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Peter J. Wallison                    529


                        Table 14. Announced CRA Commitments in Connection
                  with a Merger or Acquisition by Four Largest Banks and Th eir Predecessors
         Final bank  Acquired or merged bank/entity   CRA commitment (year
                     with a corresponding           announced and dollar amount)
                     announcement of a CRA commitment
         Wells Fargo  First Union acquired by Wachovia  2001 ($35 b.)
                     SouthTrust acquired by         2004 ($75 b.)
                     Wachovia
         JPMorgan    Chemical merges with           1991 ($72.5 m.)
         Chase       Manufacturers Hanover
                     NBD acquired by First Chicago  1995 ($2 b.)
                     Home Savings acquired by       1998 ($120 b.)
                     Washington Mutual
                     Dime acquired by               2001 ($375 b.)
                     Washington Mutual
                     Bank One acquired by JPMorgan Chase  2004 ($800 b.)
         Bank of     Continental acquired by Bank of America  1994 ($1 b.)
         America
                     Bank of America (acquired by NationsBank,   1998 ($350 b.)
                     which kept the Bank of America name).
                     Bank of Boston                 1999 ($14.6 b.)
                     acquired by Fleet
                     Fleet                          2004 ($750 b.)
         Citibank    Travelers                      1998 ($115 b.)
                                                    1998 ($115 b.)
                     Cal Fed                        2002 ($120 b.)
         Compiled by Edward Pinto from the NCRC 2007 report CRA Commitments, found at http://www.
         community-wealth.org/_pdfs/articles-publications/cdfi s/report-silver-brown.pdf , NCRC testimony
         regarding Bank of America’s $1.5 trillion in CRA agreements and commitments in conjunction with its
         2008 acquisition of Countrywide found at http://www.house.gov/apps/list/hearing/fi nancialsvcs_dem/
         taylor_testimony_-_4.15.10.pdf.
              Given the enormous size of the commitments reported by NCRC, the key
         questions are: (i) how many of these commitments were actually fulfi lled by the
         banks that made them, (ii) where are these loans today, and (iii) how are these loans
         performing?
              Currently, in light of the severely limited Commission investigation of this
         issue, there are only partial answers to these questions.
              Were the loans actually made? Th  e banks that made these commitments
         apparently came under pressure from community groups to fulfi ll them. In an
         interview by Brad Bondi of the Commission’s staff , Josh Silver of the NCRC noted
         that community groups did follow up these commitments.
              Bondi: Who follows up…to make sure that these banks honor their voluntary
              agreements or their unilateral commitments?
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