Sunday, February 19, 2006
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
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.
(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.
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.
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.
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
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.
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.
# posted by walter @ 2:36 PM 
