 00, 0, ,0 00 $5 5, 0,000,000 $10,000,000 $1 $20,000,000 $25,000 $3 $35,000,000

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 14 Ranking of Nationʹs Largest SBA Lenders* by Loan‐to‐Asset ratio to African Americans

# of SBA Loans Per Rank Bank $5 Billion in assets # Loans Total Assets 1 JP Morgan Chase & Co. 2.18 717 $1,642,862,000,000 2 Bank of America 0.94 308 1,743,478,291,000 3 US Bancorp 0.35 115 241,781,000,000 4 Wells Fargo & Co. 0.32 104 595,221,000,000 5 Capital One Financial Corp. 0.23 76 150,608,527,000 6 PNC Financial Services Group 0.21 70 140,026,464,000 7 BB&T Corp. 0.20 67 136,417,064,000 8 Huntington Bancshares Inc. 0.17 56 55,985,225,000 9 Citigroup Inc. 0.16 53 2,199,848,000,000 10 SunTrust Banks, Inc. 0.14 46 178,986,947,000 11 Wachovia Corp. 0.13 43 808,575,000,000 12 M&T Bank Corp. 0.10 33 66,085,573,000 13 National City Corp. 0.10 32 155,046,667,000 14 Comerica Inc. 0.05 17 67,167,320,000 15 KeyCorp 0.05 15 101,596,381,000 16 Sovereign Bancorp, Inc. 0.03 11 81,906,412,000 17 Marshall & Ilsley Corp. 0.03 9 63,432,326,000 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall

Number of SBA Loans Originated to African Americans Per $5 Billion of Bank Assets, 2008

JP Morgan Chase & Co. Bank of America US Bancorp Wells Fargo & Co. Capital One Financial Corp. PNC Financial Services Group BB&T Corp. Huntington Bancshares Inc . Citigroup Inc . SunTrust Banks, Inc . Wachovia Corp. M&T Bank Corp. National City Corp. Comerica Inc . KeyCorp Sovereign Bancorp, Inc . Marshall & Ilsley Corp.

011223

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 15 SBA LENDING TO ASIAN AMERICANS DATA AND GRADES

The following tables provide the data on lending to Asian Americans. The grades in the last column of each table are calculated based on the percent of lending target the bank reached, and its position relative to its competitors. The graphs below the data tables illustrate the disparity among the banks in their rates of lending. The banks studied represent the top twenty lenders in the United States, defined as banks with $50 billion in assets or greater, and that have made more than 200 SBA loans in fiscal year 2008.

The Best and the Worst: Lending to Asian Americans

JP Morgan Chase & Co. 914 TOP TWO Bank of America 592 Number of Loans BOTTOM SunTrust Banks, Inc. 31 TWO Marshall & Ilsley Corp. 13

Citigroup Inc. 25.2% TOP TWO Bank of America 17.7% Percent of Loans BOTTOM M&T Bank Corp. 5.1% TWO Marshall & Ilsley Corp. 4.0%

Wells Fargo & Co. $81,646,600 TOP TWO US Bancorp 63,111,300 SBA Lending Volume BOTTOM KeyCorp $3,176,800 TWO Marshall & Ilsley Corp. 1,347,000

JP Morgan Chase & Co. 2.78 TOP TWO Loan‐to‐Asset Ratio: Bank of America 1.80 Number of Loans per $5 billion in Assets BOTTOM SunTrust Banks, Inc. 0.09 TWO Marshall & Ilsley Corp. 0.04

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 16 Ranking of Nationʹs Largest SBA Lenders* by Number of Loans to Asian Americans

Rank Bank # Loans Total Assets Grades 1 JP Morgan Chase & Co. 914 $1,642,862,000,000 A‐ 2 Bank of America 592 1,743,478,291,000 B 3 US Bancorp 358 241,781,000,000 C+ 4 Wells Fargo & Co. 319 595,221,000,000 C+ 5 PNC Financial Services Group 150 140,026,464,000 C‐ 6 Capital One Financial Corp. 134 150,608,527,000 C‐ 7 Citigroup Inc. 125 2,199,848,000,000 C‐ 8 Huntington Bancshares Inc. 104 55,985,225,000 C‐ 9 National City Corp. 67 155,046,667,000 D 10 Sovereign Bancorp, Inc. 66 81,906,412,000 D 11 Wachovia Corp. 57 808,575,000,000 D 12 Comerica Inc. 51 67,167,320,000 D 13 BB&T Corp. 50 136,417,064,000 D 14 M&T Bank Corp. 41 66,085,573,000 F 15 KeyCorp 39 101,596,381,000 F 16 SunTrust Banks, Inc. 31 178,986,947,000 F 17 Marshall & Ilsley Corp. 13 63,432,326,000 FF TOTAL 3,111 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall

Number of SBA Loans Originated to Asian Americans, 2008

JP Morgan Chase & Co. Bank of America US Bancorp Wells Fargo & Co. PNC Financ ial Services Group Capital One Financ ial Corp. Citigroup Inc . Huntington Bancshares Inc . National City Corp. Sovereign Bancorp, Inc . Wachovia Corp. Comerica Inc . BB&T Corp. M&T Bank Corp. KeyCorp SunTrust Banks, Inc . Marshall & Ilsley Corp.

0 100 200 300 400 500 600 700 800 900 1,000

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 17 Ranking of Nationʹs Largest SBA Lenders* by Percentage of Loans Made to Asian Americans

Rank Bank % to Asian Americans # to Asian Americans Total SBA Loans Grade 1 Citigroup Inc. 25.2% 125 497 A 2 Bank of America 17.7% 592 3,351 B+ 3 Sovereign Bancorp, Inc. 17.1% 66 385 B+ 4 PNC Financial Services Group 14.7% 150 1,018 B 5 Comerica Inc. 13.4% 51 382 B 6 JP Morgan Chase & Co. 12.7% 914 7,218 B 7 Wells Fargo & Co. 11.5% 319 2,775 B‐ 8 SunTrust Banks, Inc. 10.0% 31 310 B‐ 9 US Bancorp 9.1% 358 3,955 C+ 10 Wachovia Corp. 8.3% 57 689 C+ 11 Capital One Financial Corp. 8.0% 134 1,682 C+ 12 Huntington Bancshares Inc. 7.7% 104 1,348 C 13 BB&T Corp. 6.6% 50 762 C‐ 14 National City Corp. 6.2% 67 1,078 C‐ 15 KeyCorp 6.1% 39 644 C‐ 16 M&T Bank Corp. 5.1% 41 808 D 17 Marshall & Ilsley Corp. 4.0% 13 323 F TOTAL 11.4% 3,111 27,225 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall.

Percent of SBA Loans Originated to Asian Americans, 2008

Citigroup Inc . Bank of America Sovereign Bancorp, Inc . PNC Financial Services Group Comerica Inc . JP Morgan Chase & Co. Wells Fargo & Co. SunTrust Banks, Inc . US Bancorp Wachovia Corp. Capital One Financ ial Corp. Huntington Bancshares Inc . BB&T Corp. National City Corp. KeyCorp M&T Bank Corp. Marshall & Ilsley Corp.

0% 5% 10% 15% 20% 25% 30%

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 18 Ranking of Nationʹs Largest SBA Lenders* by Total Dollar Amount to Asian Americans

Rank Bank SBA Lending Volume 1 Wells Fargo & Co. $81,646,600 2 US Bancorp 63,111,300 3 JP Morgan Chase & Co. 50,931,900 4 Huntington Bancshares Inc. 45,305,300 5 Wachovia Corp. 43,721,100 6 Comerica Inc. 28,288,200 7 PNC Financial Services Group 27,051,600 8 Bank of America 20,706,900 9 BB&T Corp. 11,830,400 10 Citigroup Inc. 8,862,000 11 Capital One Financial Corp. 6,735,000 12 National City Corp. 5,749,400 13 Sovereign Bancorp, Inc. 5,196,900 14 M&T Bank Corp. 5,034,700 15 SunTrust Banks, Inc. 3,639,000 16 KeyCorp 3,176,800 17 Marshall & Ilsley Corp. 1,347,000 TOTAL $412,334,100 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall.

Total Dollar Amount of SBA Loans Originated to Asian Americans, 2008

Wells Fargo & Co. US Bancorp JP Morgan Chase & Co. Huntington Bancshares Inc . Wachovia Corp. Comerica Inc . PNC Financ ial Services Group Bank of America BB&T Corp. Citigroup Inc . Capital One Financ ial Corp. National City Corp. Sovereign Bancorp, Inc . M&T Bank Corp. SunTrust Banks, Inc . KeyCorp Marshall & Ilsley Corp.

0 0 0 0 0 0 $0 0 0 0 0 0 0 ,000 ,0 ,0 ,0 ,0 00 00 00 00 0 ,0 ,0 ,000 ,0 ,000,0 ,000,0 20 30 40 50 60 70 $10, $ $ $ $ $ $ $80,000,000 $90,000,000

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 19 Ranking of Nationʹs Largest SBA Lenders* by Loan‐to‐Asset ratio to Asian Americans

# of SBA Loans Per Rank Bank $5 Billion in assets # Loans Total Assets 1 JP Morgan Chase & Co. 2.78 914 $1,642,862,000,000 2 Bank of America 1.80 592 1,743,478,291,000 3 US Bancorp 1.09 358 241,781,000,000 4 Wells Fargo & Co. 0.97 319 595,221,000,000 5 PNC Financial Services Group 0.46 150 140,026,464,000 6 Capital One Financial Corp. 0.41 134 150,608,527,000 7 Citigroup Inc. 0.38 125 2,199,848,000,000 8 Huntington Bancshares Inc. 0.32 104 55,985,225,000 9 National City Corp. 0.20 67 155,046,667,000 10 Sovereign Bancorp, Inc. 0.20 66 81,906,412,000 11 Wachovia Corp. 0.17 57 808,575,000,000 12 Comerica Inc. 0.16 51 67,167,320,000 13 BB&T Corp. 0.15 50 136,417,064,000 14 M&T Bank Corp. 0.12 41 66,085,573,000 15 KeyCorp 0.12 39 101,596,381,000 16 SunTrust Banks, Inc. 0.09 31 178,986,947,000 17 Marshall & Ilsley Corp. 0.04 13 63,432,326,000 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall

Number of SBA Loans Originated to Asian Americans Per $5 Billion of Bank Assets, 2008

JP Morgan Chase & Co. Bank of America US Bancorp Wells Fargo & Co. PNC Financial Services Group Capital One Financial Corp. Citigroup Inc . Huntington Bancshares Inc . National City Corp. Sovereign Bancorp, Inc . Wachovia Corp. Comerica Inc . BB&T Corp. M&T Bank Corp. KeyCorp SunTrust Banks, Inc . Marshall & Ilsley Corp.

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ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 20 SBA LENDING TO LATINOS DATA AND GRADES

The following tables provide the data on lending to Latinos. The grades in the last column of each table are calculated based on the percent of lending target the bank reached, and its position relative to its competitors. The graphs below the data tables illustrate the disparity among the banks in their rates of lending. The banks studied represent the top twenty lenders in the United States, defined as banks with $50 billion in assets or greater, and that have made more than 200 SBA loans in fiscal year 2008.

The Best and the Worst: Lending to Latinos

JP Morgan Chase & Co. 725 TOP TWO Bank of America 637 Number of Loans BOTTOM M&T Bank Corp. 23 TWO Huntington Bancshares Inc. 20

Citigroup Inc. 21.5% TOP TWO Bank of America 19.0% Percent of Loans BOTTOM M&T Bank Corp. 2.8% TWO Huntington Bancshares Inc. 1.5%

Wells Fargo & Co. $54,522,000 TOP TWO JP Morgan Chase & Co. 36,230,900 Total Dollar Amount BOTTOM SunTrust Banks, Inc. 2,699,700 TWO Marshall & Ilsley Corp. 2,394,500

JP Morgan Chase & Co. 2.21 TOP TWO Loan‐to‐Asset Ratio: Bank of America 1.94 Number of Loans per $5 billion in Assets BOTTOM M&T Bank Corp. 0.07 TWO Huntington Bancshares Inc. 0.06

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 21 Ranking of Nationʹs Largest SBA Lenders* by Number of Loans to Latinos

Rank Bank # Loans Total Assets Grade 1 JP Morgan Chase & Co. 725 $1,642,862,000,000 B+ 2 Bank of America 637 1,743,478,291,000 B+ 3 Wells Fargo & Co. 254 595,221,000,000 B‐ 4 US Bancorp 219 241,781,000,000 B‐ 5 Capital One Financial Corp. 114 150,608,527,000 C 6 Citigroup Inc. 107 2,199,848,000,000 C 7 PNC Financial Services Group 64 140,026,464,000 D 8 Wachovia Corp. 49 808,575,000,000 F 9 National City Corp. 47 155,046,667,000 F 10 Comerica Inc. 42 67,167,320,000 F 11 Sovereign Bancorp, Inc. 37 81,906,412,000 F 12 Marshall & Ilsley Corp. 30 63,432,326,000 F 13 KeyCorp 28 101,596,381,000 F 14 SunTrust Banks, Inc. 26 178,986,947,000 F 15 BB&T Corp. 25 136,417,064,000 F 16 M&T Bank Corp. 23 66,085,573,000 F 17 Huntington Bancshares Inc. 20 55,985,225,000 F TOTAL 2,447 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall

Number of SBA Loans Originated to Latinos, 2008

JP Morgan Chase & Co. Bank of America

Wells Fargo & Co. US Bancorp Capital One Financial Corp. Citigroup Inc . PNC Financial Services Group Wachovia Corp. National City Corp. Comerica Inc . Sovereign Bancorp, Inc .

Marshall & Ilsley Corp.

KeyCorp SunTrust Banks, Inc . BB&T Corp. M&T Bank Corp. Huntington Bancshares Inc .

0 100 200 300 400 500 600 700 800

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 22 Ranking of Nationʹs Largest SBA Lenders* by Percentage of Loans Made to Latinos

Rank Bank % to Latinos # to Latinos Total SBA Loans Grade 1 Citigroup Inc. 21.5% 107 497 A 2 Bank of America 19.0% 637 3,351 A‐ 3 Comerica Inc. 11.0% 42 382 C 4 JP Morgan Chase & Co. 10.0% 725 7,218 C 5 Sovereign Bancorp, Inc. 9.6% 37 385 C 6 Marshall & Ilsley Corp. 9.3% 30 323 C 7 Wells Fargo & Co. 9.2% 254 2,775 C 8 SunTrust Banks, Inc. 8.4% 26 310 C‐ 9 Wachovia Corp. 7.1% 49 689 C‐ 10 Capital One Financial Corp. 6.8% 114 1,682 C‐ 11 PNC Financial Services Group 6.3% 64 1,018 D+ 12 US Bancorp 5.5% 219 3,955 D 13 National City Corp. 4.4% 47 1,078 D 14 KeyCorp 4.3% 28 644 D 15 BB&T Corp. 3.3% 25 762 F 16 M&T Bank Corp. 2.8% 23 808 F 17 Huntington Bancshares Inc. 1.5% 20 1,348 F TOTAL 9.0% 2,447 27,225 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall.

Percent of SBA Loans Originated to Latinos, 2008

Citigroup Inc . Bank of America Comerica Inc . JP Morgan Chase & Co. Sovereign Bancorp, Inc . Marshall & Ilsley Corp. Wells Fargo & Co. SunTrust Banks, Inc . Wachovia Corp. Capital One Financial Corp. PNC Financial Services Group US Bancorp National City Corp. KeyCorp BB&T Corp. M&T Bank Corp. Huntington Bancshares Inc .

0% 5% 10% 15% 20% 25%

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 23 Ranking of Nationʹs Largest SBA Lenders* by Total Dollar Amount to Latinos

Rank Bank Total SBA Lending 1 Wells Fargo & Co. $54,522,000 2 JP Morgan Chase & Co. 36,230,900 3 Bank of America 24,204,400 4 Wachovia Corp. 23,907,200 5 US Bancorp 22,994,600 6 Comerica Inc. 19,371,900 7 PNC Financial Services Group 10,438,700 8 BB&T Corp. 6,809,500 9 Citigroup Inc. 5,793,600 10 Capital One Financial Corp. 5,110,000 11 KeyCorp 3,720,000 12 M&T Bank Corp. 3,653,200 13 Huntington Bancshares Inc. 3,623,900 14 National City Corp. 3,533,500 15 Sovereign Bancorp, Inc. 3,154,900 16 SunTrust Banks, Inc. 2,699,700 17 Marshall & Ilsley Corp. 2,394,500 TOTAL $232,162,500 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall.

Total Dollar Amount of SBA Loans Originated to Asian Americans, 2008

Wells Fargo & Co. JP Morgan Chase & Co. Bank of America Wachovia Corp. US Bancorp Comerica Inc . PNC Financ ial Services Group BB&T Corp. Citigroup Inc . Capital One Financ ial Corp. KeyCorp M&T Bank Corp. Huntington Bancshares Inc . National City Corp. Sovereign Bancorp, Inc . SunTrust Banks, Inc . Marshall & Ilsle y Corp.

$0 ,000 ,000 ,000 ,000 ,000 ,000 00 00 00 00 00 00 ,0 ,0 ,0 10,0 20,0 30,0 40 50 60 $ $ $ $ $ $

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 24 Ranking of Nationʹs Largest SBA Lenders* by Loan‐to‐Asset ratio to Latinos

# of SBA Loans Per Rank Bank $5 Billion in assets # Loans Total Assets 1 JP Morgan Chase & Co. 2.21 725 $1,642,862,000,000 2 Bank of America 1.94 637 1,743,478,291,000 3 Wells Fargo & Co. 0.77 254 595,221,000,000 4 US Bancorp 0.67 219 241,781,000,000 5 Capital One Financial Corp. 0.35 114 150,608,527,000 6 Citigroup Inc. 0.33 107 2,199,848,000,000 7 PNC Financial Services Group 0.19 64 140,026,464,000 8 Wachovia Corp. 0.15 49 808,575,000,000 9 National City Corp. 0.14 47 155,046,667,000 10 Comerica Inc. 0.13 42 67,167,320,000 11 Sovereign Bancorp, Inc. 0.11 37 81,906,412,000 12 Marshall & Ilsley Corp. 0.09 30 63,432,326,000 13 KeyCorp 0.09 28 101,596,381,000 14 SunTrust Banks, Inc. 0.08 26 178,986,947,000 15 BB&T Corp. 0.08 25 136,417,064,000 16 M&T Bank Corp. 0.07 23 66,085,573,000 17 Huntington Bancshares Inc. 0.06 20 55,985,225,000 *Defined as banks with over $50 billion in assets and that made over 200 SBA loans overall.

Number of SBA Loans Originated to Asian Americans Per $5 Billion of Bank Assets, 2008

JP Morgan Chase & Co. Bank of America Wells Fargo & Co. US Bancorp Capital One Financ ial Corp. Citigroup Inc . PNC Financ ial Services Group Wachovia Corp. National City Corp. Comerica Inc .

Sovereign Bancorp, Inc . Marshall & Ilsley Corp. KeyCorp SunTrust Banks, Inc . BB&T Corp. M&T Bank Corp. Huntington Bancshares Inc .

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ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 25 CHANGE IN PERFORMANCE 2007‐2008

The tables below rank the banks by the change in their performance since the last fiscal year in lending by number and percentage of all loans made. 2007 figures are from last year’s edition of this report. Three banks that were included in last year’s analysis: Union Bank of California, Corp., HSBC Bank USA, N.A., and Fifth Third Bancorp were not included in the report this year, because they originated less than 200 SBA loans in fiscal year 2008. Additionally, two new banks met the criteria for inclusion this year: Huntington Bancshares and Marshall & Ilsley Corp.

JP Morgan Chase expanded its SBA lending to minorities by originating 1214.13 percent more loans this year compared to last year, the greatest expansion among all banks. Wachovia and Citibank continue to rank in the top half of banks that have expanded their SBA lending to minorities year after year, increasing the number of loans originated to all minorities from 2007‐2008 by 300% and 140.34%, respectively, and 275.51% and 136.20% respectively, from 2006‐2007.

Citibank made a strong push this year in the percent of its SBA originations to minorities, making 45.05 percent more of its loans to minorities, edging out Bank of America for the top spot in that category.

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 26 Change in Performance of Nationʹs Largest SBA Lenders In Lending to All Minorities

Percent Change in Number of SBA Loans Made to All Minorities # SBA Loans Made # SBA Loans Made Rank Bank 2008 2007 % Change 1 JP Morgan Chase & Co. 2,418 184 1214.13% 2 Bank of America 1,560 127 1128.35% 3 Wachovia Corp. 156 39 300.00% 4 Citigroup Inc. 286 119 140.34% 5 SunTrust Banks, Inc. 106 72 47.22% 6 Huntington Bancshares Inc. 198 156 26.92% 7 Comerica Inc. 113 101 11.88% 8 US Bancorp 729 1,044 ‐30.17% 9 Capital One Financial Corp. 334 491 ‐31.98% 10 BB&T Corp. 143 215 ‐33.49% 11 Marshall & Ilsley Corp. 56 177 ‐68.36% 12 PNC Financial Services Group 298 1,153 ‐74.15% 13 Wells Fargo & Co. 709 2,947 ‐75.94% 14 Sovereign Bancorp, Inc. 121 812 ‐85.10% 15 M&T Bank Corp. 100 703 ‐85.78% 16 National City Corp. 152 1,148 ‐86.76% 17 KeyCorp 84 5,468 ‐98.46% TOTAL 7,563 14,956 ‐49.43%

Percent Change in Percent of SBA Loans Made to All Minorities % SBA Loans Made % SBA Loans Made Rank Bank 2008 2007 % Change 1 Citigroup Inc. 57.55% 12.50% 45.05% 2 Comerica Inc. 29.58% 12.80% 16.78% 3 Sovereign Bancorp, Inc. 31.43% 15.60% 15.83% 4 Bank of America 46.55% 38.50% 8.05% 5 BB&T Corp. 18.77% 14.30% 4.47% 6 JP Morgan Chase & Co. 33.50% 32.50% 1.00% 7 Huntington Bancshares Inc. 14.69% 16.20% ‐1.51% 8 Wachovia Corp. 22.64% 25.50% ‐2.86% 9 US Bancorp 18.43% 21.30% ‐2.87% 10 SunTrust Banks, Inc. 34.19% 39.00% ‐4.81% 11 M&T Bank Corp. 12.38% 21.50% ‐9.12% 12 Marshall & Ilsley Corp. 17.34% 27.10% ‐9.76% 13 Capital One Financial Corp. 19.86% 35.40% ‐15.54% 14 KeyCorp 13.04% 32.40% ‐19.36% 15 National City Corp. 14.10% 34.50% ‐20.40% 16 Wells Fargo & Co. 25.55% 49.80% ‐24.25% 17 PNC Financial Services Group 29.27% 56.00% ‐26.73% AVERAGE 25.82% 28.52% ‐2.71%

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 27 Change in Performance of Nationʹs Largest SBA Lenders In Lending to African Americans

Percent Change in Number of SBA Loans Made to African Americans # SBA Loans Made # SBA Loans Made Rank Bank 2008 2007 % Change 1 JP Morgan Chase & Co. 717 52 1278.85% 2 Bank of America 308 55 460.00% 3 PNC Financial Services Group 70 18 288.89% 4 Huntington Bancshares Inc. 56 15 273.33% 5 Citigroup Inc. 53 20 165.00% 6 Wachovia Corp. 43 23 86.96% 7 BB&T Corp. 67 47 42.55% 8 US Bancorp 115 116 ‐0.86% 9 Marshall & Ilsley Corp. 9 11 ‐18.18% 10 Capital One Financial Corp. 76 220 ‐65.45% 11 National City Corp. 32 112 ‐71.43% 12 SunTrust Banks, Inc. 46 163 ‐71.78% 13 Sovereign Bancorp, Inc. 11 39 ‐71.79% 14 Wells Fargo & Co. 104 632 ‐83.54% 15 M&T Bank Corp. 33 254 ‐87.01% 16 Comerica Inc. 17 154 ‐88.96% 17 KeyCorp 15 1,422 ‐98.95% TOTAL 1,772 3,353 ‐47.15%

Percent Change in Percent of SBA Loans Made to African Americans % SBA Loans Made % SBA Loans Made Rank Bank 2008 2007 % Change 1 SunTrust Banks, Inc. 14.84% 2.60% 12.24% 2 Bank of America 9.19% 4.90% 4.29% 3 PNC Financial Services Group 6.88% 2.80% 4.08% 4 Citigroup Inc. 10.66% 7.80% 2.86% 5 BB&T Corp. 8.79% 7.00% 1.79% 6 M&T Bank Corp. 4.08% 3.80% 0.28% 7 Wells Fargo & Co. 3.75% 3.50% 0.25% 8 Huntington Bancshares Inc. 4.15% 4.10% 0.05% 9 Capital One Financial Corp. 4.52% 4.50% 0.02% 10 National City Corp. 2.97% 4.10% ‐1.13% 11 Comerica Inc. 4.45% 6.20% ‐1.75% 12 US Bancorp 2.91% 4.90% ‐1.99% 13 Wachovia Corp. 6.24% 8.60% ‐2.36% 14 JP Morgan Chase & Co. 9.93% 13.00% ‐3.07% 15 KeyCorp 2.33% 5.90% ‐3.57% 16 Sovereign Bancorp, Inc. 2.86% 7.40% ‐4.54% 17 Marshall & Ilsley Corp. 2.79% 7.60% ‐4.81% AVERAGE 5.96% 5.81% 0.16%

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 28 Change in Performance of Nationʹs Largest SBA Lenders In Lending to Asian Americans

Percent Change in Number of SBA Loans Made to Asian Americans # SBA Loans Made # SBA Loans Made Rank Bank 2008 2007 % Change 1 JP Morgan Chase & Co. 914 73 1152.05% 2 Citigroup Inc. 125 26 380.77% 3 Wachovia Corp. 57 12 375.00% 4 Wells Fargo & Co. 319 81 293.83% 5 Huntington Bancshares Inc. 104 37 181.08% 6 BB&T Corp. 50 43 16.28% 7 SunTrust Banks, Inc. 31 43 ‐27.91% 8 US Bancorp 358 560 ‐36.07% 9 Comerica Inc. 51 103 ‐50.49% 10 Bank of America 592 1,252 ‐52.72% 11 M&T Bank Corp. 41 107 ‐61.68% 12 Capital One Financial Corp. 134 398 ‐66.33% 13 PNC Financial Services Group 150 495 ‐69.70% 14 National City Corp. 67 304 ‐77.96% 15 Marshall & Ilsley Corp. 13 91 ‐85.71% 16 KeyCorp 39 404 ‐90.35% 17 Sovereign Bancorp, Inc. 66 1,938 ‐96.59% TOTAL 3,111 5,967 ‐47.86%

Percent Change in Percent of SBA Loans Made to Asian Americans % SBA Loans Made % SBA Loans Made Rank Bank 2008 2007 % Change 1 JP Morgan Chase & Co. 12.66% 30.00% ‐17.34% 2 Wells Fargo & Co. 11.50% 14.60% ‐3.10% 3 Wachovia Corp. 8.27% 15.50% ‐7.23% 4 US Bancorp 9.05% 16.90% ‐7.85% 5 SunTrust Banks, Inc. 10.00% 6.10% 3.90% 6 Sovereign Bancorp, Inc. 17.14% 13.50% 3.64% 7 PNC Financial Services Group 14.73% 10.70% 4.03% 8 National City Corp. 6.22% 17.70% ‐11.48% 9 Marshall & Ilsley Corp. 4.02% 8.00% ‐3.98% 10 M&T Bank Corp. 5.07% 4.60% 0.47% 11 KeyCorp 6.06% 4.70% 1.36% 12 Huntington Bancshares Inc. 7.72% 20.30% ‐12.58% 13 Comerica Inc. 13.35% 3.80% 9.55% 14 Citigroup Inc. 25.15% 9.20% 15.95% 15 Capital One Financial Corp. 7.97% 9.20% ‐1.23% 16 BB&T Corp. 6.56% 4.80% 1.76% 17 Bank of America 17.67% 13.90% 3.77% AVERAGE 10.77% 11.97% ‐1.20%

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 29 Change in Performance of Nationʹs Largest SBA Lenders In Lending to Latinos

Percent Change in Number of SBA Loans Made to Latinos # SBA Loans Made # SBA Loans Made Rank Bank 2008 2007 % Change 1 Wells Fargo & Co. 254 50 408.00% 2 Wachovia Corp. 49 15 226.67% 3 US Bancorp 219 50 338.00% 4 SunTrust Banks, Inc. 26 20 30.00% 5 Sovereign Bancorp, Inc. 37 303 ‐87.79% 6 PNC Financial Services Group 64 485 ‐86.80% 7 National City Corp. 47 395 ‐88.10% 8 Marshall & Ilsley Corp. 30 30 0.00% 9 M&T Bank Corp. 23 135 ‐82.96% 10 KeyCorp 28 30 ‐6.67% 11 JP Morgan Chase & Co. 725 27 2585.19% 12 Huntington Bancshares Inc. 20 996 ‐97.99% 13 Comerica Inc. 42 53 ‐20.75% 14 Citigroup Inc. 107 2,041 ‐94.76% 15 Capital One Financial Corp. 114 362 ‐68.51% 16 BB&T Corp. 25 64 ‐60.94% 17 Bank of America 637 253 151.78% TOTAL 2,447 5,309 ‐53.91%

Percent Change in Percent of SBA Loans Made to Latinos % SBA Loans Made % SBA Loans Made Rank Bank 2008 2007 % Change 1 Citigroup Inc. 21.53% 2.60% 18.93% 2 Bank of America 19.01% 3.50% 15.51% 3 SunTrust Banks, Inc. 8.39% 3.20% 5.19% 4 Sovereign Bancorp, Inc. 9.61% 4.80% 4.81% 5 Marshall & Ilsley Corp. 9.29% 7.10% 2.19% 6 National City Corp. 4.36% 4.20% 0.16% 7 Capital One Financial Corp. 6.78% 6.80% ‐0.02% 8 KeyCorp 4.35% 4.80% ‐0.45% 9 JP Morgan Chase & Co. 10.04% 11.00% ‐0.96% 10 PNC Financial Services Group 6.29% 7.40% ‐1.11% 11 US Bancorp 5.54% 10.40% ‐4.86% 12 Comerica Inc. 10.99% 16.50% ‐5.51% 13 Huntington Bancshares Inc. 1.48% 9.60% ‐8.12% 14 M&T Bank Corp. 2.85% 11.70% ‐8.85% 15 Wells Fargo & Co. 9.15% 18.60% ‐9.45% 16 Wachovia Corp. 7.11% 19.40% ‐12.29% 17 BB&T Corp. 3.28% 17.20% ‐13.92%

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 30 IS BIG FINANCIAL SERVING SMALL BUSINESS?

Commitment to Minorities is More Important than Bank Size Our analysis shows that although the largest banks in our study tend to make more loans to minorities as a whole, there is little other correlation between a bank’s size and its minority lending performance. More importantly, there is also no correlation between the size of the bank’s SBA division (defined as the number of SBA loans originated annually) and the percentage of those loans that are originated to current or prospective minority entrepreneurs. Figure 1 presents the banks in our study by increasing total loan volume in 2008 (blue line), and shows the corresponding percent of loans originated by that bank to minority entrepreneurs (red bars).

Figure 1

Percent of SBA Loans Originated to Minorities vs. Total Loans Originated Number 70% 8000

60% 7000 of

SBA Minorities

6000

50% Loans to

5000

40% Originated 4000 Originated

30% 3000

Loans 20%

2000 Fiscal of

10% 1000 Year Percent

0% 0 2007

. . c. . c. p nc p c rp. rp. rp. rp. I or In In or o o Inc. o Co. Co. , In C Corp. C ks C a , C Co C & & n p up a k Group ancorp ey or ro Key i America B Ba sl c ig ov an City of t Il it h B US omeric an BB&T inancial Fargo Chase us & C B C F s ll Services Bancshares l n Tr a gn Wac tional Bank n M&T a rga u ei N One Wel S rsh er a v al Mo M t So JP Financial HuntingtonCapi PNC % Loans to Min. Total # Loans Orig.

For example, the data shows that Citigroup, which originated only 29.5% as many SBA loans in fiscal year 2008 than US Bancorp, actually originated 39.1% more of its SBA loans to minorities than its competitor.

This analysis indicates that a major factor in determining a bank’s lending rate to minorities is their corporate commitment to serving a diverse client base, not the size of its lending division, or even the size of the bank itself.

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 31 Smaller Banks Outperform Larger Banks It should be noted that if this study were to include the SBA lending figures for all banks, regardless of asset size, many of the major financial institutions would lose their leadership ranking. Two banks: Innovative Bank (Oakland, CA, 5,000 loans to minorities, 78.3% of their total loan number), and Banco Popular (Mount Laurel, 1,000 loans to minorities, 45.5% of their total loan number), were among the top banks in SBA lending to minorities, despite their much smaller asset sizes. In fact, if Innovative Bank were included in the parameters of our study, would take the number one spot in both number of loans and percentage of loans.

This analysis shows that all banks, regardless of asset size, should demonstrate greater commitment to minority entrepreneurs by making more loans to minorities proportional to the total number of loans they originate annually.

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 32 SPECIAL SECTION: SBA LENDING TO MINORITIES BY BAILOUT BANKS

To date, the Federal Reserve has disbursed nearly $239 billion in bailout funds to 103 banks across the country. The largest share of the bailout funds went to the nation’s largest banks, Citigroup, AIG, Wells Fargo, Bank of America, JP Morgan Chase, Goldman Sachs, and Morgan Stanley, which together received whopping 75 percent of all bailout funds so far disbursed.

Of the 103 banks below, 18 made no SBA loans at all, and 14 made no loans to minority entrepreneurs. Altogether, all the bailout banks made $1,170,045,021 in SBA loans to minority small businesses in fiscal year 2008, and received $238,749,700,000 in bailout funds. This means that for every $1 in bailout funds these banks received, minority small businesses received less than one penny in loans ($0.007).

Greenlining recommends that in the wake of the current wave of bank restructuring, financial institutions – particularly the restructured investment banks – should expand their investment in minority business enterprises. As we have stated previously, small businesses are the backbone of innovation in our industries, the largest job producers, and the main source of economic activity in our nation’s disadvantaged communities.

Government support and guarantees have strengthened the position of many financial institutions, creating ideal conditions for their partnership with the SBA to become advocates for minority small business.

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 33 Ranking of Financial Institutions Receiving Bailout Monies in SBA Lending to Minorities, Number of SBA Loans to Minorities # Loans to % Loans to Loan Bailout Rank Bank Minorities Minorities Volume Amount 1 JP Morgan Chase 2,418 33.5% $123,697,600 $25,000,000,000 2 Bank of America (incl. Merrill Lynch) 1,560 46.6% $54,152,100 $25,000,000,000 3 Popular, Inc. 1,000 45.5% $79,569,500 $950,000,000 4 U.S. Bancorp 729 18.4% $99,692,800 $6,599,000,000 5 Wells Fargo 709 25.5% $162,392,500 $25,000,000,000 6 Capital One 334 19.9% $15,675,000 $3,555,200,000 7 PNC 298 29.3% $47,962,700 $7,700,000,000 8 Citigroup 286 57.5% $20,252,900 $45,000,000,000 9 Huntington Bancshares 198 14.7% $58,694,000 $1,398,100,000 10 Wilshire Bancorp 169 84.9% $62,659,900 $62,000,000 11 BB&T 143 18.8% $32,195,300 $3,133,600,000 12 Comerica 113 29.6% $55,669,300 $2,250,000,000 13 SunTrust 106 34.2% $11,454,786 $3,500,000,000 14 M&T Bank Corporation 100 12.4% $13,982,900 $600,000,000 15 Center Financial Corp 95 90.5% $42,120,600 $55,000,000 16 Nara Bancorp 92 86.0% $52,841,000 $67,000,000 17 KeyCorp 84 13.0% $9,547,200 $2,500,000,000 18 Associated Bank‐Corp 66 10.9% $4,341,500 $525,000,000 19 Community West Bancshares 60 41.7% $21,419,400 $15,600,000 20 Marshall & Ilsley 56 17.3% $5,006,500 $1,715,000,000 21 UCBH Holdings 51 83.6% $9,419,000 $298,700,000 22 Regions Financial 48 27.1% $13,410,800 $3,500,000,000 23 Fifth Third 42 21.8% $13,486,900 $3,450,000,000 24 Fidelity Southern Corp 38 70.4% $26,099,000 $48,200,000 25 Pacific Capital Bancorp 34 22.1% $19,648,500 $188,000,000 26 Valley National 33 30.3% $8,192,500 $330,000,000 27 Susquehanna Bancshares 29 23.0% $10,275,000 $300,000,000 28 Provident Bancshares 26 44.8% $1,445,200 $151,000,000 29 Heritage Commerce Corp 22 48.9% $12,703,700 $40,000,000 30 Citizens Republic Bancorp 21 11.9% $5,311,500 $300,000,000 30 Webster Financial 21 18.8% $4,007,000 $400,000,000 31 East West Bancorp 20 57.1% $4,964,500 $316,000,000 31 Synovus 20 20.4% $7,003,900 $973,000,000 32 Trustmark Corp 18 14.4% $1,930,525 $215,000,000 33 Sandy Spring Bancorp 17 53.1% $4,844,200 $83,000,000 34 First Financial 14 12.1% $4,066,000 $80,000,000 35 City National 12 26.7% $4,051,700 $395,000,000 35 Sterling Financial Corp 12 29.3% $6,331,100 $303,000,000 36 Boston Private Financial Holdings 11 28.2% $3,110,000 $150,000,000 37 First Niagara 10 5.7% $996,600 $186,000,000 38 Umpqua 9 14.5% $3,382,000 $214,200,000 39 Home Bancshares, Inc. 8 24.2% $1,462,800 $50,000,000 40 Peoples Bancorp 6 21.4% $715,000 $39,000,000 40 Wilmington Trust Corporation 6 14.0% $981,700 $330,000,000

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 34 41 Cathay General Bancorp 5 45.5% $2,679,000 $258,000,000 41 Eagle Bancorp 5 38.5% $7,985,000 $38,200,000 41 Heritage Financial 5 11.6% $2,032,000 $24,000,000 42 Banner Corp 4 20.0% $500,900 $124,000,000 42 First Defiance Financial Corp 4 26.7% $1,803,925 $37,000,000 42 FirstMerit Corp 4 4.7% $439,200 $248,000,000 42 Intermountain Cmty. Bancorp 4 6.8% $713,000 $27,000,000 42 Superior Bancorp 4 6.7% $227,400 $69,000,000 43 CenterState Banks of Florida 3 60.0% $600,000 $27,900,000 43 CVB Finanical 3 14.3% $760,000 $130,000,000 43 IBERIABANK Corp 3 60.0% $2,168,000 $115,000,000 43 Signature Bank 3 23.1% $765,000 $120,000,000 43 Simmons First National 3 23.1% $825,000 $40,000,000 43 Southern Community Financial 3 37.5% $775,000 $42,800,000 43 VIST Financial Corp 3 9.4% $275,000 $25,000,000 43 Western Alliance Bancorporation 3 21.4% $1,161,000 $140,000,000 44 Ameris Bancorp 2 40.0% $1,005,000 $52,000,000 44 United Community Banks 2 18.2% $2,565,000 $180,000,000 45 Bank of Commerce 1 33.3% $30,000 $17,000,000 45 Capital Bank 1 14.3% $115,000 $42,900,000 45 Capital Pacific Bancorp 1 50.0% $633,200 $4,000,000 45 Columbia Banking System 1 5.3% $26,000 $76,900,000 45 Northern Trust 1 100.0% $500,000 $1,576,000,000 45 Porter Bancorp 1 6.7% $64,785 $35,000,000 45 TCF Financial 1 11.1% $30,000 $361,200,000 45 Wainwright Bank & Trust 1 50.0% $200,000 $22,000,000 46 1st Financial Services 0 0.0% $0 $16,300,000 46 American River Bankshares 0 0.0% $0 $6,000,000 46 Cascade Financial Corp 0 0.0% $0 $39,000,000 46 First Community Bancshares 0 0.0% $0 $41,500,000 46 First Midwest Bancorp 0 0.0% $0 $193,000,000 46 Great Southern Bancorp 0 0.0% $0 $60,000,000 46 HF Financial Corp 0 0.0% $0 $25,000,000 46 HopFed Bancorp 0 0.0% $0 $18,400,000 46 Independent Bank Corp 0 0.0% $0 $72,000,000 46 Indiana Community Bancorp 0 0.0% $0 $21,500,000 46 International Bancshares Corp. 0 0.0% $0 $216,000,000 46 MB Financial 0 0.0% $0 $196,000,000 46 Midwest Banc 0 0.0% $0 $85,500,000 46 Old National Bancorp 0 0.0% $0 $150,000,000 46 WesBanco 0 0.0% $0 $75,000,000 46 AIG 0 0.0% $0 $40,000,000,000 46 Bank of New York Mellon 0 0.0% $0 $3,000,000,000 46 Broadway Financial Corporation 0 0.0% $0 $9,000,000 46 Encore Bancshares 0 0.0% $0 $34,000,000 46 FFW Corp 0 0.0% $0 $7,300,000 46 First Horizon National 0 0.0% $0 $866,000,000 46 First PacTrust Bancorp 0 0.0% $0 $19,300,000 46 Goldman Sachs 0 0.0% $0 $10,000,000,000

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 35 46 LNB Bancorp 0 0.0% $0 $25,200,000 46 Morgan Stanley 0 0.0% $0 $10,000,000,000 46 Peapack‐Gladstone Financial 0 0.0% $0 $28,700,000 46 Saigon National 0 0.0% $0 $1,200,000 46 Severn Bancorp 0 0.0% $0 $23,500,000 46 South Financial Group 0 0.0% $0 $347,000,000 46 Southwest Bancorp 0 0.0% $0 $70,000,000 46 State Street 0 0.0% $0 $2,000,000,000 46 Taylor Capital 0 0.0% $0 $104,800,000 46 Washington Federal 0 0.0% $0 $200,000,000

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 36 METHODOLOGY

This study summarizes data on lending by the top twenty lenders in the United States, defined as banks with $50 billion in assets or greater, and that have made more than 200 SBA loans in fiscal year 2008. These data were acquired through a Freedom of Information Act (FOIA) request to the Small Business Administration.

The banks are rated in four categories, so as to provide a comprehensive analysis. They are explained below:

Number of loans made to minorities This is a straightforward count of the SBA loans made to all minority entrepreneurs together, then separately for African Americans, Asian Americans, and Latinos.

Percentage of all loans made This measures the percent of all the bank’s SBA originations that went to minority businesses. We have set national goals of at least 20 percent SBA loans going to each race category studied, for a total goal of 60 percent of SBA loans going to all minorities.

Total dollar amount This is a sum of the volume of all loans made to minorities, first together, then separately for the three race categories we studied. Due to differences in asset size among the banks, we do not assign grades for this category.

Number made per $5 billion in assets (Loan‐to‐asset Ratio) This is a measure of the proportion of all the bank’s SBA originations that go towards supporting minority businesses. By measuring the number of loans made per $5 billion chunk of the bank’s assets, this measure controls for differences in bank size.

The Greenlining Institute believes that the major financial institutions can drastically improve their SBA lending record to minorities. With this in mind, Greenlining has given a grade to each major financial institution based on two measures: lending on a loan‐to‐ asset ratio and percentage of loans made to minorities. The grades are based on each financial institution’s performance relative to the minority lending targets that we and our minority business association members have developed for each institution based on its flexibility, its access to resources, and its performance relative to its peers. Since the grades are based on these two variables a financial institution may meet the lending target but can still receive a low grade because of its ranking relative to its peers.

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 37 REFERENCES

All fiscal year 2008 SBA lending data was acquired through a Freedom of Information Act (FOIA) request to the Small Business Administration.

Asset size figures for all financial institutions are for United States assets only, as reported by American Banker at http://www.americanbanker.com/rankingthebanks.html, and are current as of March 31, 2008 (published July 23, 2008). Accessed November 14, 2008.

Bailout figures and institutions from ProPublica. Available at http://www.propublica.org/feature/bailout‐bucks‐to‐banks‐1028. Accessed November 25, 2008.

ANNUAL REPORT ON LENDING TO MINORITY-OWNED SMALL BUSINESS | PAGE 38