Recycling Black Dollars (RBD)
Listen to: com-cast www.KTYM.com
Monday 1-2pm pst Call-in #310-673-7777
Listen to: com-cast www.KTYM.com
Monday 1-2pm pst Call-in #310-673-7777
posted by walter | 12:36 PM
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Tuesday, October 17, 2006
Monday, October 16, 2006
The Merger Between AmSouth /Regions Bank Should Be Denied By The OCC/FDIC/FRB and CONGRESS
October 16, 2006
Mr. Ritter, CEO AmSouth Bank
1600 – 5th Ave., N
Birmingham, AL 35203
United Affirmative Action Development Corp, UAAD a 501c3 non-profit after reading all the fine things your bank is doing and have done through your CRA programs, have become extremely disappointed in your CRA officials' lack of response to this Non-profits requests.
see: http://www.uedcrabank.blogspot.com/. Due to false statements and your officials determination to delay any type of negotiations of a CRA agreement with UAAD and other non-profits we are asking the Federal Reserve Board, the OCC, the Justice Department and Congress to not allow this merger between your Bank and Regions Bank. We would appreciate a reply from you as to our complaint.
2/18/06
TO: Honorable Member of Congress
RE: Request A Meeting Re: Community Reinvestment Act (CRA)
I am writing to request a meeting on the misinterpretation of the 1977 Community Reinvestment Act. The landmark legislation was a Civil Rights victory to benefit African Americans and other people of color. Today, financial institutions have applied a broader interpretation, using it as an Affirmative Action practice to benefit other groups who were not the intended beneficiaries.
To date, the nation’s banks have over $4.2 trillion in CRA commitments. However, our investigation of CRA activity nationwide has shown that the majority of the country’s banks allocations have not been made to people of color. For example, J.P. Morgan Chase Bank had a CRA budget commitment of $800 billion since April 2004; yet out of $69 billion dollars, disbursed so far the majority of the disbursement has gone to none minority interests.
If these CRA commitments were to be used to provide assistance to hurricane victims, it would benefit both the bank and the community at large. Given the fact that J.P. Morgan Chase Bank is the largest bank in Louisiana, we believe it is necessary to apply some enforcement to this legislation now rather than later, to empower urban communities and cities effected by Hurricane Katrina.
United Affirmative Action Development Corp, a Louisiana-based 501(c) 3 (http://www.uaadcorp.com/), is working with Recycling Black Dollars, a Los Angeles-based 501(c) 3 (http://www.rbdglobal.com/), and we intend to build a coalition with other organizations such as ACORN, the NAACP, and the Greenlining Institute to demand compliance. I have spoken to Sharon Gilstrap of the Office of the Controller of Currency (OCC) in Houston, and she indicated that a hearing before Congress would be appropriate to reinstate the spirit of the Civil Rights legislation. With the assistance of Congress and supporting regulatory agencies, we intend to form an agreement with banks that aren’t in compliance with this legislation.
Mr. Walter Ellis, CEO of United Affirmative Action Development Corp
Mr. Muhammad Nassardeen, CEO of Recycling Black Dollars
February 21, 2006
Memorandum regarding meeting with:
Mr. Peter Barrett / Counsel to Committee on Finance Services
U.S. House of Representatives
2120 Rayburn Building
Washington, D.C. 20515
Mr. Barrett is the counsel to the Finance Services Committee which is chaired by Republican Congressman Michael G. Oxley, met with me today. The purpose of the meeting was to seek assistance from Congress regarding a complaint of our nation’s banks implementing the Community Re-Investment ACT (CRA) and its provisions. (see complaint http://www.uaadcorp.com/ and click on link UEDC CRA BANK.)
Mr. Barrett suggested that I contact as many Congress Persons that is on the Committee on Financial Services. The purpose of such contact would be to ask that they support the nature of our complaint.
It was indicated that UAAD might be better served if our complaint addressed all banks that were not in compliance to CRA rather than singling out a particular bank.
Mr. Barrett mentioned several times that he would be available to assist UAAD if requested. He also stated he would e-mail additional information regarding our request. Walter L. Ellis CEO UAAD
AmSouth Bank you state this is your CRA Program?????
Community Relationships
About AmSouth Overview
2005 Community Giving Report
AmSouth’s relationships with its communities reflect our simple, yet powerful, commitment to service. We believe in the power of the relationship. This dedication benefits not only our customers, but also the communities we serve.
AmSouth has a long tradition of supporting its communities. With gifts totaling more than $7.8 million in 2005, AmSouth Bank, its employees, and affiliated foundations helped sustain hundreds of agencies, including many that receive United Way support. In addition, AmSouth employees volunteered thousands of hours to these agencies, including the Salvation Army, Junior Achievement, and the YMCA/YWCA.
AmSouth also continued to invest significant time and resources to help make housing affordable for low- and moderate-income families. With more than $590 million in loans to low- to moderate-income borrowers and in low-to moderate-income census tracts in 2005, more than $340 million in investments (bank wide, 2004-2005), and countless hours of community service by our employees to affordable housing organizations, AmSouth worked hard to help families achieve the American Dream. In addition, AmSouth obtained $1.8 million in grants and subsidies for affordable housing organizations through the Federal Home Loan Bank of Atlanta. Since the mid 1990s, AmSouth Bank has obtained $38 million in grants from the Federal Home Loan Bank which has helped in the development of over 2700 affordable housing units.
AmSouth and its employees supported many other organizations with more than 2500 AmSouth Matching Gifts – an employee gift doubled by an AmSouth match – totaling over $500,000. These gifts benefited educational institutions and local community development organizations, health and human services agencies, and arts and cultural groups.
Through its support of arts organizations, AmSouth helps thousands enjoy art in their own communities. In 2005, AmSouth sponsored the Nashville Symphony’s Capital Campaign for a new concert center. This center adds a vital element to the city’s cultural life by enhancing Nashville’s musical character and establishing itself as a leading downtown destination. In Orlando, AmSouth sponsored the annual Shakespeare in the Park Festival, in conjunction with the University of Central Florida. In Birmingham, AmSouth has committed funds to the Sixteenth Street Foundation for the restoration, preservation and maintenance of the Sixteenth Street Baptist Church. The church figured prominently in the Civil Rights movement and attracts more than 200,000 visitors annually to downtown Birmingham.
AmSouth’s record of lending, investing and service has earned the bank the highest CRA (Community Reinvestment Act) rating for two consecutive periods, a rating achieved by only a few of our peers. This outstanding rating acknowledges AmSouth’s exemplary level of qualified investments, which now total more than $340 million, that are benefiting low- and moderate-income families and communities that we serve.
Every day, in every one of its locations, AmSouth underscores its dedication to building strong relationships with its customers and its communities, creating a momentum that helps families, businesses and communities grow stronger and more financially secure.
For answers to specific questions or concerns, email us or call us at 1-800-AMSOUTH (1-800-267-6884).
Although your CRA rating by the FDIC/FRB/OCC is that you have the highest rating, that rating is very misleading.
The CRA act was implemented and passed in 1977. It would appear that since your bank have committed little or none of it’s funds to African Americans, and the CRA Act was passed by Congress as part of the Civil Rights Legislation, of 1977, and looking at the above report and what your CRA Representatives relate that the majority of your commitments favor Caucasians and Caucasian organizations as indicated above, we believe with our, the NAACP and others rating your CRA program will and have received a very “poor” rating when AFRICAN AMERICANS are concerned.
As all banks are aware the COMMUNITY RE-INVESTMENT Act of 1977, CRA was made an important part of the Civil Rights Legislation. This Act was made part of the Legislation due to RED-LINING, PREDATORY LENDING PRACTICES on the part of YOUR and other BANKS, in the AFRICAN AMERICAN, Espanic Communities.
Your and most banks are in violation of 12CFR43.25 by not posting and allow viewing of complaints against your bank.
JPMorganChase Bank treats a small portion ($5 Million) of their Community Partnership/CRA/Smart Start of LOUISIANA/REPARATION commitment of $800 Billion as a fair amount to allocate to descendants of Ex-Slaves. This they apparently feel is a fair amount for both their CRA and apology for their banks involvement in the SLAVE TRADE.
For instance JPMorganChase Bank agreed to pay REPARATION, and choose to call their program “SMART START of Louisiana”. How they named the program is insignificant, but the fact that they under funded the program, and apparently purposely hid the funding since 2004, becomes a problem that the NAACP and the Federal Government should investigate.
An effective BOYCOTT of Chase may influence other banks in Louisiana and else where to negotiate reasonable agreements as suggested under the COMMUNITY RE-INVESTMENT Act of 1977, CRA.
UAAD ASK ALL AFRICAN AMERICANS TO BOYCOTT JPMorganChase Bank in LOUISIANA.
What say your Bank? It is my understanding that your bank merged with a bank that was also involved in the SLAVE TRADE. The merger between AmSouth and Regions Bank should not be allowed until the Slave Trade issue and other issues are investigated by the proper agencies to include Community, Civic and Civil Rights Organizations.
Banks predatory lending, led to “COMMUNITY RE-INVESTMENT Act”, CRA
CRA a part of the civil rights legislation of 1977 was created due to predatory lending, red-lining and discrimination on the part of our nation’s banks.
see: http://www.uaadcorp.com/ / http://www.chaseuedcaffinity.blogspot.com/
This administration, who control banks discriminate, and control banks who discriminate.
The manner in which we treat Blacks in this country, it is amazing that they and other minorities would volunteer to die for bush’s war. See: http://www.outbush2005.blogspot.com/
There is no equality, nor equity for African Americans in this country, see: http://www.uedcdwb.blogspot.com/ http://www.uedcrabank.blogspot.com/
, see: http://unitedaffirmativeactiondevelopment.com/id12.html
Bankshttp://www.chasebankreparation.blogspot.com/
As long as this country is controlled by families such as the Bush Family, whose ancestors were “Slave Owners”, see: http://www.hstg.org/index.cgi/1633, it is apparent that Blacks have many reasons for not shedding blood for this country.
See: http://academic.udayton.edu/race/02rights/repara30.htm
http://www.finalcall.com/artman/publish/article_1797.shtml
It is apparent that the Department of Justice, The OCC, FDIC, FRB collaborate with banks in allowing banks to continue their discriminatory practices. See:
http://www.unitedaffirmativeactiondevelopment.com/id12.html. When complaints are filed by non-profit organizations as UAAD has on many occasions, these agencies who receive the bulk of their revenue from the low-moderate income who they are sworn to protect, yet tell these non-profits and many who are living in poverty to hire a lawyer see: http://www.federalreserve.gov/events/publicmeeting/19980813/panel16.htm, a “Reverse ROBIN HOOD” policy that this administration support.
May 4, 2006
MEMORANDUM CONVERSATION WITH DAVID LEWIS (OCC) RE: MEDIATING CHASE BANK PREDATORY LENDING PRACTICES.
Q. Why OCC will not assist UAAD and other organizations in asking JPMorganChase Bank to make funds available to African Americans?
A. Mr. David Lewis the Community Affairs Officer of the Comptroller of the Currency (OCC) stated that the bank could negotiate with any entity it chose.
Q. When asked if his agency had any influence in insisting that Chase Bank cease to discriminate against African Americans?
A. Mr. Lewis stated that the CRA report indicate that Chase Bank does not discriminate, and if so it would be indicated in their performance report.
Q. Why does their performance report indicate that their performance is un-satisfactory in areas where African Americans are the majority?
A. Mr. Lewis stated this is not a true statement.
Q. Since CRA is a part of the Civil Rights Legislation of 1977, it would appear that the $800 billion Chase Bank have committed toward these activities should be allocated in low interest loans and contributions to African Americans (AA) in particular due to AA being to victims of red-ling and discrimination, the main reason the legislation was enacted.
A. Mr. Lewis stated that CRA defiantly wasn’t Civil Rights Legislation, and it had nothing to do with discrimination.
Mr. Lewis I would appreciate your answering and replying to the above in writing or by e-mail in order that I can post on various web sites and blogs.
Thanks, Walter L. Ellis CEO UAAD
The following are past complaints, unanswered:
There is no crime when “BLACKS” are the victim, according to the FDIC!
It is the opinion of many that JPMorganChase Bank, and probably your bank(s) are guilty of violations under the “RICO” Act, due to the constant and consistent reenacting various violations of our members’ human rights, disallowing economic parity, discrimination in hiring and fair lending practices, and committing those acts from their founding days until the present. Our complaint which probably will not be addressed by government agencies or these institutions will probably have to be brought to Amnesty International or the appropriate agency of the United Nations (UN). A class action suit should be brought with all civil rights organizations joining.
Your CRA Representatives are similar to most other Bank’s:
September 16, 2006
Mr. Kevin E. Williams
VP Regional Community Development Manager
AmSouth Bank
333Texas Street, 3rd floor
Shreveport, Louisiana 71101
Phone: 318 429-1918
Re: A request for CRA funding
Mr. Williams,
I would like to express my appreciation for meeting with UAAD in your office 400 Podyras St. on 9/15/06.
UAAD’s request at that meeting is to seek start-up funding to assist UAAD in finalizing organizing a Coalition of Community Organizations to seek CRA funding for projects to be presented to your bank.
United Affirmative action Development Corp, UAAD a 501c3 Tax ID#62-1753255, is seeking contributions to continue its efforts in presenting and developing various programs that we believe will benefit the African American Community, low and moderate income individuals, utilizing CRA, with benefits that will create economic parity for many.
UAAD is seeking a $5,000.00 contribution to provide expenses in developing a final proposal to your bank.
We are looking forward to meeting with you Monday September 18th to present personally this request, and to begin a process to negotiate a long term agreement that will address and assist the Victims of Katrina.
September 16, 2006
Ms. Yvette Cola
VP Regional Community Development Manager
Regions Bank
New Orleans, LA
Phone: 504-584-2105
Re: A request for CRA funding
Ms. Cola,
I would like to express my appreciation for meeting with UAAD.
UAAD’s request is to seek start-up funding to assist UAAD in organizing a Coalition of Community Organizations to seek CRA funding for projects to be presented to your bank.
United Affirmative action Development Corp, UAAD, a 501c3, Tax ID#62-1753255, is seeking contributions to continue its efforts in presenting and developing various programs that we believe will benefit the African American Community, low and moderate income individuals, utilizing CRA, with benefits that will create economic parity for many.
UAAD is seeking a $5,000.00 contribution to provide expenses in developing a final proposal to your bank.
We are looking forward to meeting with you Monday September 18th to present personally this request, and to begin a process to negotiate a long term agreement that will address and assist the Victims of Katrina.
October 9, 2006
Regions Bank Re: Meeting Wednesday October 11, 2006
Mr. Charles Stewart,
United Affirmative Action Development Corp, (UAAD) has attempted to contact your office regarding a CRA meeting your office indicated you would have with UAAD by October 6, 2006. Mr. John Mosley who is not an official of UAAD, advised that he had arranged a meeting to be held on Wednesday October 11th, at 9:00AM. I had advised Mr. Mosley on Friday that the time would need to be changed for my scheduling. Mr. Mosley’s organization(s) I understand has an interest in negotiating a CRA agreement with your and other banks. After reviewing your and other banks’ CRA Activity Reports for the past 2 years in New Orleans in particular, it is my opinion that your and other banks could use the assistance of all Community Organizations in order to bring your bank(s) up to the standards required by the FDIC/OCC/FRB, especially during a merger as intended with your bank and AmSouth.
UAAD and its affiliates would like to be advised when the Public Meeting will be held where organizations or individuals can support or protest the merger between Regions and AmSouth Bank. UAAD’s concern at this time is that many officials of both banks have received numerous requests to negotiate agreements with both banks, and have been given what we believe to be a run-around.
UAAD would ask that Regions and AmSouth enter into good faith negotiations with our 501c3 non-profit, or have the CEO of each bank put in writing why you can or will not. You are aware that when some banks merge the issue of REPARATION becomes a discussion point. Those issues should be resolved, or at least investigated prior to mergers in fairness to the other bank, and the Community such banks serve.
Please reply when receiving this e-mail.
Respectfully,
MEMORANDUM of Meeting held at Regions Bank Charles St. New Orleans Wednesday October 11, 2006
This meeting was held with statements made on previous dates by Mr. Charles Stewart the CRA representative for Regions Bank that the main purpose was to negotiate a CRA proposal UAAD had presented to his office and other officials the past several months. (see: CRA complaint(s)).
In order to verify the intent, purpose, and dialog of this meeting I requested that the meeting be recorded by Mr. Charles Stewart and Ms. Yvette Cola. I also request a transcript of the recordings in a timely manner in order that we may compare our minutes taken at the meeting by UAAD’s representative Brother Walter Uramani.
These transcripts are needed in order that they can be entered into a formal complaint being filed by UAAD, in which we believe Mr. Stewart, Mr. Kevin Williams, present at this meeting have acted in bad faith. Throughout the process in hearing our proposals they and other bank officials have acted in bad faith in allowing African Americans access to CRA benefits.
See: http://www.uaadcorp.com/
October 12, 2006
UAAD Complaint Regarding “Bad Faith Negotiations on the Part of Regions, AmSouth Bank
The CEO of United Development Corp UAAD approached Regions Bank in
Ruston, Louisiana, asked to speak to their CRA Representative. We were told that we would have to travel to Monroe, LA, some 20 plus miles East of Ruston in order to speak to the CRA Rep for the Bank. An attempt was made to make an appointment. A few days later I was introduced to Mr. Dollins who immediately advised that he would put UAAD in touch with the correct officials and he realized the urgency due to the bank(s) recent merger announcement. On this occasion I asked Mr. Dollin if he had the date of the public hearing or comment regarding FDIC approval of the merger. Mr. Dollin indicated that information would have to come from some other official of the bank.
I did meet with a Mr. Dollins regarding a CRA development loan on properties our for-profit United Equity Development Corporation, UEDC regarding building low income housing. This project is being delay waiting Regions Bank's negotiating a CRA agreement with UAAD/UEDC.
Previously I had contacted both Regions and AmSouth via telephone and e-mail asking that they would entertain entering into a proposed CRA arrangement involving most banks in Louisiana, and many community organizations in the State of Louisiana. (see attachments, memorandums, web-site, blog-sites etc. for additional information regarding these issues).
The CEO of UAAD Walter L. Ellis and two representatives met with Mr. Kevin Williams at AmSouth Bank and discussed CRA start-up funding, and other issues in order to put together the proposal he had received several weeks past. Mr. Williams told the Group that he had a Budget of only $5,000.00, but had run out of such funds at this date. Mr. Williams stated he believed he could provide UAAD with a $5,000.00 dollar start-up request, and would ask his Boss to provide such funds from his account. Mr. Williams asked that I submit a request in writing, and that he would meet with me the following Monday in Shreveport, LA, and possibly honor such a request after speaking to his Boss. On Monday Mr. Williams asked that we not meet in person in Shreveport after I advised him that I had completed the request letter, and had several other documents to indicate the authenticity of UAAD/UEDC. Those documents included background of UAAD's many years involvement in CRA with various banks, JPMorganChase Bank in particular, but not exclusively. The documents also included UAAD's non-profit status, membership in LANO, IRS, FEMA, Dunn and Bradstreet, 50lc3, LA corporation certificates and other documentation most institutions require in order to enter into negations of this nature. Mr. Williams now indicates in this telephone conversation on Monday that he had not gotten in touch with his Boss, and stated he would get back to me by Friday of the same week. After not receiving a call from Mr. Williams on Friday, I in the afternoon did call Mr. Williams advised him that it appeared that he was delaying matters I thought to be intent ally. I also asked Mr. Williams to give his or her name of his boss, which days later he stated to be a Mr. Douglas Jackson. After reluctantly giving me the name, main 800 number of AmSouth Bank and e-mail address, Mr. Williams asked that I not call Mr. Jackson, his Boss, that Mr. Jackson would call me by the following Monday . I am at this writing October 12, 2006 awaiting Mr. Jackson's call promised by Mr. Williams in September.
On most occasions when talking to both AmSouth and Regions officials they refused to indicate when or if there was going to be Public Hearings or a Public comment period as usually held when banks merge.
UAAD and its personnel have on many occasions months prior to the opening of the August-September Public Comment period held by Federal Officials we believe were intentionally deceived and given false information by both the OCC/FDIC and other government agencies regarding the dates of these public hearings and other matters pertaining to these mergers.
After meeting with Whitney Bank we were advised that a Ms. Nancy Montoya of the Federal Reserve would contact UAAD and advice on how we may participate in gaining access to funding from a coalition of local banks in the New Orleans area that Ms. Montoya had organized. Ms. Montoya did return my call in the afternoon, stated she would gladly speak to me on this concern, and stated she would appreciate it if would entertain a late evening call this date, which I agreed. I'm now awaiting that call and it is now October 12, 2006. http://www.unitedaffirmativeactiondevelopment.comlid 12.html
UAAD and its Coalition partners ask that the merger between AmSouth and Regions Bank be denied pending this and other complaints to include the possible SLA VE TRADE involvement of both Banks. UAAD and its Coalition Partners ask that these matters be properly investigated by the NAACP, Department of Justice, Congress and all agencies that regulate and control the activities of these and other banks.
Due to the sincerity of these matters, UAAD ask that these matters are addressed in an open forum, with the public and Community Organizations to include specific Community Organizations whose principle concerns are African Americans UAAD being one of those organizations. These and others should be properly notified and invited to testify, as others are invited.
UAAD ask that your agencies consider this a formal complaint and insist that it be investigated immediately before more harm is done to our associates.
Prior to KATRINA our Justice Department collaborated with the banks to deny fair banking practices for African Americans creating the conditions contributed to KATRINA. Now with so many dying, suffering from poverty and despair created by supposing OUR Government, despicable Red-lining, predatory lending, lying and deceit by both Banking and Government officials to deny funding that was created as a penalty under the Community Re-Investment Act of 1977, CRA, because of red lining and discriminatory practices that are as bad now and possibly worse than prior to the implantation of this Civil Rights legislation by Congress.
Are Chase and other banks compelled under the statute and regulations to provide information on CRA?
If Chase does not provide the data is the Controller of the Currency obligated under statute and /or regulations to make Chase comply?
Every operation of the federal government has an inspector general, except for the judiciary and Congress. In the case of Congress there is the General Accounting Office. Have you filed a complaint against OCC with the Ig for Treasury?
Lastly, if there is a federal official under statute that must see that the laws are followed, I suppose in this instance it would be Secretary of the Department of Treasury, then that official could be sued under maybe a writ of mandamus asking the court to compel the official to do what the law demands.
But the most important thing here, to me, seems to be getting the Ig’s office to investigate. In the Ig’s office you might be able to get somebody on the House or Senate
UAAD CRA PROPOSAL to NAACP
UAAD suggest that:
Mr. Kevin Williams arrange a start-up grant (contribution) of $20,000.00 to be funded by October 15, 2006. These funds will allow expenses to be paid to CRA Consultants in order to propose a $500,000.00 Contribution to Northern Louisiana NAACP CRA / UAAD non-profit affiliate.
The urgency of this request is to assist African Americans suffering AmSouth’s past and present red-lining and predatory lending in the low, moderate-income Communities. These violations are in direct violation of the Community Re-Investment Act of 1977, the most important Civil Rights Legislation ever passed by Congress.
The urgency for AmSouth is their desire to appease Organizations such as the NAACP while they are attempting to merge with Region Bank. A public hearing will be held in the very near future and both banks will be offering Organizations as little as possible to indicate to the OCC that they are meeting their CRA obligations. That obligation is that it is suggested that they contribute approximately 10% of their total assets toward CRA activities. I would believe that Mr. Williams have or will demonstrate how his bank has met those obligations for the past 2 years, which is one of the duties of the banks CRA Official. Other duties are to arrange agreements with Community Organizations to make long term agreements, up 10 years to offer low interest loans, SBA loans, Block Grants etc. to the minority community. Under CRA loans can be negotiated by the bank with 501c3 non-profits sometimes below prime interest rates. Many times these negotiations are allowed when the Community non-profit offers a micro-management of such loans, in order that the bank, protected by the FDIC and Federal Reserve insist that prudent banking practices are observed.
In addition to AmSouth’s contribution we ask that they assign a bank official that has the loan capacity to service the commitment. This official will serve on a Community loan committee that will be selected to choose paid Business Consultants who will pre approve loans, that the bank will give final approval or disapproval
This agreement is and will model on older CRA arrangements of this nature, and a recent CRA agreement with Wells Fargo Bank. An affiliate of UAAD Recycling Black Dollars was involved in these recent negotiations. This agreement is the first I am aware of that indicates that CRA was meant for People of Color. This arrangement makes a commitment of 60% to African Americans, 30% to Hispanics, and 10% to others. Although I personally don’t agree to 10% to others, it is far better than past hand-outs by banks. See: http://www.uaadcorp.com/
UAAD will be seeking similar arrangements with SCLC in New Orleans, see:
http://www.cra-uaad-neworleans.blogspot.com/.
A CRA Proposal to REGIONS/AmSouth Bank
It is my understanding that your bank, Regions and AmSouth are merging. As the CEO of UAAD we have asked several agencies, NAACP, SCLC, OCC, Mr. Kevin Williams, VP CRA AmSouth Bank, Yvette Cola, VP CRA Regions Bank, Mr. Charles Stewart, VP CRA Regions Bank, Gail Blackstock, CRA Rep. Regions Bank, when the public hearing will be held regarding the merger. On the 22nd of September I was advised by Mr. Kevin Williams that his boss Mr. Douglas Jackson of AmSouth would contact me on Monday September 25, 2006. As of this date October 6, 2006, UAAD hasn’t received a call or any correspondence from any official other than Mr. Williams from AmSouth. UAAD also is seeking to discuss how we can assist your bank(s) in improving your CRA activity, because of UAAD’s and other organizations’ review of your reports.
UAAD CRA Coalition Proposal to COMMUNITY Organizations & Banks
United Affirmative Action Development Corp UAAD
(A 501C3 non-profit)
On or about May 4, 2006 the following was requested of your bank:
A CRA Proposal from UNITED AFFIRMATIVE ACTION DEVELOPMENT CORP (UAAD) To All Banks in The State of Louisiana for Hurricane
KATRINA Recovery.
UEDC, an affiliate of UNITED AFFIRMATIVE ACTION DEVELOPMENT CORP (UAAD) a 501c3 non-profit, propose to create a coalition of small and large banks in the state of Louisiana in order to provide low, moderate-income individuals and small businesses to include African Americans the necessary funding in order to recover from KATRINA, and its aftermath.
The suggestions of the COMMUNITY RE-INVESTMENT ACT of 1977 (CRA) is that banks commit at least 10 percent of their assets toward CRA activities. These set asides can be in the form of low interest loans, or contributions.
CRA a part of the civil rights legislation of 1977, was created due to predatory lending, red-lining and discrimination on the part of our nation’s banks.
see: http://www.uaadcorp.com/ / http://www.chaseuedcaffinity.blogspot.com/
http://www.chasebankreparation.blogspot.com/
UAAD/UEDC will organize a coalition of banks and community organizations, in order to benefit the Hurricane victims. Such a coalition will benefit the banks and provide benefits to low, moderate-income individuals to include Africian Americans. http://www.bankwhileblack.com/
Although UAAD/UEDC has in excess of 20 years involvement in CRA, we are aware that the success of accomplishing our goals we will need a commitment from our nation’s banks, FDIC, Office of the Comptroller of the Currency (OCC) and as many community organizations that will join with us in order to assist the KATRINA victims and others. Our nation’s banks have in excess of $4.2 trillion dollars in CRA commitments. If the CRA ACT has any significance or purpose, now is the time for it to be implemented. http://www.uedcinc.com/
We propose a 5 year commitment of 10 percent of assets to be administered by UAAD and other established community organizations. We will be negotiating for UAAD and the coalition will require a reasonable percentage in advance to administer these programs.
See: http://www.uaadcrahbuc.blogspot.com/
We anticipate your in-put and participation.
UAAD will ask small banks to contribute administration assistance in lieu of cash contributions. Such contributions will be in the form of business consultation, serving on community loan committees, teaching CRA and banking in HBCU’s etc. Larger banks will be asked to contribute at least 10 percent of their assets toward these proposed projects for the next 5 years. We believe the FDIC/OCC will consider this proposal to be practical and meet the requirements of the bank(s) obligation to meet prudent banking practices as required under the Community Re-Investment Act of 1977 (CRA).
This proposal will set standards on how our nation’s banks can meet their CRA obligations, and at the same time practice prudent banking principles as required by the FDIC/OCC.
Looking forward to meeting with the proper officials to discuss this proposal.
What agency(s) is responsible for banks to comply to the statues and regulations?
Ms. Kate Gaboardi, Application Analyst Federal Reserve Board of Atlanta
1000 Peachtree Street Atlanta, GA 30309 404 498-7250
Ms. Gaboardi,
I spoke to you by phone October 10, 2006, regarding when the public hearings would be held regarding the merger of Regions and AmSouth Banks. You stated that since United Affirmative Action Development Corp, UAAD had not had a chance to comment, that the public hearings would be extended through November 2006. UAAD also asked that your office send UAAD and others in writing the extended comment period. UAAD ask also that the extended period be indefinite, due to UAAD and others seeking Congressional hearings on your agencies involvement in this process and the bank(s) un-ethical practices.
Are Chase and other banks compelled under the statute and regulations to provide information on CRA?
If Chase does not provide the data is the Controller of the Currency obligated under statute and /or regulations to make Chase comply? Every operation of the federal government has an inspector general, except for the judiciary and Congress. In the case of Congress there is the General Accounting Office. Have you filed a complaint against OCC with the Ig for Treasury? Lastly, if there is a federal official under statute that must see that the laws are followed, I suppose in this instance it would be Secretary of the Department of Treasury, then that official could be sued under maybe a writ of mandamus asking the court to compel the official to do what the law demands. But the most important thing here, to me, seems to be getting the Ig’s office to investigate. In the Ig’s office you might be able to get somebody on the House or Senate Banking Committee to get the General Accounting Office to investigate the matter. UAAD request a written reply regarding these concerns. http://www.uaadcorp.com/ http://www.uedcrabank.blogspot.
Memorandum
May 16, 2006
Meeting with Sen. Vitter’s assistant
I met with Sen. Vitter’s assistant, Brent Tippen. We discussed the complaint against Office of the Comptroller of the Currency (OCC) and the complaints against JPMorganChase Bank. He was given copies of the complaints and he indicated that he would contact the senator’s office for further action.
Our main focus of this meeting was centered on Senator Vitter’s office assisting and UAAD arranging an affiliation of all banks in Louisiana and community organizations in Louisiana to make CRA funds available to the Katrina victims. Mr. Tippen stated he would do what he could to get a statement on or about May 25th.
We would like to express our thanks to the senator’s office for taking time and expressing an interest in important matters for low and moderate income citizens in Louisiana.
Would you like me to contact OCC on your behalf? If so, I will need you to fill out the attached letter and send it back to my office signed with a letter from you explaining your situation like the one below. Thank you!
Brent Tippen
United States Senator David Vitter
1217 North 19th Street
Monroe, LA 71201
318-325-8120 (phone)
318-325-9165 (fax)
Brent_Tippen@vitter.senate.gov
http://www.vitter.senate.gov/
Briefly state the nature of your problem (be specific):
The Office of the Comptroller of the Currency & the Federal Reserve Bank have refused to notify my organization and other NGOs and CBOs regarding the public notice period and regarding any public hearings on the matter of the merger of Regions Bank & AmSouth Bank. http://www.uaadcorp.com/
Briefly state the outcome you are seeking:
Request a delay of the proposed merger of Regions Bank and AmSouth Bank and to extend the public comment period indefinitely. See: http://www.uedcrabank.blogspot.com/
Mr. Ritter, CEO AmSouth Bank
1600 – 5th Ave., N
Birmingham, AL 35203
United Affirmative Action Development Corp, UAAD a 501c3 non-profit after reading all the fine things your bank is doing and have done through your CRA programs, have become extremely disappointed in your CRA officials' lack of response to this Non-profits requests.
see: http://www.uedcrabank.blogspot.com/. Due to false statements and your officials determination to delay any type of negotiations of a CRA agreement with UAAD and other non-profits we are asking the Federal Reserve Board, the OCC, the Justice Department and Congress to not allow this merger between your Bank and Regions Bank. We would appreciate a reply from you as to our complaint.
2/18/06
TO: Honorable Member of Congress
RE: Request A Meeting Re: Community Reinvestment Act (CRA)
I am writing to request a meeting on the misinterpretation of the 1977 Community Reinvestment Act. The landmark legislation was a Civil Rights victory to benefit African Americans and other people of color. Today, financial institutions have applied a broader interpretation, using it as an Affirmative Action practice to benefit other groups who were not the intended beneficiaries.
To date, the nation’s banks have over $4.2 trillion in CRA commitments. However, our investigation of CRA activity nationwide has shown that the majority of the country’s banks allocations have not been made to people of color. For example, J.P. Morgan Chase Bank had a CRA budget commitment of $800 billion since April 2004; yet out of $69 billion dollars, disbursed so far the majority of the disbursement has gone to none minority interests.
If these CRA commitments were to be used to provide assistance to hurricane victims, it would benefit both the bank and the community at large. Given the fact that J.P. Morgan Chase Bank is the largest bank in Louisiana, we believe it is necessary to apply some enforcement to this legislation now rather than later, to empower urban communities and cities effected by Hurricane Katrina.
United Affirmative Action Development Corp, a Louisiana-based 501(c) 3 (http://www.uaadcorp.com/), is working with Recycling Black Dollars, a Los Angeles-based 501(c) 3 (http://www.rbdglobal.com/), and we intend to build a coalition with other organizations such as ACORN, the NAACP, and the Greenlining Institute to demand compliance. I have spoken to Sharon Gilstrap of the Office of the Controller of Currency (OCC) in Houston, and she indicated that a hearing before Congress would be appropriate to reinstate the spirit of the Civil Rights legislation. With the assistance of Congress and supporting regulatory agencies, we intend to form an agreement with banks that aren’t in compliance with this legislation.
Mr. Walter Ellis, CEO of United Affirmative Action Development Corp
Mr. Muhammad Nassardeen, CEO of Recycling Black Dollars
February 21, 2006
Memorandum regarding meeting with:
Mr. Peter Barrett / Counsel to Committee on Finance Services
U.S. House of Representatives
2120 Rayburn Building
Washington, D.C. 20515
Mr. Barrett is the counsel to the Finance Services Committee which is chaired by Republican Congressman Michael G. Oxley, met with me today. The purpose of the meeting was to seek assistance from Congress regarding a complaint of our nation’s banks implementing the Community Re-Investment ACT (CRA) and its provisions. (see complaint http://www.uaadcorp.com/ and click on link UEDC CRA BANK.)
Mr. Barrett suggested that I contact as many Congress Persons that is on the Committee on Financial Services. The purpose of such contact would be to ask that they support the nature of our complaint.
It was indicated that UAAD might be better served if our complaint addressed all banks that were not in compliance to CRA rather than singling out a particular bank.
Mr. Barrett mentioned several times that he would be available to assist UAAD if requested. He also stated he would e-mail additional information regarding our request. Walter L. Ellis CEO UAAD
AmSouth Bank you state this is your CRA Program?????
Community Relationships
About AmSouth Overview
2005 Community Giving Report
AmSouth’s relationships with its communities reflect our simple, yet powerful, commitment to service. We believe in the power of the relationship. This dedication benefits not only our customers, but also the communities we serve.
AmSouth has a long tradition of supporting its communities. With gifts totaling more than $7.8 million in 2005, AmSouth Bank, its employees, and affiliated foundations helped sustain hundreds of agencies, including many that receive United Way support. In addition, AmSouth employees volunteered thousands of hours to these agencies, including the Salvation Army, Junior Achievement, and the YMCA/YWCA.
AmSouth also continued to invest significant time and resources to help make housing affordable for low- and moderate-income families. With more than $590 million in loans to low- to moderate-income borrowers and in low-to moderate-income census tracts in 2005, more than $340 million in investments (bank wide, 2004-2005), and countless hours of community service by our employees to affordable housing organizations, AmSouth worked hard to help families achieve the American Dream. In addition, AmSouth obtained $1.8 million in grants and subsidies for affordable housing organizations through the Federal Home Loan Bank of Atlanta. Since the mid 1990s, AmSouth Bank has obtained $38 million in grants from the Federal Home Loan Bank which has helped in the development of over 2700 affordable housing units.
AmSouth and its employees supported many other organizations with more than 2500 AmSouth Matching Gifts – an employee gift doubled by an AmSouth match – totaling over $500,000. These gifts benefited educational institutions and local community development organizations, health and human services agencies, and arts and cultural groups.
Through its support of arts organizations, AmSouth helps thousands enjoy art in their own communities. In 2005, AmSouth sponsored the Nashville Symphony’s Capital Campaign for a new concert center. This center adds a vital element to the city’s cultural life by enhancing Nashville’s musical character and establishing itself as a leading downtown destination. In Orlando, AmSouth sponsored the annual Shakespeare in the Park Festival, in conjunction with the University of Central Florida. In Birmingham, AmSouth has committed funds to the Sixteenth Street Foundation for the restoration, preservation and maintenance of the Sixteenth Street Baptist Church. The church figured prominently in the Civil Rights movement and attracts more than 200,000 visitors annually to downtown Birmingham.
AmSouth’s record of lending, investing and service has earned the bank the highest CRA (Community Reinvestment Act) rating for two consecutive periods, a rating achieved by only a few of our peers. This outstanding rating acknowledges AmSouth’s exemplary level of qualified investments, which now total more than $340 million, that are benefiting low- and moderate-income families and communities that we serve.
Every day, in every one of its locations, AmSouth underscores its dedication to building strong relationships with its customers and its communities, creating a momentum that helps families, businesses and communities grow stronger and more financially secure.
For answers to specific questions or concerns, email us or call us at 1-800-AMSOUTH (1-800-267-6884).
Although your CRA rating by the FDIC/FRB/OCC is that you have the highest rating, that rating is very misleading.
The CRA act was implemented and passed in 1977. It would appear that since your bank have committed little or none of it’s funds to African Americans, and the CRA Act was passed by Congress as part of the Civil Rights Legislation, of 1977, and looking at the above report and what your CRA Representatives relate that the majority of your commitments favor Caucasians and Caucasian organizations as indicated above, we believe with our, the NAACP and others rating your CRA program will and have received a very “poor” rating when AFRICAN AMERICANS are concerned.
As all banks are aware the COMMUNITY RE-INVESTMENT Act of 1977, CRA was made an important part of the Civil Rights Legislation. This Act was made part of the Legislation due to RED-LINING, PREDATORY LENDING PRACTICES on the part of YOUR and other BANKS, in the AFRICAN AMERICAN, Espanic Communities.
Your and most banks are in violation of 12CFR43.25 by not posting and allow viewing of complaints against your bank.
JPMorganChase Bank treats a small portion ($5 Million) of their Community Partnership/CRA/Smart Start of LOUISIANA/REPARATION commitment of $800 Billion as a fair amount to allocate to descendants of Ex-Slaves. This they apparently feel is a fair amount for both their CRA and apology for their banks involvement in the SLAVE TRADE.
For instance JPMorganChase Bank agreed to pay REPARATION, and choose to call their program “SMART START of Louisiana”. How they named the program is insignificant, but the fact that they under funded the program, and apparently purposely hid the funding since 2004, becomes a problem that the NAACP and the Federal Government should investigate.
An effective BOYCOTT of Chase may influence other banks in Louisiana and else where to negotiate reasonable agreements as suggested under the COMMUNITY RE-INVESTMENT Act of 1977, CRA.
UAAD ASK ALL AFRICAN AMERICANS TO BOYCOTT JPMorganChase Bank in LOUISIANA.
What say your Bank? It is my understanding that your bank merged with a bank that was also involved in the SLAVE TRADE. The merger between AmSouth and Regions Bank should not be allowed until the Slave Trade issue and other issues are investigated by the proper agencies to include Community, Civic and Civil Rights Organizations.
Banks predatory lending, led to “COMMUNITY RE-INVESTMENT Act”, CRA
CRA a part of the civil rights legislation of 1977 was created due to predatory lending, red-lining and discrimination on the part of our nation’s banks.
see: http://www.uaadcorp.com/ / http://www.chaseuedcaffinity.blogspot.com/
This administration, who control banks discriminate, and control banks who discriminate.
The manner in which we treat Blacks in this country, it is amazing that they and other minorities would volunteer to die for bush’s war. See: http://www.outbush2005.blogspot.com/
There is no equality, nor equity for African Americans in this country, see: http://www.uedcdwb.blogspot.com/ http://www.uedcrabank.blogspot.com/
, see: http://unitedaffirmativeactiondevelopment.com/id12.html
Bankshttp://www.chasebankreparation.blogspot.com/
As long as this country is controlled by families such as the Bush Family, whose ancestors were “Slave Owners”, see: http://www.hstg.org/index.cgi/1633, it is apparent that Blacks have many reasons for not shedding blood for this country.
See: http://academic.udayton.edu/race/02rights/repara30.htm
http://www.finalcall.com/artman/publish/article_1797.shtml
It is apparent that the Department of Justice, The OCC, FDIC, FRB collaborate with banks in allowing banks to continue their discriminatory practices. See:
http://www.unitedaffirmativeactiondevelopment.com/id12.html. When complaints are filed by non-profit organizations as UAAD has on many occasions, these agencies who receive the bulk of their revenue from the low-moderate income who they are sworn to protect, yet tell these non-profits and many who are living in poverty to hire a lawyer see: http://www.federalreserve.gov/events/publicmeeting/19980813/panel16.htm, a “Reverse ROBIN HOOD” policy that this administration support.
May 4, 2006
MEMORANDUM CONVERSATION WITH DAVID LEWIS (OCC) RE: MEDIATING CHASE BANK PREDATORY LENDING PRACTICES.
Q. Why OCC will not assist UAAD and other organizations in asking JPMorganChase Bank to make funds available to African Americans?
A. Mr. David Lewis the Community Affairs Officer of the Comptroller of the Currency (OCC) stated that the bank could negotiate with any entity it chose.
Q. When asked if his agency had any influence in insisting that Chase Bank cease to discriminate against African Americans?
A. Mr. Lewis stated that the CRA report indicate that Chase Bank does not discriminate, and if so it would be indicated in their performance report.
Q. Why does their performance report indicate that their performance is un-satisfactory in areas where African Americans are the majority?
A. Mr. Lewis stated this is not a true statement.
Q. Since CRA is a part of the Civil Rights Legislation of 1977, it would appear that the $800 billion Chase Bank have committed toward these activities should be allocated in low interest loans and contributions to African Americans (AA) in particular due to AA being to victims of red-ling and discrimination, the main reason the legislation was enacted.
A. Mr. Lewis stated that CRA defiantly wasn’t Civil Rights Legislation, and it had nothing to do with discrimination.
Mr. Lewis I would appreciate your answering and replying to the above in writing or by e-mail in order that I can post on various web sites and blogs.
Thanks, Walter L. Ellis CEO UAAD
The following are past complaints, unanswered:
There is no crime when “BLACKS” are the victim, according to the FDIC!
It is the opinion of many that JPMorganChase Bank, and probably your bank(s) are guilty of violations under the “RICO” Act, due to the constant and consistent reenacting various violations of our members’ human rights, disallowing economic parity, discrimination in hiring and fair lending practices, and committing those acts from their founding days until the present. Our complaint which probably will not be addressed by government agencies or these institutions will probably have to be brought to Amnesty International or the appropriate agency of the United Nations (UN). A class action suit should be brought with all civil rights organizations joining.
Your CRA Representatives are similar to most other Bank’s:
September 16, 2006
Mr. Kevin E. Williams
VP Regional Community Development Manager
AmSouth Bank
333Texas Street, 3rd floor
Shreveport, Louisiana 71101
Phone: 318 429-1918
Re: A request for CRA funding
Mr. Williams,
I would like to express my appreciation for meeting with UAAD in your office 400 Podyras St. on 9/15/06.
UAAD’s request at that meeting is to seek start-up funding to assist UAAD in finalizing organizing a Coalition of Community Organizations to seek CRA funding for projects to be presented to your bank.
United Affirmative action Development Corp, UAAD a 501c3 Tax ID#62-1753255, is seeking contributions to continue its efforts in presenting and developing various programs that we believe will benefit the African American Community, low and moderate income individuals, utilizing CRA, with benefits that will create economic parity for many.
UAAD is seeking a $5,000.00 contribution to provide expenses in developing a final proposal to your bank.
We are looking forward to meeting with you Monday September 18th to present personally this request, and to begin a process to negotiate a long term agreement that will address and assist the Victims of Katrina.
September 16, 2006
Ms. Yvette Cola
VP Regional Community Development Manager
Regions Bank
New Orleans, LA
Phone: 504-584-2105
Re: A request for CRA funding
Ms. Cola,
I would like to express my appreciation for meeting with UAAD.
UAAD’s request is to seek start-up funding to assist UAAD in organizing a Coalition of Community Organizations to seek CRA funding for projects to be presented to your bank.
United Affirmative action Development Corp, UAAD, a 501c3, Tax ID#62-1753255, is seeking contributions to continue its efforts in presenting and developing various programs that we believe will benefit the African American Community, low and moderate income individuals, utilizing CRA, with benefits that will create economic parity for many.
UAAD is seeking a $5,000.00 contribution to provide expenses in developing a final proposal to your bank.
We are looking forward to meeting with you Monday September 18th to present personally this request, and to begin a process to negotiate a long term agreement that will address and assist the Victims of Katrina.
October 9, 2006
Regions Bank Re: Meeting Wednesday October 11, 2006
Mr. Charles Stewart,
United Affirmative Action Development Corp, (UAAD) has attempted to contact your office regarding a CRA meeting your office indicated you would have with UAAD by October 6, 2006. Mr. John Mosley who is not an official of UAAD, advised that he had arranged a meeting to be held on Wednesday October 11th, at 9:00AM. I had advised Mr. Mosley on Friday that the time would need to be changed for my scheduling. Mr. Mosley’s organization(s) I understand has an interest in negotiating a CRA agreement with your and other banks. After reviewing your and other banks’ CRA Activity Reports for the past 2 years in New Orleans in particular, it is my opinion that your and other banks could use the assistance of all Community Organizations in order to bring your bank(s) up to the standards required by the FDIC/OCC/FRB, especially during a merger as intended with your bank and AmSouth.
UAAD and its affiliates would like to be advised when the Public Meeting will be held where organizations or individuals can support or protest the merger between Regions and AmSouth Bank. UAAD’s concern at this time is that many officials of both banks have received numerous requests to negotiate agreements with both banks, and have been given what we believe to be a run-around.
UAAD would ask that Regions and AmSouth enter into good faith negotiations with our 501c3 non-profit, or have the CEO of each bank put in writing why you can or will not. You are aware that when some banks merge the issue of REPARATION becomes a discussion point. Those issues should be resolved, or at least investigated prior to mergers in fairness to the other bank, and the Community such banks serve.
Please reply when receiving this e-mail.
Respectfully,
MEMORANDUM of Meeting held at Regions Bank Charles St. New Orleans Wednesday October 11, 2006
This meeting was held with statements made on previous dates by Mr. Charles Stewart the CRA representative for Regions Bank that the main purpose was to negotiate a CRA proposal UAAD had presented to his office and other officials the past several months. (see: CRA complaint(s)).
In order to verify the intent, purpose, and dialog of this meeting I requested that the meeting be recorded by Mr. Charles Stewart and Ms. Yvette Cola. I also request a transcript of the recordings in a timely manner in order that we may compare our minutes taken at the meeting by UAAD’s representative Brother Walter Uramani.
These transcripts are needed in order that they can be entered into a formal complaint being filed by UAAD, in which we believe Mr. Stewart, Mr. Kevin Williams, present at this meeting have acted in bad faith. Throughout the process in hearing our proposals they and other bank officials have acted in bad faith in allowing African Americans access to CRA benefits.
See: http://www.uaadcorp.com/
October 12, 2006
UAAD Complaint Regarding “Bad Faith Negotiations on the Part of Regions, AmSouth Bank
The CEO of United Development Corp UAAD approached Regions Bank in
Ruston, Louisiana, asked to speak to their CRA Representative. We were told that we would have to travel to Monroe, LA, some 20 plus miles East of Ruston in order to speak to the CRA Rep for the Bank. An attempt was made to make an appointment. A few days later I was introduced to Mr. Dollins who immediately advised that he would put UAAD in touch with the correct officials and he realized the urgency due to the bank(s) recent merger announcement. On this occasion I asked Mr. Dollin if he had the date of the public hearing or comment regarding FDIC approval of the merger. Mr. Dollin indicated that information would have to come from some other official of the bank.
I did meet with a Mr. Dollins regarding a CRA development loan on properties our for-profit United Equity Development Corporation, UEDC regarding building low income housing. This project is being delay waiting Regions Bank's negotiating a CRA agreement with UAAD/UEDC.
Previously I had contacted both Regions and AmSouth via telephone and e-mail asking that they would entertain entering into a proposed CRA arrangement involving most banks in Louisiana, and many community organizations in the State of Louisiana. (see attachments, memorandums, web-site, blog-sites etc. for additional information regarding these issues).
The CEO of UAAD Walter L. Ellis and two representatives met with Mr. Kevin Williams at AmSouth Bank and discussed CRA start-up funding, and other issues in order to put together the proposal he had received several weeks past. Mr. Williams told the Group that he had a Budget of only $5,000.00, but had run out of such funds at this date. Mr. Williams stated he believed he could provide UAAD with a $5,000.00 dollar start-up request, and would ask his Boss to provide such funds from his account. Mr. Williams asked that I submit a request in writing, and that he would meet with me the following Monday in Shreveport, LA, and possibly honor such a request after speaking to his Boss. On Monday Mr. Williams asked that we not meet in person in Shreveport after I advised him that I had completed the request letter, and had several other documents to indicate the authenticity of UAAD/UEDC. Those documents included background of UAAD's many years involvement in CRA with various banks, JPMorganChase Bank in particular, but not exclusively. The documents also included UAAD's non-profit status, membership in LANO, IRS, FEMA, Dunn and Bradstreet, 50lc3, LA corporation certificates and other documentation most institutions require in order to enter into negations of this nature. Mr. Williams now indicates in this telephone conversation on Monday that he had not gotten in touch with his Boss, and stated he would get back to me by Friday of the same week. After not receiving a call from Mr. Williams on Friday, I in the afternoon did call Mr. Williams advised him that it appeared that he was delaying matters I thought to be intent ally. I also asked Mr. Williams to give his or her name of his boss, which days later he stated to be a Mr. Douglas Jackson. After reluctantly giving me the name, main 800 number of AmSouth Bank and e-mail address, Mr. Williams asked that I not call Mr. Jackson, his Boss, that Mr. Jackson would call me by the following Monday . I am at this writing October 12, 2006 awaiting Mr. Jackson's call promised by Mr. Williams in September.
On most occasions when talking to both AmSouth and Regions officials they refused to indicate when or if there was going to be Public Hearings or a Public comment period as usually held when banks merge.
UAAD and its personnel have on many occasions months prior to the opening of the August-September Public Comment period held by Federal Officials we believe were intentionally deceived and given false information by both the OCC/FDIC and other government agencies regarding the dates of these public hearings and other matters pertaining to these mergers.
After meeting with Whitney Bank we were advised that a Ms. Nancy Montoya of the Federal Reserve would contact UAAD and advice on how we may participate in gaining access to funding from a coalition of local banks in the New Orleans area that Ms. Montoya had organized. Ms. Montoya did return my call in the afternoon, stated she would gladly speak to me on this concern, and stated she would appreciate it if would entertain a late evening call this date, which I agreed. I'm now awaiting that call and it is now October 12, 2006. http://www.unitedaffirmativeactiondevelopment.comlid 12.html
UAAD and its Coalition partners ask that the merger between AmSouth and Regions Bank be denied pending this and other complaints to include the possible SLA VE TRADE involvement of both Banks. UAAD and its Coalition Partners ask that these matters be properly investigated by the NAACP, Department of Justice, Congress and all agencies that regulate and control the activities of these and other banks.
Due to the sincerity of these matters, UAAD ask that these matters are addressed in an open forum, with the public and Community Organizations to include specific Community Organizations whose principle concerns are African Americans UAAD being one of those organizations. These and others should be properly notified and invited to testify, as others are invited.
UAAD ask that your agencies consider this a formal complaint and insist that it be investigated immediately before more harm is done to our associates.
Prior to KATRINA our Justice Department collaborated with the banks to deny fair banking practices for African Americans creating the conditions contributed to KATRINA. Now with so many dying, suffering from poverty and despair created by supposing OUR Government, despicable Red-lining, predatory lending, lying and deceit by both Banking and Government officials to deny funding that was created as a penalty under the Community Re-Investment Act of 1977, CRA, because of red lining and discriminatory practices that are as bad now and possibly worse than prior to the implantation of this Civil Rights legislation by Congress.
Are Chase and other banks compelled under the statute and regulations to provide information on CRA?
If Chase does not provide the data is the Controller of the Currency obligated under statute and /or regulations to make Chase comply?
Every operation of the federal government has an inspector general, except for the judiciary and Congress. In the case of Congress there is the General Accounting Office. Have you filed a complaint against OCC with the Ig for Treasury?
Lastly, if there is a federal official under statute that must see that the laws are followed, I suppose in this instance it would be Secretary of the Department of Treasury, then that official could be sued under maybe a writ of mandamus asking the court to compel the official to do what the law demands.
But the most important thing here, to me, seems to be getting the Ig’s office to investigate. In the Ig’s office you might be able to get somebody on the House or Senate
UAAD CRA PROPOSAL to NAACP
UAAD suggest that:
Mr. Kevin Williams arrange a start-up grant (contribution) of $20,000.00 to be funded by October 15, 2006. These funds will allow expenses to be paid to CRA Consultants in order to propose a $500,000.00 Contribution to Northern Louisiana NAACP CRA / UAAD non-profit affiliate.
The urgency of this request is to assist African Americans suffering AmSouth’s past and present red-lining and predatory lending in the low, moderate-income Communities. These violations are in direct violation of the Community Re-Investment Act of 1977, the most important Civil Rights Legislation ever passed by Congress.
The urgency for AmSouth is their desire to appease Organizations such as the NAACP while they are attempting to merge with Region Bank. A public hearing will be held in the very near future and both banks will be offering Organizations as little as possible to indicate to the OCC that they are meeting their CRA obligations. That obligation is that it is suggested that they contribute approximately 10% of their total assets toward CRA activities. I would believe that Mr. Williams have or will demonstrate how his bank has met those obligations for the past 2 years, which is one of the duties of the banks CRA Official. Other duties are to arrange agreements with Community Organizations to make long term agreements, up 10 years to offer low interest loans, SBA loans, Block Grants etc. to the minority community. Under CRA loans can be negotiated by the bank with 501c3 non-profits sometimes below prime interest rates. Many times these negotiations are allowed when the Community non-profit offers a micro-management of such loans, in order that the bank, protected by the FDIC and Federal Reserve insist that prudent banking practices are observed.
In addition to AmSouth’s contribution we ask that they assign a bank official that has the loan capacity to service the commitment. This official will serve on a Community loan committee that will be selected to choose paid Business Consultants who will pre approve loans, that the bank will give final approval or disapproval
This agreement is and will model on older CRA arrangements of this nature, and a recent CRA agreement with Wells Fargo Bank. An affiliate of UAAD Recycling Black Dollars was involved in these recent negotiations. This agreement is the first I am aware of that indicates that CRA was meant for People of Color. This arrangement makes a commitment of 60% to African Americans, 30% to Hispanics, and 10% to others. Although I personally don’t agree to 10% to others, it is far better than past hand-outs by banks. See: http://www.uaadcorp.com/
UAAD will be seeking similar arrangements with SCLC in New Orleans, see:
http://www.cra-uaad-neworleans.blogspot.com/.
A CRA Proposal to REGIONS/AmSouth Bank
It is my understanding that your bank, Regions and AmSouth are merging. As the CEO of UAAD we have asked several agencies, NAACP, SCLC, OCC, Mr. Kevin Williams, VP CRA AmSouth Bank, Yvette Cola, VP CRA Regions Bank, Mr. Charles Stewart, VP CRA Regions Bank, Gail Blackstock, CRA Rep. Regions Bank, when the public hearing will be held regarding the merger. On the 22nd of September I was advised by Mr. Kevin Williams that his boss Mr. Douglas Jackson of AmSouth would contact me on Monday September 25, 2006. As of this date October 6, 2006, UAAD hasn’t received a call or any correspondence from any official other than Mr. Williams from AmSouth. UAAD also is seeking to discuss how we can assist your bank(s) in improving your CRA activity, because of UAAD’s and other organizations’ review of your reports.
UAAD CRA Coalition Proposal to COMMUNITY Organizations & Banks
United Affirmative Action Development Corp UAAD
(A 501C3 non-profit)
On or about May 4, 2006 the following was requested of your bank:
A CRA Proposal from UNITED AFFIRMATIVE ACTION DEVELOPMENT CORP (UAAD) To All Banks in The State of Louisiana for Hurricane
KATRINA Recovery.
UEDC, an affiliate of UNITED AFFIRMATIVE ACTION DEVELOPMENT CORP (UAAD) a 501c3 non-profit, propose to create a coalition of small and large banks in the state of Louisiana in order to provide low, moderate-income individuals and small businesses to include African Americans the necessary funding in order to recover from KATRINA, and its aftermath.
The suggestions of the COMMUNITY RE-INVESTMENT ACT of 1977 (CRA) is that banks commit at least 10 percent of their assets toward CRA activities. These set asides can be in the form of low interest loans, or contributions.
CRA a part of the civil rights legislation of 1977, was created due to predatory lending, red-lining and discrimination on the part of our nation’s banks.
see: http://www.uaadcorp.com/ / http://www.chaseuedcaffinity.blogspot.com/
http://www.chasebankreparation.blogspot.com/
UAAD/UEDC will organize a coalition of banks and community organizations, in order to benefit the Hurricane victims. Such a coalition will benefit the banks and provide benefits to low, moderate-income individuals to include Africian Americans. http://www.bankwhileblack.com/
Although UAAD/UEDC has in excess of 20 years involvement in CRA, we are aware that the success of accomplishing our goals we will need a commitment from our nation’s banks, FDIC, Office of the Comptroller of the Currency (OCC) and as many community organizations that will join with us in order to assist the KATRINA victims and others. Our nation’s banks have in excess of $4.2 trillion dollars in CRA commitments. If the CRA ACT has any significance or purpose, now is the time for it to be implemented. http://www.uedcinc.com/
We propose a 5 year commitment of 10 percent of assets to be administered by UAAD and other established community organizations. We will be negotiating for UAAD and the coalition will require a reasonable percentage in advance to administer these programs.
See: http://www.uaadcrahbuc.blogspot.com/
We anticipate your in-put and participation.
UAAD will ask small banks to contribute administration assistance in lieu of cash contributions. Such contributions will be in the form of business consultation, serving on community loan committees, teaching CRA and banking in HBCU’s etc. Larger banks will be asked to contribute at least 10 percent of their assets toward these proposed projects for the next 5 years. We believe the FDIC/OCC will consider this proposal to be practical and meet the requirements of the bank(s) obligation to meet prudent banking practices as required under the Community Re-Investment Act of 1977 (CRA).
This proposal will set standards on how our nation’s banks can meet their CRA obligations, and at the same time practice prudent banking principles as required by the FDIC/OCC.
Looking forward to meeting with the proper officials to discuss this proposal.
What agency(s) is responsible for banks to comply to the statues and regulations?
Ms. Kate Gaboardi, Application Analyst Federal Reserve Board of Atlanta
1000 Peachtree Street Atlanta, GA 30309 404 498-7250
Ms. Gaboardi,
I spoke to you by phone October 10, 2006, regarding when the public hearings would be held regarding the merger of Regions and AmSouth Banks. You stated that since United Affirmative Action Development Corp, UAAD had not had a chance to comment, that the public hearings would be extended through November 2006. UAAD also asked that your office send UAAD and others in writing the extended comment period. UAAD ask also that the extended period be indefinite, due to UAAD and others seeking Congressional hearings on your agencies involvement in this process and the bank(s) un-ethical practices.
Are Chase and other banks compelled under the statute and regulations to provide information on CRA?
If Chase does not provide the data is the Controller of the Currency obligated under statute and /or regulations to make Chase comply? Every operation of the federal government has an inspector general, except for the judiciary and Congress. In the case of Congress there is the General Accounting Office. Have you filed a complaint against OCC with the Ig for Treasury? Lastly, if there is a federal official under statute that must see that the laws are followed, I suppose in this instance it would be Secretary of the Department of Treasury, then that official could be sued under maybe a writ of mandamus asking the court to compel the official to do what the law demands. But the most important thing here, to me, seems to be getting the Ig’s office to investigate. In the Ig’s office you might be able to get somebody on the House or Senate Banking Committee to get the General Accounting Office to investigate the matter. UAAD request a written reply regarding these concerns. http://www.uaadcorp.com/ http://www.uedcrabank.blogspot.
Memorandum
May 16, 2006
Meeting with Sen. Vitter’s assistant
I met with Sen. Vitter’s assistant, Brent Tippen. We discussed the complaint against Office of the Comptroller of the Currency (OCC) and the complaints against JPMorganChase Bank. He was given copies of the complaints and he indicated that he would contact the senator’s office for further action.
Our main focus of this meeting was centered on Senator Vitter’s office assisting and UAAD arranging an affiliation of all banks in Louisiana and community organizations in Louisiana to make CRA funds available to the Katrina victims. Mr. Tippen stated he would do what he could to get a statement on or about May 25th.
We would like to express our thanks to the senator’s office for taking time and expressing an interest in important matters for low and moderate income citizens in Louisiana.
Would you like me to contact OCC on your behalf? If so, I will need you to fill out the attached letter and send it back to my office signed with a letter from you explaining your situation like the one below. Thank you!
Brent Tippen
United States Senator David Vitter
1217 North 19th Street
Monroe, LA 71201
318-325-8120 (phone)
318-325-9165 (fax)
Brent_Tippen@vitter.senate.gov
http://www.vitter.senate.gov/
Briefly state the nature of your problem (be specific):
The Office of the Comptroller of the Currency & the Federal Reserve Bank have refused to notify my organization and other NGOs and CBOs regarding the public notice period and regarding any public hearings on the matter of the merger of Regions Bank & AmSouth Bank. http://www.uaadcorp.com/
Briefly state the outcome you are seeking:
Request a delay of the proposed merger of Regions Bank and AmSouth Bank and to extend the public comment period indefinitely. See: http://www.uedcrabank.blogspot.com/
posted by walter | 3:18 PM
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