Page 557 - untitled

528 Dissenting Statement

To understand CRA’s role in the fi nancial crisis, the relevant statistic is the $4.5
trillion in bank CRA lending commitments that the NCRC cited in its 2007 report.
(Th is document and others that are relevant to this discussion were removed from
the NCRC website, www.ncrc.org, aft er they received publicity but can still be found
155
on the web ). One important question is whether the bank regulators cooperated
with community groups by withholding approvals of applications for mergers and
acquisitions until an agreement or commitment for CRA lending satisfactory to
the community groups had been arranged. It is not diffi cult to imagine that the
regulators did not want the severe criticism from Congress that would have followed
their failure to assist community groups in reaching agreements with and getting
commitments from banks that had applied for these approvals. In statements in
connection with mergers it has approved the Fed has said that commitments by
the bank participants about future CRA lending have no infl uence on the approval
process. A Fed offi cial also told the Commission’s staff that the Fed did not consider
these commitments in connection with merger applications. Th e Commission did
not attempt to verify this statement, but accepted it at face value from a Fed staff
offi cial. Nevertheless, there remains no explanation for why banks have been making
these enormous commitments in connection with mergers, but not otherwise.
Th e largest of the commitments, in terms of dollars, were made by four banks
or their predecessors—Bank of America, JPMorgan Chase, Citibank, and Wells
Fargo—in connection with mergers or acquisitions as shown in Table 14 below.

155 http://www.community-wealth.org/_pdfs/articles-publications/cdfi s/report-silver-brown.pdf.