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UAAD'S PROPOSAL to FUND SOLAR PANELS for LOW-MODERATE INCOME HOMES

Framed against the backdrop of Californians on the verge of  Home  foreclosure,______________________
Press Enterprise article by Debra Gruszecki dgruszecki@pe.com 

LOS ANGELES — Framed against the backdrop of Californians on the verge of foreclosure, Gov. Jerry Brown on Wednesday, July 11, signed into law the Homeowner Bill of Rights to establish landmark protection rules for mortgage loan borrowers that were set to retire after three years. The law, which takes effect Jan. 1, will offer immediate help to an estimated 700,000 people in default and to hundreds of thousands of others in the Golden State who are having a tough time paying or modifying home mortgages. It was heralded by a crowd packed into the Ronald Reagan State Building Auditorium in Los Angeles as the first of its kind to be
passed in the nation.

Shelly Parker, of Corona, is another Riverside County homeowner who says she received a letter telling her she’s qualified for a $244,000 principal reduction while her home is in the pre-foreclosure process through                     Bank of America’s servicer ReconTrust.
                      

 “We are here to tell the banks to do what’s right,” Brown said. “Doing what’s right does not mean kicking people out of their houses.

“We are here to rein in dual process,” Brown added, so that people “can keep their houses and restore their dignity.” 

The mortgage servicing bill passed by California lawmakers on July 2 requires lenders or loan servicers to establish a single point of contact for borrowers.  It sets penalties for “robo-signing” of foreclosure documents.  And it prohibits “dual tracking,’’ a practice where foreclosure is pursued by banks, even as new terms are simultaneously negotiated with a residential loan borrower. 

Attorney General Kamala Harris has said the Homeowner Bill of Rights puts an indelible stamp in California on the $25 billion settlement set to expire after three years between federal regulators, the attorney generals in 49 states and the nation’s largest loan servicers, such as Bank of America, JPMorgan Chase, Wells Fargo, Citigroup and Ally Financial.  It brings fairness, transparency and accountability into the marketplace, she said.  But even as the precedent-setting reform was signed, and Inland Empire homeowners celebrated an end to “dual-tracking,’’  the banking industry warned the law will stifle the state’s housing market recovery. 

A study by Beacon Economics, commissioned by the California Bankers Association and other lending industry groups, predicted that the bill will slow down the foreclosure process, push up interest rates and trigger sales transactions that require significantly larger down payments.
  The end result is it will greatly increase the cost of mortgage loans, Beacon Economics founder Christopher Thornberg said, posing harm to the consumer and the economy.  “It will punish perfectly responsible, future home buyers,’’ he said recently,  “even as the housing market has turned the corner to full recovery”, “I don’t understand, in any way, shape or form, why we need this now.”

 Rose Gudiel, an employment program representative for the state, who nearly lost her home in Los Angeles, said she hears a steady stream of stories about mortgage modification bungling all the time. “People are being taken out of their homes, and until now there was no government legislation to help them,’’ she said.  “I’m happy this passed; we need help now.” Major lenders like Bank of America, which in its Countrywide  takeover assumed millions of “exotic” or zero-interest home loans negotiated before the housing bubble burst, have not commented specifically on the new California law, but it has held homeowner loan modification seminars here with the goal of showcasing its assists to troubled borrowers like Stephanie and Ray Velez.

The Velez family, who paid $530,000 for their home in San Bernardino that’s assessed at $275,000 today, has just gotten word from Bank of America that they are in line for a $193,000 reduction on their principal._________________________________________________

Bank of America Home Loans in a statement release in May said that it reached out to more than 200,000 customers across the country who may be eligible for forgiveness of a portion of the principal balance on their mortgages under the settlement. 

Until now, Stephanie said she and her husband had nearly given up. “I got the Dear John letter,’’ she said, and had been rejected multiple times through a steady stream of paper filings and phone calls to the bank for the Making Home Affordable program.

The Velezes were on the verge of going through the short-sale process when they learned in January about a nonprofit group that helps consumers lower their principals and reduce payments.
 After two sit-downs with bank officials, the couple was approved for the DOJ settlement-related mortgage reduction. Even while the Velezes said their persistence paid off, Stephanie said a 6-month miscalculation on their income by a paper servicer nearly cost them their home. 

“I’m a real estate agent,” she said. “And I had an extremely difficult time working through this.” Shelly Parker, of Corona, is another Riverside County homeowner who says she received a letter telling her she’s qualified for a $244,000 principal reduction while her home is in the pre-foreclosure process through Bank of America’s servicer ReconTrust. “It’s not over till it’s over,’’ she said, describing the process as a daunting one that offered little hope until recently. “The possibility of the modification has lifted some weight off my shoulders, but I still have some uncertainties.  The letter I have is kind of abstract.” “It’s a good day,” said Peggy Mears, of Fontana, who was helped by a coalition fighting to put a stop to dual tracking. Mears, one of 21 bill supporters who attended the signing wearing yellow T-shirts, received a loan modification. 

Brian Nelson, special assistant attorney general, said Tuesday that this bill is meant to clear all the confusion, and make sure the rules of the road are clear.
 “What it does in a number of ways is make sure homeowners have access to information they need so they know if they have the ability to get a mortgage modification or participate in the national mortgage settlement and move on with their life,’’ Nelson said. “By having a single-point of contact, homeowners will have the tools they need to make sure the process is smooth and correct.” Nelson said he has gotten anecdotal accounts that servicers are starting to take action on $12 billion worth of principal reductions in California, and those modifications are significant. He added that he has not seen the data, yet, but expects to get a report from the servicers in the near future. 

PROPOSAL to WELLS FARGO BANK to FUND SOLAR PANELS, LOW-MODERATE INCOME HOMES  

UNITED AFFIRMATIVE ACTION DEVELOPMENT CORP, (UAAD) a 501c3 non-profit

 UAAD’S MISSION STATEMENT:

The mission of UAAD is to improve the financial status of low and moderate-income individuals. UAAD is dedicated to building a long-term relationship with financial institutions providing low interest loans and other benefits to these communities. UAAD’s efforts will also assist banks in meeting their CRA obligations. The aim of UAAD is to assist our members in advancing financially, mentally and socially. UAAD’s targeted clients have too long been under-represented and denied equal opportunities to participate in our economy.

As the founder of UNITED AFFIRMATIVE ACTION DEVELOPMENT CORP., UAAD a 501c3 non-profit, in a meeting March 28, 2012 with Wells Fargo CRA officials I asked if their bank would anticipate a proposal from UAAD to fund a project that could involve an affiliation with Grid Alternative and UAAD and also funding for Solar Energy in a partnership with Wells Fargo Bank and UAAD. 
  
Designated area:

SOUTHERN CALIFORNIA HOUSE HOLD INCOME QUALIFICATIONS:  0-$40,000.00 (o cost)
$41,000.00 to $100,000.00, cost $10,000.00 to $15,000.00 up to 20 panels. 
Additional panels at retail installation cost. 
Funding Request: UAAD request that WELLS FARGO COMMUNITY DEVELOPMENT Department allocate in the form of a grant of $50,000.00 to develop the program. UAAD request a $500 million dollar Community Re-Development Grant at an interest rate of .01% to be lent to qualified low-moderate income households at .04% to pay for and install solar panels on their home.   UAAD will partnership with minority financial institutions in order that the bank can satisfy the safe investment of its funds. UAAD will have the responsibility, along with the FDIC financial institution to micro-manage the loans, in order that all of the loans are repaid, and protected. Households receiving the benefits of the panels will allow a lien to put on their properties for the value of the panels when installed. UAAD intend to develop a partnership with organizations as GRID ALTERNATIVE, and or other for-profit solar energy installations companies. 

Benefits of this program to the Community:
         
It will reduce emissions into the atmosphere.
           
Solar panels will drastically reduce electrical bills.
           
Solar panels will increase the value of homes.
Solar panel installation will create jobs for low/moderate income individuals for long term employment.
Benefits to the BANK:           
The BANK(s) will have properties with added equity, making homes easier to finance.
            
Will get credit for
Improving job creation.
Improving the environment.
For meeting the requirements of the Community it serves, as recommended under the
COMMUNITY RE-INVESTMENT Act of 1977, CRA

 Wells Fargo Bank CRA Financing The Community Reinvestment Act is a financing tool for community development. It is important to understand which activities and products CRA agreements can support in order to better target an advocacy strategy.
Securing Finance Products that Work 
In 1998, many newspapers carried a banner headline: Bank of America pledges $350 billion for community reinvestment. When the bank pledged $12 billion in 1992 and when Wells Fargo Bank pledged $45 billion in 1996, similar headlines appeared. What difference do these pledges really make for local businesses, neighbors and community organizations?The truth is that the commitments probably have had more and less impact than anticipated. 

Direct commitments result in short term impact, with increased loans and financial presence.

Indirect commitments 
slowly change the way banks operate, with long-term implications for the community. Both are important. With community residents and their organizations holding banks responsible, there can be scores of community investments and improvements occurring. The types of equitable development financing support to target include:

Lending Small business loans (less than $50,000) previously unavailable, or only available at substantially higher interest rates.Mortgage loans with low down payments and reasonable interest rates available to moderate and low-income residents.Monitoring and correction of discriminatory practices.Financing of affordable rental housing built by nonprofit developers.Mortgage financing for long-term affordability properties including LEHCs and CLT housing.

Investments Corporate grant programs that support community-based organizations.Bank investments in nonprofit community development loan pools.
Services Bank vendor purchase programs that offer business opportunities for minority-owned businesses.Retention of local bank branches. http://www.policylink.org/site/c.lkIXLbMNJrE/b.5136951/k.E993/Financing.htm  http://www.fmcrc.org/CommunityLeadersSpeakOutAgainstBofA.pdf

 I first heard about GRID Alternatives through research on the internet.   After hearing about the opportunity to receive a residential solar system at little to no cost, my family and I contacted GRID Alternatives-Inland Empire office to submit our application. We received a 2.565 kW solar system in early December of 2011, which has since saved us $75.00 per month.  This means we will save over $23,900 and reduce over 232 tons of CO2 over the lifetime of the solar system. Since receiving our solar electric system, we have seen the need to attempt to let all our friends, relatives, neighbors made aware of the benefits to them and the environment.We want to let them know how we qualified as Senior Citizens, and with your Non-Profit organization affiliated with SOUTHERN CALIFORNIA EDISON we were able to get 13 panels installed at a cost of less than $100.00 to us, (the cost of lunch for the wonderful voluntary workers) who we very much appreciate and thank for their efforts and ethics.We would want our friends, neighbors and family to be aware of GRID ALTERNATIVE’S program so that they and others will benefit.I am pleased to give GRID Alternatives my full support and appreciation in their effort to provide families in need with a clean, renewable energy solution and tangible educational opportunities throughout the Inland Empire.   This will give you a general idea of what we are trying to accomplish. I suggest we model our program after Grid Alternative, who use and train volunteers to install the panels.  See:  http://www.gridalternatives.org/ .Conversations with top officials from Wells Fargo's President's office held March 28, 2012 here in Lake Elsinore were very positive.  They listened to my verbal proposal, and seemed impressed; they agreed to meet at a later date, for us to discuss making a relationship with a local bank to channel the funds as a loan to UAAD the non-profit at 1-2% interest, where we can loan our members funds at 3-4 % to have the panels installed.  Their suggestion at this meeting is that we would cover only Southern California initially.  
 
(An article from the Press Enterprise)
 
ENERGY: Homeowner loans could be offered statewide

The money pays for rooftop solar systems and other improvements; the loan is paid back on a homeowner’s property tax bill

 Getting optimal energy efficiency through improvements such as insulation, above, are being funded by a local group called the Home Energy Retrofit Opportunity or HERO, coordinated by the Western Riverside Council of Governments. The agency wants to take the project statewideSpecial loans for homeowners who want to install rooftop solar systems or other energy-saving improvements have been so popular in Riverside County that local leaders want to take the program statewide. Officials with the Western Riverside Council of Governments, a multi-city agency that oversees planning and development programs in areas west of Banning, will ask the agency’s board to expand the Home Energy Retrofit Opportunity — known as HERO — to other counties and cities in the state.
“If we offer our existing program to other people so they do not have to do all the legwork, it helps them put their programs together much more quickly,” explained Rick Bishop, WRCOG’s executive director.The HERO program loans money from private investors to homeowners in western Riverside County who want to install residential solar systems, purchase high-efficiency appliances such as water heaters, furnaces, air conditioners and attic fans. The money can be used for insulation, energy-efficient windows and water-conserving improvements such as drip irrigation systems.About $12 million of the $100 million available for residential projects has been claimed since December, when the program started. Based on the expected average loan of $17,500 per home, about 675 homeowners have tapped the program.“Right now, we’re pushing out about a million dollars a week,” Bishop said, adding that the program has met or exceeded expectations and drawn regional awards for its ability to improve home energy efficiency and lower gas and electricity use.

Good Deal

Homeowners pay up-front loan costs — 5.35 percent plus fees, or about $1,160 for a $20,000 loan — and then repay the borrowed amount, plus interest. The interest rate is determined by the length of the loan. At the end of April, rates varied between 5.95 percent for a five-year payback to 8.25 percent for a 20-year term.“It turned out to be totally the best deal as far as I’m concerned,” said Bill Haas, 78, who had a new heating and air conditioning unit installed in his Menifee home.By borrowing the money and then repaying it via his property taxes, Haas said he gets an added tax advantage because his entire property tax bill can be deducted from his income taxes. Coupled with about $4,000 in rebates and the reduction in his monthly utility bill, the savings was extraordinary, he said.“It is a good plan for people, and the product is out of this world,” Haas said. His new cooling and heating system is more efficient and comes with a remote that makes it easier for him as well, he said.“Now I don’t have to walk downstairs to turn it on or check the temperature,” he laughed.Local businesses that perform the work for HERO-eligible projects also benefit.“The program has been great for the homeowners and great for the economy,” said Steve Elizondo, operations manager for WC Heating & Air Conditioning Inc., based in Murrieta.Soon, the loans will be offered to businesses for efficiency upgrades at offices, restaurants and stores; repayment would be through the business’ property taxes.About $20 million worth of projects already are waiting to begin, Bishop said, once the financing is expanded to the commercial projects. In all, $225 million will be available to businesses — $25 million for large-scale solar projects and $200 million aimed at small-to-midsize companies.“I think the real need and real flash value of the program is on the commercial side,” Bishop said.  

Statewide Effort

Board members on Monday, June 4, are expected to allow WRCOG staff to start a joint powers authority, the first step toward partnering with other interested agencies around the state. Bishop said local planners would share with other interested cities, counties and agencies the legal paperwork needed to form the public-private partnership and establish the rules and regulations.“What we’ve hit, we think, is a great formula for public-private investment,” he said. “We want to share that.”The move by the council of government follows a rule change by state legislators two weeks ago that doubled the amount of credit homes and businesses with rooftop solar systems can receive from their local utilities. The May 24 vote by the California Public Utilities Commission will allow additional homeowners and businesses to qualify for reimbursements on their electric bills.The rule pertains to the state’s large investor-owned utilities, including Southern California Edison.More information on the loan program, call 951-955-7985  

Community Reinvestment Act Information The Act (CRA)

The CRA was enacted in 1977 to prevent redlining and to encourage banks and thrifts to help meet the credit needs of all segments of their communities, including low- and moderate-income neighborhoods. It extends and clarifies the longstanding expectation that banks will serve the convenience and needs of their local communities. The CRA and its implementing regulations require federal financial institution regulators to assess the record of each bank and thrift in helping to fulfill their obligations to the community and to consider that record in evaluating applications for charters or for approval of bank mergers, acquisitions, and branch openings. The federal financial institution regulators are: Office of the Comptroller of the Currency; Board of Governors of the Federal Reserve System; Federal Deposit Insurance Corporation; and Office of Thrift Supervision.

The law provides a framework for depository institutions and community organizations to work together to promote the availability of credit and other banking services to underserved communities. Under its impetus, banks and thrifts have opened new branches, provided expanded services, adopted more flexible credit underwriting standards, and made substantial commitments to state and local governments or community development organizations to increase lending to underserved segments of local economies and populations. CRA Institutions CRA applies to federally insured depository institutions, national banks, thrifts, and state-chartered commercial and savings banks. OCC’s CRA Responsibilities The CRA’s implementing regulation (12 CFR 25, et seq.) requires the OCC to assess a national bank’s record of helping to meet the credit needs of its entire community, including low- and moderate-income neighborhoods, consistent with safe and sound operations. It also mandates that the agency consider that record in its evaluation of a bank’s application for new branches or relocation of an existing branch, bank mergers and consolidations, and other corporate activities. In general, the OCC conducts a CRA examination of a national bank every three years. However, the Gramm-Leach-Bliley Act mandates an extended examination cycle for smaller banks. CRA examinations for banks with an overall CRA rating of outstanding and aggregate assets of $250 million or less can be started no sooner than 60 months after the most recent CRA examination. Similarly, CRA examinations for banks with an overall CRA rating of satisfactory and aggregate assets of $250 million or less can be started no sooner than 48 months after the most recent CRA examination. Banks may be removed from this extended CRA examination cycle for reasonable cause or in connection with an application for a depository facility. The OCC publishes an advance notice of scheduled CRA examinations quarterly. A written performance evaluation of the bank’s CRA activities, including a CRA rating, is prepared at the end of each CRA examination and made available to the general public. The OCC encourages community and civic organizations, government, and other members of the public to express their views about a bank’s CRA performance to the bank and the OCC at the earliest possible time. This allows the bank to address any concerns and the OCC to take the public’s views into account in evaluating the bank’s CRA record and reaching conclusions about its performance ratings. If those comments are sent to the OCC, the OCC will also consider them when reviewing applications covered by the CRA. Additional Information If you are interested in obtaining additional information about CRA, visit our website at  http://www.occ.treas.gov  or contact:
Office of the Comptroller of the Currency / Compliance Division / 250 E Street, SW - Mail Stop 6-7
Washington, DC 20219 /
Telephone: (202) 874-4428 / Fax: (202) 874-5221  
posted by:
 http://about.me/walterellis
 

UAAD’s PURPOSE AND GOALS

The mission of UAAD is to improve the financial status of low and moderate-income individuals. UAAD is dedicated to building a long-term relationship with financial institutions providing low interest loans and other benefits to these communities. UAAD’s efforts will also assist banks in meeting their CRA obligations. The aim of UAAD is to assist our members in advancing financially, mentally and socially. UAAD’s targeted clients have too long been under-represented and denied equal opportunities to participate in our economy.                  

 

GOP uses ACORN to fight BANK REDLINING LAW
01rights190.jpg

GOP uses ACORN to fight “BANK REDLINING LAW
By:SHARON’THEIMER’and’PETE’YOST

Associated Press Writers   October 12, 2009

 WASHINGTON (AP) - Conservative Republicans are capitalizing on the troubles of community activist group ACORN _ ranging from charges of voter registration fraud to embarrassing videos of its employees _ to revive their long-standing fight against a federal law that grades banks on their investments in poor and minority neighborhoods.

The 1977 Community Reinvestment Act was intended to end redlining, a practice in which banks in effect walled off many inner-city neighborhoods from mortgage loans. But some GOP lawmakers say it has outlived its purpose and is being used inappropriately by ACORN to shake down banks for money. They want to repeal the law, scale it back or at least block a Democratic proposal to expand it………….

CRA lending during the Bush administration created problems in the Banking Industry. These low interest loans were being allocated to the Majority (Caucasians) rather than African Americans and other Minorities this CIVIL RIGHTS LEGISLATION was enacted to prevent “Red Lining” in the African American Communities it was meant to adddress. 


TO BE EQUAL  5/10/99

Banking On Equal Opportunity By Hugh B. PricePresident National Urban League Most people who live outside of Washington D.C. have probably never heard of the Community Reinvestment Act.  Yet, though unsung, the CRA is one of the most important pieces of civil rights legislation Congress has ever passed.  That’s why; as Congress considers legislation that would remake the financial services industry – allowing banks, investment firms, and insurance companies to merge and compete – it must make sure that the goals of the original Community Reinvestment Act are protected and furthered.  For the evidence is clear:The CRA has been extremely successful in making capital for business development and for home ownership available in low-and moderate-income urban neighborhoods and rural communities.  That success has significantly aided the revitalization of hundreds of low-income urban neighborhoods and rural communities.  And that success has made it possible for thousands upon thousands of individuals to improve their economic circumstances and their “stake” in American society.  In other words, the CRA has helped enhance all Americans’ including African Americans’, access to economic opportunity, which is the cornerstone of communities’, individuals’ and groups’ ability to meaningfully participate in American society.  Congress pass the Community Reinvestment Act in 1977 in response to clear evidence of the noxious effects of “redlining”-the systematic refusal of lenders to provide loans to businesses, homeowners and prospective home buyers in particular neighborhoods, especially those which were predominantly Black or Hispanic.  The act required federally - insured banks to document their efforts to invest in home ownership and business development in poor communities.  In its early years, the act had a modest impact. But during the 1990s the law’s positive reach has been extraordinary, as numerous measurements prove.  Undoubtedly, the unprecedented period of prosperity the country has enjoyed during the decade has had something to do with that. So, undoubtedly, has the increased sophistication of community housing groups in using the law, and the increased pressure of federal regulators making their evaluations of banks’ lending performances public.  But it’s also true that the benefits of the Community Reinvestment Act to society have become too evident to ignore.  As many observers have noted, homeownership – in which Blacks and Hispanics have always lagged significantly behind whites – is the critical building bloc that enables individuals and families to escape poverty and achieve social mobility. The CRA is just such an asset-building program.  Writing in the National Urban League publication, The State of Black America 1998, scholars Melvin L. Oliver and Thomas N. Shapiro, declared, “While (governmental) programs providing income for consumption are essential, programs for the accumulation of assets invest in the ability of families to become self-reliant and to support their communities by stimulating education, job mobility, home ownership, entrepreneurship, and equity.   ’It’s not just city dwellers or suburbanites who benefit, either. In 1997 banks and thrifts made $11 billion in loans to small farmers for operating expenses, livestock and real estate purchases.CRA is also profitable for the banks.
Federal Reserve Board chairman Anal Greenspan has stated that there’s “little or no evidence that banks’ safety and soundness have been compromised by CRA lending.”  Richard Rosenberg, former chairman and CEO of Bank America Corporation, is more assertive. “Banks that learn how to meet (community reinvestment) demand profitably,” he said, “and integrate it into their business lines, will gain a tremendous competitive advantage.”  Thus, efforts to cut the provisions of the act enabling the public to see and comment on bank lending policies in their communities; or to allow the shift of many financial assets out of banks and thrifts into other financial institutions not covered by CRA; or to exempt small rural banks from CRA rules go against the original spirit of the act – and the needs of millions of Americans.            Insuring equal economic opportunity for Americans in a capitalist society requires insuring equal access to capital. Congress should add to, not detract from, the Community Reinvestment Act’s ability to meet its goals, That’s an investment that would benefit all of American society.
19 TBE 5/10/99 TO BE EQUAL  120 Wall Street, NY, NY 10005 
                                       
"Banking while Black " hurts homeowners 
This article appeared in USA Today; 2006, this is an edited version___________________
 African-Americans and Hispanic consumers face a double whammy. First, they are less likely than whites to own their homes. According to the Survey of Consumer Finance, 47% of African-Americans and Hispanics are homeowners, compared with 74% of whites. But even when African-Americans and Hispanics own their homes, they face lending discrimination when they refinance.
This week, the National Community Reinvestment Coalition (NCRC) released a report on credit discrimination with troubling findings. Consumers living in areas with more minority residents are more likely to have mortgages with interest rates higher than "prevailing and competitive" rates. Some get these sub-prime be a cause they have poor credit. But far too frequently, the problem is lending discrimination. Often, African-Americans, Hispanics and in some cases, elderly buyers who qualify for market-rate loans are steered to high-cost loans. This is especially true when they live in heavily black or elderly areas.
In response to racial profiling on highways, some activists coined the term "driving while black". NCRC president John Taylor does them one better when he notes that "banking while black or elderly means that most are most likely to get gouged by high interest rates and fees." NCRC says the broken credit system can be fixed if the Federal Reserve Bank increases its oversight on anti-discrimination and fair lending laws, and if existing laws are better enforced. Because incomes were fairly stagnant in 2002, much of Americans' consumer spending has been financed by credit cards and home-equity credit. Too many African-Americans and seniors who are helping to keep the economy afloat are paying extraordinarily high fees to do so. That’s a lump of coal in a Christmas stocking, an injustice that needs to be rectified.
Commentary by Julianne Malveaux
posted by Walter @ 5:46 PM 2 comments  

On 10/23/06   UAAD and its AFFILIATES Requested a delay of the proposed merger of Regions Bank and AmSouth Bank pending a CONGRESSIONAL HEARING.
We are asking community and civil rights organizations to assist in stopping this merger.  This process will create circumstances whereby these banks will not negotiate in good faith CRA agreements with community organizations as required under the Civil Rights Legislation, the COMMUNITY RE-INVESTMENT ACT of 1977.

http://www.unitedaffirmativeactiondevelopment.com/id34.html http://www.unitedaffirmativeactiondevelopment.com/id28.html

http://www.unitedaffirmativeactiondevelopment.com/id29.html

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