Monday, February 20, 2006

 
RBD/UAAD Quarterly BANK CRA Rating

Our 501c3 non-profit Community Organization(s) will issue quarterly CRA ratings reports on our nations banks.
We will utilize the Federal Reserve Board Banks National Reports, state reports, and local branch reports to evaluate banks specific performance.
Reports and their results will be publicized via news conference, weekly radio broadcast, web cast on KTYM.COM and other news media sources.
Banks will be asked to provide their past 2yr Community Performance reports. Such reports will assist RBD/UAAD in evaluating each banks adherence to the intent of The Community Re-Investment Act of 1977 (CRA).
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.
Our commitment is to insist that banks such as JPMorgan Chase Bank enter into agreements as suggested under CRA in order to provide financial assistance to low-income moderate-income individuals to include African Americans in particular and to eliminate past redlining and discriminatory practices by banks.
We will lobby Congress, The FDIC, OCC to insist that the bulk of the 4.2trillion dollars banks have committed to CRA will be available to African Americans as intended by CRA which was passed as part of Civil Rights legislation in 1977. Had Chase Bank provided the bulk of their 800 billion dollar to African Americans as UAAD and ACORN has attempted to negotiate since 1995, many victims of Katrina would have had a better chance of survival.
The sooner JPMorgan Chase Bank make these funds available to African Americans who are and were the main victims of red-lining, and discrimination, and the reason this regulation was enacted by Congress, the sooner the Katrina victims and other African Americans will be able to achieve financial stability and economic parity.
Banks practices of committing the bulk of their CRA funding to Caucasians rather than to African Americans who are the victims, and the reason for enacting the Civil Rights legislation CRA should cease, and these funds need to be channeled to those the act was originally intended.
CRA agreements negotiated in good faith will be a benefit to both banks and the community they serve or should serve. The bulk of Chase Banks $800 billion dollars commitment should be used to rebuild the Gulf Coast and other urban areas where African Americans are in dire need.
These funds utilized as the Act intended will help to eliminate poverty and assist the destitute and homeless wherever they exist.
RBD/UAAD with a coalition of other community organizations intend to lobby Congress, the FDIC, OCC and our nations banks to address these issues now, not later.
Contacts:
Recycling Black Dollars (RBD)
Muhammad Nassardeen
“Positive Side Radio Program
http://www.ktym.com/ (Mon 1-2PM PST)
1460AM (Los Angeles)
http://www.rbdglobal.com/
Audience call in 310 673-7777

United Affirmative Action Development Corp (UAAD)
Walter L. Ellis/CEO and VP CRA enforcement for (RBD)
http://www.uaadcorp.com/ uedcinc@aol.com Toll free

Sunday, February 19, 2006

 
Observing Bank One/Chase Bank’s Public Disclosure Performance Evaluation for June 1999 and March 2004 in various states, it appears that Chase Bank/Bank One’s CRA commitment is “low satisfactory” in areas where African Americans reside. (see Public Disclosure Reports)
UAAD/RBD’s CRA evaluation would rate Chase Bank/Bank One’s performance in Louisiana, Texas, Oklahoma and Illinois “poor” and unsatisfactory. This evaluation is based on 10 years of attempting to negotiate a CRA agreement
with Bank One/Chase Bank. (see http://www.uaadcorp.com/ and blogs)

 
CRA COMPLAINT
Case # 617-354 Re: JP Morgan/Chase Bank
Non-compliance of 12CFR25.43 OCC/FDIC CRA Regulations

Presented to

Members of the Congressional Finance Committee
of the
United States Congress
Rayburn House Office Bldg
Washington, DC 20515
and
Office of the Comptroller of the Currency
Compliance Division
250 E Street, SW – Mail Stop 6-7
Washington, DC 20219

See: www.uaadcorp.com
www.rbdglobal.com

 
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 (www.uaadcorp.com), is working with Recycling Black Dollars, a Los Angeles-based 501(c) 3 (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.
We would appreciate it if you would facilitate this worthy effort of setting up a meeting. I am available if you have any questions. I can be reached at, (866) 276-2294 in my office or please feel free to use my cell phone number at, (951) 452-9160.
Thank you for your time and consideration. I look forward to hearing from you soon.
Kind regards,
Mr. Walter Ellis, CEO of United Affirmative Action Development Corp
Mr. Muhammad Nassardeen, CEO of Recycling Black Dollars

 
February 16, 2006

Ms Charlita S. Cloman, VP
Community Partnership Mgr
Community Development Grp
LA1-1882
P.O. Box 21116
Shreveport, LA 71154-0001

RE: Non-Compliance of CRA Regulation 12CFR25.43 (Content and Availability of Public File)

Ms. Cloman,
United Affirmative Action Development Corp (UAAD), a 501c3 non profit community organization is seeking branch CRA activities for the past 2 years. We ask that these be made available by all separate branches and that each branch post their separate report in order that the public may observe, as required under The Community Re-investment Act of 1977 (CRA). I would appreciate a reply to this request. I was told by Ms. Bridgette Sanders, who stated she was the CRA Representative for the main Ruston branch that she would provide the above request, and today she stated I would have to contact your office in order to receive the report for the Ruston branch. Your indication that you are proud of your bank’s CRA activities should indicate that the public should be aware of same.
Ms. Cloman it is the concern of UAAD and other organizations, some being Recycling Black Dollars (RBD), the NAACP, and others that your bank is withholding this public information to hide your past and present discriminatory, predatory practices.
Ms. Sharon Gilstrup who is a supervisor at The Office of the Comptroller of the Currency (OCC), advised that a Small Bank has 20 minutes to produce their CRA performance Report upon request. Your bank or branches a Large Bank have up to five days to produce your past two year performance reports.
As the CEO of UAAD on February13, 2006 a request was made for your CRA Performance Reports at 3 (three) locations:
Chase Bank / LA1-1901, 400 Texas Street, Shreveport, LA 71101
Chase Bank, 1935 Airline Dr, Shreveport, LA.
Chase Bank, LA1-9557, 400 N. Trenton, Ruston, LA
UAAD request that these and all branch reports be made available to this 501c3 non-profit, and all organizations and individuals that you are required to provide such reports, under CRA regulations and rules. You providing and having these reports available on or by February 20 ,2006 would be appreciated. Our request is that these reports be posted in public view at all branches throughout Louisiana where JPMorgan Chase/Bank operates.
Your immediate reply to this request is appreciated.
Respectfully,
Walter L. Ellis CEO / UAAD / VP CRA Compliance RBD
For more information see: http://www.uaadcorp.com

 

Ms. Bridgette Sanders, CRA Mgr December 5, 2005
Chase Bank
400 N. Trenton St
Ruston, LA 71270

Ms. Sanders,
This is a complaint regarding our conversation 11/25/05 whereby you indicated you would furnish United Affirmative Action Development Corp (UAAD), a 501c3 non-profit community organization, a copy of your branch’s recent CRA activities. You first stated that your CRA representative would provide the documents and later stated that you were the CRA representative and the report could be picked up on Monday (11/28/05). UAAD was given a performance evaluation from the OCC, which shed little light on your branch’s performance here in Ruston, LA. UAAD would appreciate a recent activity report of the Chase Bank branches here in Ruston, in order to compare with the one received prior to Bank One purchasing Premier Bank in 1996. UAAD would like to have this report by 12/6/05.
As the closest CRA official of Chase Bank, I would appreciate you meeting with staff of UAAD and explain how your branch carries out its CRA obligations. A meeting sometime this week would be beneficial. Topics to be discussed at such a meeting would include how undergraduate and graduate students at Grambling State University (GSU), a HBUC, can contribute to and benefit from the bank’s CRA commitments.
In 1995 when the president of Premier Bank, Mr. Johnnie Maxwell, asked UAAD to assist the Ruston’s Banks in improving its CRA performance in order to amplify the merger with Bank One, an inspection of Premier’s CRA involvement in the community showed that it excluded African Americans. UAAD would ask that you provide an updated activity report of the Ruston Branch’s in order that we may discuss a satisfaction or how to improve the bank’s performance in the low, moderate income, to include the African American community. Thanks for your cooperation. See our website www.uaadcorp.com to better understand our purpose and goals.

Walter L. Ellis
CEO UAAD

 
December 9, 2005

Ms. Cloman,
United Affirmative Action Development Corp (UAAD), a501c3 non profit community organization is seeking branch CRA activities for the past 2 years. We ask that these be made available by all separate branches and that each branch post their separate report in order that the public may observe, as required under The Community Re-investment Act of 1977 (CRA). I would appreciate a reply to this request. I was told by Ms. Bridgette Sanders, who stated she was the CRA Representative for the main Ruston branch that she would provide the above request, and today she stated I would have to contact your office in order to receive the report for the Ruston branch. Your indication that you are proud of your bank’s CRA activities should indicate that the public should be aware of same. This being the case it should benefit your bank in our promoting your concerns. Our reason for asking to see these reports is to confirm Mr. Scott’s denial that JP Morgan/Chase Bank does not discriminate against African Americans. Attached is an email recently received from Mr. Mizel Scott, VP CRA JP Morgan/Chase Bank.
For additional information see: http://www.uaadcorp.com
Respectfully,


Walter L. Ellis
CEO / UAAD
walter@uaadcorp.com
uedcinc@aol.com

 
12/5/05

Dear Mr. Ellis:
We have received a number of e-mails from you commenting upon Chase's CRA performance in Louisiana and requesting a "CRA Agreement" between United Affirmative Action Development and Chase. We strongly object to your comments that Chase engages in discriminatory or redlining practices. In our September response to similar e-mails from you, we informed you that it is not Chase's policy to enter into CRA agreements because we believe our record of helping to strengthen and develop the communities in which we do business speaks for itself. We also sent you in September the most recent CRA public evaluation for Bank One, N.A. Illinois, (now Chase) which includes an evaluation of the bank's CRA performance in Louisiana. The OCC rated Bank One's performance in Louisiana as "Satisfactory" overall and rated the Lending test "High Satisfactory" and the Investment Test "Outstanding." It noted that Bank One had good performance in LMI geographies and lending volume and excellent performance to LMI borrowers. Again, if you or your organization wishes to apply for a small business or consumer loan, information is available on Chase's web site, www.chase.com. Respectfully,

 
December 5, 2005

Mr. Scott,
Your email dated 12-1-05 regarding Chase Bank’s performance in Louisiana is perplexing. UAAD inspected the CRA Performance of Premier Bank’s main branch in Ruston, LA in 1995. This branch’s performance did not indicate any loans or CRA contributions to African Americans. On 11/25/05 our office spoke to Ms. Bridgette Sanders, the branch manager who first stated that I should get in touch with Charlita Cloman in Shreveport. Then she stated that a CRA representative at the Ruston branch would prepare the report. She later stated that she would complete the report and our office could pick it up on Saturday or Monday. We were given approximately 275 pages which included the state of Louisiana, but it did not include the Ruston main branch performance for the past 2 years. Since we have a previous report that indicate poor performance, we would ask that you advise Ms. Sanders to provide the report she promised on 11/25/05.Louisiana’s most recent performance report (see report) will indicate why the lack of service to African Americans in New Orleans and other areas of Louisiana, help create the poverty that existed and still exist. See www.uaadcorp.com and blogs. See State of LA/N.O. PMA pg C-11 of Chase Bank Performance Evaluation which indicates that Chase Bank practiced predatory lending then and now. Give me your opinion.

 
11/3/05

Mr. Scott,
We would like to hear from you to further our prior conversation regarding negotiating a "CRA" agreement as previously indicated. The following web and blog sites will better explain our interest:

http://www.unitedaffirmativeactiondevelopment.com/

http://www.uaadcra.blogspot.com/

http://www.uedcrabank.blogspot.com/

http://uaadcrahbuc.blogspot.com/

In 1998 UAAD filed a complaint with The Federal Reserve Board at a public meeting regarding the merger of Bank One and First Chicago, August 13, 1998. The following is a transcript of the meeting.
http://www.federalreserve.gov/events/publicmeeting/19980813/panel16.htm

On November 2, 2005 UAAD representatives met with officials at Grambling University to re-open negotiations with the intent of establishing an agreement with Chase Bank under the Community Reinvestment Act of 1977. With your cooperation we believe this program can be implemented in a short period of time. We will be meeting with officials of GSU next week and would like to have a reply from your office (Chase) prior to this meeting.

Walter L. Ellis
Executive Director UAAD

 
10/11/05

TO: Mike Scott
CRA Rep. Bank One
RE: Request to Negotiate CRA Agreement

Mr. Scott,
Now is the time for JP Morgan/Chase Bank to negotiate an agreement under the “Community Re-Investment Act of 1977 (CRA) with United Equity Development Corporation (UEDC) AND United Affirmative Action Development Corporation (UAAD).
As Indicated in JP Morgan/Chase Bank’s CRA (Community Partnership) Proposal, this bank has proposed to contribute over three hundred billion dollars ($350,000,000,000) toward CRA- Community Partnerships activities. (see JP Morgan/Chase via www.unitedaffirmativeactiondevelopment.com (pg 9, 41 & 45)
CRA was implemented in 1977 to regulate our nation’s banks to address the issue of red-lining, for example the African Americans in New Orleans and other ghetto’s of America.
Bank of America in approximately 1997, 1998 signed a $350, 000,000,000 CRA agreement for 10 years with “ACORN” in order for the low, moderate income to purchase homes at low interest rates.
UAAD/UEDC’s proposal addresses home, business development and other components that will assist our members, the low, moderate income to include African and Native Americans who the regulations should have addressed. Once JP Morgan/Chase/Bank One fulfill its obligations under the CRA Act and other banks nationwide following suit, not only can New Orleans and the Gulf Coast be rebuilt orderly, it will also lend to providing economic parity to all these banks serve or should serve.
UAAD/UEDC is seeking assistance from community organization, businesses, and congress and government agencies in order to further our efforts in negotiation a CRA agreement with JP Morgan/Chase/Bank One. Now is the time to implement our proposal in order to assist those this act should have addressed when enacted in 1977. Now is the time to distribute funds to those most in need with banks operating under CRA guidelines.(see CRA summary)UAAD/UEDC’s proposal provides protections and benefits to the community it serves and Chase Bank in order that both will achieve its goals. UAAD/UEDC nor ACORN’s agreement entails the bank(s) setting aside, nor contributing these funds to community organizations. It is simply a commitment by the bank(s) to provide these funds to low, moderate income individuals with organizations as ours negotiating such agreements. UAAD/UEDC’s proposal includes consulting with its members in order to assist it’s members in paying back the loans and assist participating banks in providing economic parity for those that the act should have been intended to assist. When politicians neglect certain segments of our society, they can be impeached, recalled or voted out of office. When financial institutions neglect certain portions of our society, all rules and regulations such as CRA should be enforced to the fullest extent possible.
Mr. Scott in order to move these negotiations in the directions intended by UAAD/UEDC, we would like to meet with the official from JP Morgan/Chase Bank that can produce the desired results of UAAD/UEDC. Provided your position and official capacity would lend to an agreement with Chase Bank it would be beneficial to again meet with you if your official capacity will lead to an agreement.
We appreciate your involvement in the past and are in hopes of your further involvement in this important project. See the following websites for more info www.unitedaffirmativeactiondevelopment.com and www.uedcbank.blogspot.com
Sincerely,
Walter L. Ellis
UAAD/UEDC

 
9/28/05

Ms Reynolds
Based on our two telephone conversations and the email I received from you on 9/26/05, I would assume that you are the main spokesperson to determine whether there will be or should be a CRA negotiation between UAAD AND Chase Bank, as regulations under the Community Re-investment Act of 1977 and according to your performance evaluation that you sent to UAAD in the above mentioned email.
Due to your bank’s evaluation it is apparent that your statement and a similar statement by Ms. Coleman and others that “I am proud of Chase Bank’s CRA performance” will indicate how Chase Bank employees feel that they have no obligation to African Americans. I base this assumption on past and present practices. Chase Bank has contributed to the lack of financial support to the victims of Katrina, especially the people of the 9th ward in New Orleans. As a former police officer I feel obligated to investigate both violations of regulations and criminal acts.
The violations and inhuman treatment, of your bank with your assistance, espouses on African Americans and others should be investigated by Congress, Jesse Jackson, Minister Farrakan, ACORN and Amnesty International. I would ask the FDIC and OCC to again investigate as I did in 1999. I found out in 1999, when Clinton was in office, they supported rather than condemned Bank One’s wrongful acts. Now with Bush causing lost of life disproportionately in Iraq and now in New Orleans, we certainly do not want any assistance from him or his administration. Therefore it is UAAD’s intent to ask Amnesty International to investigate and come to the assistance of those so in need of “help”. I believe that Chase Bank is in violation of the “Rico Act” and an international body should assist in pursuing charges. Had Bank One acted in good faith in 1995 with CRA negotiations with UAAD/UEDC, it is my belief that the living conditions in the 9th ward of New Orleans and other communities would have been improved and thousands of lives probably would not have been lost. The end blame should be put on the federal agencies who should be obligated to protect “all” the people and not adhere to the Bush doctrine of freedom and liberty for Caucasians only.
I as CEO of this organization feel as I did when taking an oath as a police officer, an obligation to serve and protect the rights of all, regardless of race, creed or color. You would thing that the FBI and others in law enforcement would adhere to a similar oath that I myself fell obligated. Such federal agencies that practice and uphold discrimination provide fertile ground for right wing extremists and outlaw banks also supported by Bush and his mother.

 
September 27, 2005

Ms. Reynolds
I received your email dated 9/26/05 and your bank’s most recent performance evaluation for Bank One (all 274 pages).
On a separate note I asked whom I would speak to or could meet with in order to discuss a CRA agreement with Chase Bank/Bank One. Your reply was that individual who at the time of our conversation you were unable to identify, would be in your Chase Bank, New York office. You stated it would be the following week before you could contact that individual. You also stated you would pass on that information when you contacted him or her. I also asked what your position with the bank was and if you were a CRA official capable of discussing an agreement and you again stated that person is in the New York office.
You didn’t give me your position with the bank and I would appreciate knowing what your title is in the event UAAD may enter into an agreement with Chase Bank as you related that there were other opportunities offered by your bank to assist community organizations such as UAAD, a 501c3 non-profit.
I asked that you review our web site in order for you to understand that Bank One when it purchased Premier Bank, UAAD was invited by Premier to assist in enhancing its CRA programs. Bank One CRA officials also discussed agreements with UAAD, verbally and in writing. After the merger was finalized UAAD filed a complaint with the FDIC and OCC due to the bad faith negotiations on the part of Bank One. (documents are available)
So I say to you, Ms Reynolds that I strongly object that you would accuse UAAD or me of making false accusations regarding Chase Bank being involved in discriminatory practice, but according to Premier and Bank One officials, they clearly stated that their banks were guilty of both red-lining and discriminatory practices. There may come a time when these charges can be brought out for Congress, the courts and the public to review. I personally do not need your web address in order to find the nearest Chase Bank, I’m aware of Chase Banks lending practice to African Americans, in particular, and believe that our CRA proposal will assist in alleviating your bank’s present and past performance.
UAAD’s aim and goals is to assist Chase Bank in providing economic parity to “all” in the community your bank serves. Our proposal entails programs that will allow Chase Bank to enter into an agreement with benefits for the community and “Chase Bank consistent with safe and sound banking practices.
Your immediate reply would be appreciated.
Sincerely,
Walter L. Ellis, CEO UAAD/UEDC

 
9/21/05

Ms Reynolds,
Thank you for calling me this morning. As you are aware UAAD is seeking to negotiate a CRA agreement with Chase/Bank One. (See our website http://www.unitedaffirmativeactiondevelopment.com/) I did speak to Ms. Kim Weaver this past Friday and she stated she would mail me your CRA performance for the past 2 years. As of yet I have not received these statements. Ms. Reynolds you also stated that the Bank does not enter into agreements as UAAD requested. You also asked if UAAD, a 501c3 non profit had investments to participate with the Banks contributions. I advised that we were seeking to negotiate as we had previously with Premier Bank and Bank One, an agreement to assist our members in gaining low interest loans, and those members to include African Americans as I believe the original intent of CRA. Your final statement as I recall was that though your bank (Chase) does not enter into agreements as I explained, you stated "let’s talk about it and there may be a way we can meet your needs and ours". I consider this a positive statement on the banks behalf and ask that you or an official with the authority to receive, accept and negotiate an agreement be provided as soon as possible. We are speaking to members and other organizations especially the Katrina Hurricane victims on a daily basis with expectations that bank assistance is forth coming. With my understanding and information I have passed on to those in need it is important that you or an official with the proper authority can contact me in writing and let me know if and why an agreement can or cannot be negotiated with Chase Bank under the Community Investment Act of 1977 (CRA). Time is of the essence, my family, my members, and many others have suffered and continue to suffer due to past red lining by your bank and others. These same individuals and the victims of Hurricane Katrina need our and your help now and later.
Please reply
12CFR 25.43 Content and availability of public file
(a) Information available to the public. A bank shall maintain a public file that includes the following information:
(b) Additional information available to the public--(1) Banks other than small banks. A bank, except a small bank or a bank that was a small bank during the prior calendar year, shall include in its public file the following information pertaining to the bank and its affiliates, if applicable, for each of the prior two calendar years:
(i) If the bank has elected to have one or more categories of its consumer loans considered under the lending test, for each of these categories, the number and amount of loans:
(A) To low-, moderate-, middle-, and upper-income individuals;
(B) Located in low-, moderate-, middle-, and upper-income census tracts; and
(C) Located inside the bank's assessment area(s) and outside the bank's assessment area(s); and
(ii) The bank's CRA Disclosure Statement. The bank shall place the statement in the public file within three business days of its receipt from the OCC.
(c) Location of public information. A bank shall make available to the public for inspection upon request and at no cost the information required in this section as follows:
(1) At the main office and, if an interstate bank, at one branch office in each state, all information in the public file; and
(2) At each branch:
(i) A copy of the public section of the bank's most recent CRA Performance Evaluation and a list of services provided by the branch; and
(ii) Within five calendar days of the request, all the information in the public file relating to the assessment area in which the branch is located.
(d) Copies. Upon request, a bank shall provide copies, either on paper or in another form acceptable to the person making the request, of the information in its public file. The bank may charge a reasonable fee not to exceed the cost of copying and mailing (if applicable).
(e) Updating. Except as otherwise provided in this section, a bank shall ensure that the information required by this section is current as of April 1 of each year.

Comptroller of the Currency Administrator of National Banks
LARGE BANK

Public Disclosure

June 30, 1999

Community Reinvestment Act Performance Evaluation

Bank One Louisiana, N .A. Charter Number:. 13655

. 4

451 Florida Street Baton Rouge, LA 70801

Office of the Comptroller of the Currency

. .

I 1


Large Bank Division
250 E Street, S. W.
Washington D.C. 20219-0001

. I
NOTE: This evaluation is not, and should not be construed as, an assessment of the financial condition of this institution. The rating assigned to this institution does not represent an analysis, conclusion, or opinion of the federal financial supervisory agency concerning the safety and soundness of this financial institution.

Overall CRA Rating
Institution's CRA Rating: This institution is rated Satisfactory.
The following table indicates the performance level of. Bank One, Louisiana, NA (BOLA) with respect to the Lending, Investment, and Service Tests:
Bank One, Louisiana, NA

· The Lending Test is weighted more heavily than the Investment and Service tests when arriving at an overall rating.
The major factors that support this rating include:
The bank's volume of lending was good. Overall volumes of lending were good for both home mortgage products and small loans to businesses.

The geographic distribution of lending by income level of geography was adequate. Performance varied by loan product and market ranging from excellent to poor. Small business lending has an overall good geographic distribution.

The distribution of lending by income level of borrower was adequate. The! bank's performance for all home mortgage products was adequate. The bank's
performance in small business lending could not be assessed due to the lack of
information.
· The bank offers an adequate level of innovative or flexible lending programs. By offering an array of different products and programs the bank is helping to meet the consumer and commercial credit needs within their communities
In determining the size and capacity of BOLA for CRA evaluation purposes, we specifically considered operating subsidiaries of the bank. None of the bank's operating subsidiaries contributes to or detracts from the CRA performance of the bank.
There are no significant financial barriers limiting BOLA's ability to help meet the identified credit needs of its assessment areas.
There were seven affiliated, non-bank entities that contributed to the bank's CRA performance. Refer to Appendix A for identification of the entities and -the activities they contributed.
Statistical Areas (MSAs), and At present, BOLA's market area consists of aU or parts of eight Metropolitan five assessment areas in non-metropolitan parts of the state. AU of the assessment areas are within the State of. Louisiana. The bank's assessment areas include:

1) Alexandria MSA (added November 1 998)
2) East Baton Rouge Parish within the Baton Rouge MSA 3) Houma MSA
4) The southwestern portion of the Lafayette MSA
5) Lake Charles MSA
6) The northeastern portion of the New Orleans MSA
7) Monroe MSA
8) The western portion of the Shreveport MSA
9) Lincoln, Union, Morehouse, and Claiborne Parishes
1 O)l Iberia and St. Mary Parishes
11) Jefferson Davis Parish
1 2) Natchitoches Parish
13) Tangipahoa Parish
Several of the bank's assessment areas changed during the evaluation period due to the acquisition of First Commerce Corporation and related bank mergers. For purposes of this evaluation, the changes were considered effective November1998.
The changes to the assessment areas included: the addition of the Alexandria MSA; the addition of Ascension Parish to the Baton Rouge assessment area; the addition of St. Landry Parish in the Lafayette assessment area; the addition of St. Charles and St. John the Baptist parishes in the New Orleans assessment area; the addition of two census tracts in Beauregard Parish; the addition of Grant Parish; and the addition of Vermillion Parish to non-metropolitan area
detailed separately in the tables since this area received a full-scope review.

Data Itegrity
The scope of this examination included a review of the accuracy of the bank data analyzed to develop our conclusions and ratings. The data tested for accuracy includes information made available to the public in accordance with the Home Mortgage Disclosure Act (HMDA) and the CRA regulation. Public data includes home mortgage lending and small loans to businesses and farms. We also reviewed the accuracy of non-public data for qualified investments, community development services, and community development loans. The test was performed at the corporate level and included all Bank One affiliated banks reporting data. Therefore the percentages quoted here would be for the entire corporation, and may vary for a particular Bank One subsidiary.
The bank's HMDA data was found to be accurate. No material errors were noted with the home purchase, home improvement, or refinance loans reported by the bank.
Several errors were found in the bank's 1998 small loans to businesses submission. The material errors noted were:
Commercial leases were incorrectly reported as loans. Incorrectly reported leases represented 1.9% of the loan submitted.
Guidance lines of credit were incorrectly reported as loans. Incorrectly reported guidance lines of credit represented 3.8% of the loans submitted.
Revenue data was in error for 17% of our sample.
Management was able to remove the commercial leases from the data provided to the examiners. The data for the entire evaluation period was corrected. The correction of the data for guidance lines of credit did not cover the entire evaluation period. Management removed 149 guidance lines totaling $32 million from the 1998 data, but was unable to identify guidance lines in the 1997 data. We therefore estimate that the small loans to businesses in this report are overstated by 196 loans or 4.2% of the reported number of loans and $40 million or 8.9% of the total reported dollar. Due to the corrections made, the data analyzed as part of this examination will differ from the data publicly reported. The revenue information reported for small loans to businesses was not corrected and we did not analyze the bank's performance in lending to small businesses in this evaluation.
Conclusions with Respect to Performance Tests
LENDING TEST
Conclusions for Areas Receiving Full-Scope Reviews
The bank's Lending Test performance was adequate.
Lending Activity
BOLA's overall volume of lending is good in New Orleans, Lafayette, and Shreveport, and is adequate in Lincoln. In our analysis of home mortgage lending performance more weight was given to performance in home improvement lending as this is a more significant product line in the bank's business strategy.
Refer to Table 1 in Appendix C for the data used in this analysis.
In each of the full-scope assessment areas, BOLA" has the number one deposit market share position.
The volume of home mortgage lending in New Orleans is good. In New Orleans the bank's volume of home improvement and refinancing lending is good as the bank achieved the number two market share ranking for both lending products. The bank's volume of home purchase loans is adequate with a market share rank of sixth.

In Lafayette, the volume of home mortgage lending is good. For home improvement lending the bank's performance is good having achieved the number two market share ranking. For refinance lending, the bank's performance is excellent having achieved the number one market share ranking. The bank's volume of home purchase loans is poor with its market share ranking for home purchase loans substantially below its deposit market share rank.
The volume of home mortgage lending in Shreveport is good. In Shreveport, home improvement, and refinancing lending is good as the bank achieved the number two market share ranking for both lending products. The bank's volume of home
purchase loans is poor with the bank's market share rank for home purchase loans substantially below its deposit market share rank.

In Lincoln, the overall volume of home mortgage lending is adequate with home improvement lending being good as the bank's home improvement market share ranking is close to the bank's deposit market share ranking. The bank's volume of home purchase and refinancing lending is adequate in the Lincoln assessment area.

The volume of small business lending is excellent in Lafayette and Shreveport with the bank achieving the number one market share ranking. In Lincoln, the bank's volume of small business lending is excellent as the bank achieved the number two market share ranking for small loans to businesses. The bank's volume of small loans to businesses is good in New Orleans. This conclusion considers the over reporting of small business loans to businesses as discussed in the Scope section of this evaluation under Data Integrity.

Overall, the bank's volume of community development lending is adequate in Lafayette and poor in Shreveport and New Orleans. There were no community development loans made in the Lincoln assessment area. To help gauge the volume of community development lending in individual assessment areas, the volume of community development loans was calculated as a percentage of Tier 1 capital. This calculation involved allocating Tier 1 capital to each assessment area based on the percentage of the bank's deposits derived from that assessment area. The volume of community development loans represented 2.4% in Lafayette, 0.5% in New Orleans, and 0.4% in Shreveport. Additional details on BOLA’s community development lending are provided later in this evaluation.

Distribution of loans by Income level of Geography
The distribution of loans by income level of geography is adequate. Performance is adequate in New Orleans, poor in Lafayette, and good in Shreveport and Lincoln.
We did not find any conspicuous gaps in the bank's lending patterns for the assessment areas that received full-scope reviews. During the evaluation period, there were no clusters of low- or moderate-income census tracts that were not penetrated by at least one of the bank's home purchase, home improvement, home refinance, or small business loan products.
During our analysis, it was noted several times that the bank's lending performance in low- and moderate-income census tracts, as measured by the percentage distribution of loans, was not consistent when compared to the bank's market share performance in the corresponding areas. The percentage of distribution data was given more weight since it covers a longer time period, as the market share information is for 1998 only. In addition to the different time periods used for these two measures, the market share data may be a reflection of weak performance in low- and moderate-income areas by all financial institutions.
While the distribution of home improvement loans in low-income areas of Shreveport is adequate, the bank's market share penetration is excellent as the market share percentage in low-income areas exceeds the bank's overall market share percentage in the Shreveport assessment area. Overall, geographic distribution of home improvement loans in low-income areas of Shreveport is good. In moderate-income areas of Shreveport the bank's distribution of home improvement loans is good and market share penetration is excellent. The percentage of loans made in moderate-income areas of Shreveport is near the percentage of owner-occupied units for the area. The home improvement market share percentage is excellent in moderate-income areas of Shreveport as the ratio matches the bank's overall market share percentage for home improvement loans in the Shreveport assessment area. Giving more weight to the bank's loan distribution performance the overall geographic distribution of home improvement loans in moderate-income areas of Shreveport is good.

In Lincoln, the geographic distribution and market share penetration of home improvement loans is excellent for moderate-income census tracts. The bank's percentage of home improvement loans made in moderate-income areas exceeds the percentage of owner-occupied housing units, and the market share percentage in moderate-income areas exceeds the bank's overall home improvement market share percentage for the Lincoln assessment area.

Geographic distribution for refinancing loans is poor in New Orleans, adequate in Lafayette and Shreveport, and good in Lincoln;

In New Orleans, the distribution of refinancing loans in low-income areas is poor with percentages of loans made significantly below the percentage of owner ­occupied housing units. The bank's market share percentage is adequate and is close to the bank's overall market share position for refinancing loans. With more weight on the bank.' s loan distribution performance, the overall geographic distribution of refinancing loans in low-income areas of New Orleans is poor. In moderate-income areas of New Orleans the distribution of refinancing loans is also poor, while the market share penetration is adequate with the market share percentage being close to the bank's overall market share percentage for refinancing loans in New Orleans. With more weight being given to the bank's distribution of loans, the overall conclusion in regards to the bank's geographic distribution of refinancing loans in moderate-income areas of New Orleans is poor.

In Lafayette the geographic penetration of refinancing loans in low-income areas is adequate, however the market share analysis reflects excellent performance with the market share percentage in low-income areas significantly exceeding the bank's overall market share percentage for the Lafayette assessment area. Overall, the bank's geographic distribution of refinancing loans to low-income areas in Lafayette is good. The distribution of refinancing loans and market share penetration in moderate-income areas in Lafayette is poor. The percentages of bank loans made and market share are significantly below the percentage of owner-occupied housing units and the bank's overall market share position for refinancing loans in moderate­income areas of Lafayette. With more weight given to the bank's loan distribution performance and with more owner-occupied housing units located in the moderate­ income areas the bank's overall performance in regards to distribution of refinancing loans to low- and moderate-income areas of Lafayette is adequate.

In Shreveport, geographic distribution of refinancing loans in low-income areas is poor. The percentage of loans made is significantly below the percentage of owner-occupied housing units for refinancing loans in Shreveport. The bank's market share percentage for refinancing loans in low-income areas of Shreveport is also poor because the bank's market share of refinancing loans in low-income areas is less than the bank's overall market share for refinancing loans. In moderate­ income areas of Shreveport, the distribution of refinancing loans is adequate while the market share penetration is excellent with the market share percentage in moderate-income areas significantly exceeding the overall market share percentage for the Shreveport assessment area. The overall conclusion in regards to the bank's geographic distribution of refinancing loans in moderate-income areas in Shreveport is good. Combined, the bank's overall performance for geographic distribution of refinancing loans to low- and moderate-income areas in Shreveport is adequate.

While the geographic distribution of refinancing loans in the Lincoln moderate ­income census tracts is adequate, the market share penetration is excellent as the percentage substantially matches the overall market share percentage in the Lincoln assessment area. The overall geographic distribution of refinancing loans in Lincoln is good.

Small Business Loans
Refer to Table 5 in Appendix C for the data used in this analysis.

The geographic distribution of small loans to businesses is excellent in Shreveport, good in New Orleans, adequate in Lincoln, and poor in Lafayette.
The percentage of the bank's loans exceeded the percentages of small businesses located in both low- and moderate-income areas in Shreveport. In addition, market share penetration in low-income areas is good with the percentage being near to the bank's overall small loans to business market share in the Shreveport assessment area. The bank's small loans to businesses market share position are excellent in the Shreveport moderate-income areas with the percentage exceeding the percentage of the bank's overall small loans to business market share.

The bank's loan distribution in both low- and moderate-income areas of New Orleans is good for small loans to businesses. In New Orleans the percentage of the bank's loans were near the percentage of small businesses in both low- and moderate-income areas. In low-income areas, the bank's market share percentage exceeded the bank's overall small loans to business market. The bank's market share percentage in moderate-income areas matched the bank's overall market share percentage for small loans to businesses. With more weight given to the bank's loan distribution performance, the overall geographic distribution of small loans to businesses in both low- and moderate-income areas of New Orleans is good.

The bank's percentage of small loans to businesses and market share position is adequate with percentages being close to the percentage of small businesses and the bank's overall market share position in Lincoln.

The bank's geographic distribution in both low- and moderate-income areas of Lafayette is poor for small loans to businesses. The bank's percentage of loans made in both low- and moderate-income areas is significantly below the percentage of small businesses in the Lafayette assessment area. While the market share percentage in low-income areas in Lafayette is adequate, the market share percentage in moderate-income areas is poor in relation to the bank's overall market share percentage. With more weight given to the bank is distribution of loans, the bank's overall performance on the geographic distribution of small loans to businesses. in Lafayette is poor.

Distribution of Loans by Income level of the Borrower
The distribution of loans by borrower income level is good in New Orleans and Shreveport and adequate in Lafayette, and Lincoln.
During our analysis it was noted several times that the bank's lending performance, as measured by percentage of loans to low- and moderate-income borrowers, was not consistent when compared to the bank's corresponding market share .performance. This inconsistency is probably caused by the fact that market share data is for just one year. The borrower distribution performance data was given more weight since it covers a longer time period.
The market share ratio of refinancing loans to moderate-income borrowers in New Orleans is good with the ratio being near to the bank's overall market share ratio for refinancing loans in the assessment area. In Shreveport the market share position for refinancing loans to moderate-income borrowers just exceeds the bank's overall market share and is considered excellent. Market share position for refinancing loans to moderate-income borrowers is adequate in Lafayette and poor in Lincoln. With more weight given to the bank's loan distribution performance, the overall conclusion is that the borrower distribution of refinancing loans to moderate ­income people is adequate in New Orleans, and poor in Lafayette and Lincoln. Overall borrower distribution of refinancing loans to moderate-income borrowers in Shreveport is good.

Small Business Loans
No conclusion was developed for this aspect of the bank's lending performance. This situation is the result of the data integrity issue noted earlier, and the fact that revenue information was not available for 9% of the bank's reported small loans to businesses. We did note that a high percentage of the bank's small business loans were in amounts of $100,000 or less. However, loan size is not considered a reliable indicator of the extent that the bank's small loans to businesses were made to small businesses.

Community Development Lending
As noted above considering volume, innovativeness and complexity community development lending is adequate.
The volume of community development loans is adequate in the Lafayette assessment area and poor in Shreveport and New Orleans. There were no community development loans made in the Lincoln assessment area.
The volume of community development loans in the New Orleans assessment area is poor. Community development loans represent 0.5% of Tier 1 capital allocated to this assessment area. The bank made two community development loans during the evaluation period. One was for the retention of affordable housing and rehabilitated 81 affordable rental housing units. The second loan was part of a larger project to revitalize a blighted neighborhood.
In the Lafayette assessment area community development loans represent 2.4% of Tier 1 capital. Two loans were made, and both loans were for the creation of affordable housing. The loans created 40 new affordable rental units.

Comptroller of the Currency Administrator of National Banks
Washington. DC 20219
Public Disclosure
March 31,2004

Community Reinvestment Act Performance Evaluation
Bank One, N.A., Illinois Charter Number: 8
One Bank One Plaza Chicago, Illinois 60670
Office of the Qomptroller of the Currency Large Bank Supervision 250 E Street S. W. Washington, D.C. 20219

NOTE: This document is an evaluation of this institution's record of meeting the credit needs of its entire community, including low- and moderate-income neighborhoods, consistent with safe and sound operation of the institution. This evaluation is not, and should not be construed as, an assessment of the financial condition of this institution. The rating assigned to this institution does not represent an analysis, conclusion, or opinion of the federal financial supervisory agency concerning the safety and soundness of this financial institution.

State of Louisiana Rating
CRA Rating for the State: Satisfactory
The Lending Test is rated: High Satisfactory
The Investment Test is rated: Outstanding
The Service Test is rated: Low Satisfactory
The major factors that support this rating include:
Good performance in LMI geographies and lending volume offset excellent performance to LMI borrowers and adequate community development lending.
Excellent responsiveness to the investment needs of the state based on the large volume of qualifying investments made during the evaluation period as well as prior periods.
Adequate access to bank branches and good level of community development services along with an adequate record of branch openings and closings.

Description of Institution's Operations in the State of Louisiana
The BONAI operates in eight MAs and eight non-metropolitan AAs. As of June 30, 2003, the bank had $9.1 billion of deposits in Louisiana, which represents 6.8% of the bank's total deposits. The bank operates 182 branches and 233 deposit-taking ATMs throughout the state. We selected the New Orleans MA for a full-scope review because it holds 38% of the bank's deposits within the state. The next largest MA is Baton Rouge with 27% of the bank's deposits in the state. Baton Rouge and the remaining MAs and combined non-metropolitan AAs were analyzed using limited-scope procedures.

Refer to the market profile for the New Orleans, LA MA in Appendix C for performance context information.

LENDING TEST
Lending performance in the New Orleans MA is good. Performance in the limited­scope areas did not impact the state's overall Lending Test rating.

Conclusions for Areas Receiving Full-Scope Reviews
Lending Activity - Lending activity in the New Orleans MA is good. The volume of refinance, home improvement, and small business lending is good. However, home purchase lending is adequate.
State of Louisiana
New Orleans PMA
The BONAI AA consists of the entire New Orleans MSA including Jefferson,
Orleans, Plaquemines, St. Bernard, St. Charles, St. James, St. John the Baptist,
and St. Tammany Parishes. The bank ranks second in the New Orleans geography with a deposit share of 18.93% on $3.5 billion as of June 30, 2003. Hibernia National Bank ranks first at 27.16% and Whitney National Bank ranks third at 17.33%. There are 39 FDIC insured institutions in the MA, but the market is fairly concentrated in the top 3.
The systemic problems of poverty and education, which are dominant throughout
the state, are most prevalent in New Orleans. In the Orleans Parish, nearly 28
percent of the population live in poverty, severely limiting lending opportunities.
The educational system has been a major factor in the state’s inability to attract
new and high-paying jobs. The median family income is $45,774 and 17.37% of
households are living below the poverty level.
The well-developed port, pipeline, and rail infrastructure, including strategic port
facilities for domestic and international trade are an area strength as is the strong
performance in leisure and convention-related tourism. A weakened dollar renders imports more expensive and hence weakens cargo growth and impinges job growth at the Port of New Orleans. The household bankruptcy rate remains higher than the national average, but has been flat of late. Boding well for future employment is the downward trend in business bankruptcies.
There is a significant shortage of affordable single-family housing units available in LMI tracts. The ‘water-locked’ limitations, aging housing stock, and the level of
deteriorated and abandoned properties compounds the shortfall. The housing
department estimates there are over 20,000 blighted and abandoned properties in Orleans Parish. The city is using the adjudication process to take back these
properties and donate them to non-profit organizations for rehabilitation into
affordable housing stock. This process is lengthy, taking from 18 to 36 months
per house to complete. Many of the houses in their current condition would not
meet the standards for any type of FHA, VA, or conventional loan program.
The need for public housing is great. Four public housing properties in New
Orleans have been deemed non-viable by federal standards. Since 2000, the
Louisiana Housing Finance Agency awarded 14 tax credit projects in the New
Orleans MSA.

State of Texas Rating
CRA Rating for the State: Outstanding
The Lending Test is rated: Outstanding
The Investment Test is rated: Outstanding
The Service Test is rated: Low Satisfactory

The major factors that support this rating include:
. Excellent community development lending, performance in LMI geographies, and performance to borrowers of different income levels improve good lending levels.
. Excellent responsiveness to the investment needs of the state based on the
volume of qualifying investments made during the evaluation period.
. Adequate access to deposit services supported by good level of community
development services and an adequate record of branch openings and
closings.

Description of Institution's Operations in the State of Texas
The BONAI operates in 16 MAs and four non-metropolitan AAs. As of June 30, 2003, the bank had $19.6 billion of deposits in Texas, which represents 14.7% of the bank's total deposits. The bank operates 234 branches and over 260 deposit­taking A TMs throughout the state. We selected the Dallas MA for a full-scope review because 39% of the bank's deposits within the state are concentrated in the Dallas MA. The next largest MA is Houston, which holds 22% of the bank's deposits in the state. Houston and the remaining MAs and combined non­metropolitan AAs were analyzed using limited-scope procedures.
Refer to the market profile for the Dallas, TX MA in Appendix C for performance context information.

LENDING TEST
Lending performance in the Dallas MA is excellent. Performance in the limited­scope areas did not impact the state's overall Lending Test rating.
Conclusions for Areas Receiving Full-Scope Reviews
Lending Activity - Lending activity in the Dallas MA is good. We noted an excellent volume of home improvement loans. The volume of refinance and small business lending is good. However, home purchase lending is poor.

State of Oklahoma Rating
CRA Rating for the State: Outstanding
The Lending Test is rated: Outstanding
The Investment Test is rated: Outstanding
The Service Test is rated: Low Satisfactory

The major factors that supportthis rating include:
. Excellent level of community development lending and performance to borrowers of different income levels strengthens a good level of lending activity and performance to geographies of different income levels.
. Excellent responsiveness to the investment needs of the state based on the
volume of qualifying investments made during the evaluation period.
. Adequate access to bank branches and level of community .development
services.

Description of Institution's Operations in the State of Oklahoma
BONAI has delineated two AAs in the state. As of June 30, 2003, the bank had $2.2 billion of deposits in Oklahoma, which represents 1.6% of the bank's total deposits. The bank operates 35 branches and 53 A TMs in the two AAs. We selected the Oklahoma City MA for a full-scope review because 70% of the bank's deposits within the state are concentrated in the Oklahoma City MA. The Tulsa MA was analyzed using limited-scope procedures.

Refer to the market profile for the Oklahoma City, OK MA in Appendix C for performance context information.

LENDING TEST
Lending performance in the Oklahoma City MA is excellent. Performance in the limited-scope area did not impact the state's overall Lending Test rating.

Conclusions for Areas Receiving Full-Scope Reviews
Lending Activity - Lending activity in the Oklahoma City MA is good. The volume of home improvement, refinance, and small business lending is good. However, home purchase lending was adequate.
Distribution of Loans by Income Level of the Geography - The distribution of loans. within geographies of different income levels is good. Home improvement lending in LMI geographies is excellent. Refinance and small business lending performance

State of Illinois Rating
CRA Rating for the State: Outstanding
The Lending Test is rated: Outstanding
The Investment Test is rated: Outstanding
The Service Test is rated: Low Satisfactory

The major factors that support this rating include:
. Excellent level of community development lending, performance in LMI geographies, and performance to LMI borrowers strengthen good lending activity.
. Excellent responsiveness to the state's investment needs based on the large
volume of qualifying investments made during the evaluation period.
. Adequate access to bank branches and level of community development
services.

Description of Institution's Operations in the State of Illinois
The BONAI has delineated seven AAs within the state. As of June 30, 2003, the bank had $44.8 billion of deposits in Illinois, which represents 34% of the bank's total deposits. The bank is one of the largest in Illinois, operating 254 branches and over 1000 deposit-taking A TMs throughout the state. We selected the Chicago PMA for a full-scope review because 94% of the bank's deposits within the state are concentrated there. The remaining six MAs were analyzed using limited-scope procedures.
Refer to the market profile for the Chicago PMA in Appendix Cfor performance context information.

LENDING TEST
Lending performance in the Chicago PMA is excellent. Performance in the limited­scope areas did not impact the state's overall Lending Test rating.
Conclusions for Areas Receiving Full-Scope Reviews

Lending Activity - Lending activity in the Chicago PMA is good. We noted a good volume of home improvement, refinance and small business loans, but home purchase lending is adequate.

Distribution of Loans by Income Level of the Geography - The distribution of loans to geographies of different income levels is excellent. We noted an excellent distribution of home purchase, home improvement and refinance lending.

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