STATEWIDE EMERGENCY NETWORK 

FOR SOCIAL AND ECONOMIC SECURITY 

275 State Street l Albany, N.Y. 12210-2101 l Telephone (518) 463-5576 Fax (518) 432-9073 

July 6, 1999 

Robert M. Brady 

Vice President 

Federal Reserve Bank of Boston 

P.O. Box 2076 

Boston, MA 02 106-2076 

Dear Mr. Brady, 

Below is my testimony on the Fleet Financial Group, BankBoston merger as presented at the 

public hearing on July 7”, 1999. I have also attached a proposal presented to Fleet at a local 

meeting and supporting documents showing HMDA and other analyses of Fleet’s lending in two 

areas of New York State -- the Capital District and Orange County. 

I am requesting that the comment period be extended for two weeks after the day on which Fleet 

makes it lending pledge available for public viewing and that the Federal Reserve Board hold off 

..I.-..r AL:- - ^__^_ ..-&:I CL:- _^I_.^^ c - on deciding ~UUULIUS 111e1ge1 uuiu LIIIS request iS iii& 

Public Hearing Testimony 

Good evening. I would like to thank the Federal Reserve Bank of Boston for holding this public 

hearing about the Fleet merger. My name is Vickie Hurewitz. I work for SENSES, a New York 

State organization, the acronym stands for the Statewide Emergency Network for Social and 

Economic Security. We advocate on a variety of issues that affect low-income New Yorkers, I 

work on community reinvestment matters for SENSES. I am here today to testify about Fleet’s 

lending in New York State, particularly our Capital District and Orange County , two areas where 

I have been very active in CRA work. On its last CRA exam Fleet got a Low Satisfactory on the 

lending and service tests in New York State. 

The Capital District of New York State is roughly a six county area, consisting of Albany, 

Schenectady, Rensselaer, Saratoga, Schoharie and Montgomery counties. Fleet Bank is the 

region’s largest with over $3 billion in deposits and it has branches in all Capital Districts 

counties. Within these counties are several declining central cities and pockets of rural poverty. 

Orange County is downstate, many residents commute to Manhattan to work, however the county 
has two distressed central cities, Newburgh and Middletown and Kiryas Joel, a Haisidic Jewish 

community in need of reinvestment. 

On Friday July 2, myself and representatives of 17 other community organizations met with Fleet 

representatives, including Mr. Hermes Ames, President of Fleet National Bank to discus Fleets’ 

lending in the Capital District. I am attaching to this testimony a proposal that was presented to 

Fleet and served as the focus of our Capital District meeting. 

Over the last several years, in New York State, Fleet has acquired two banks, Shawmut National 

Bank and Natwest. An analysis done by the National Community Reinvestment Coalition showed 

that in 1995, before the mergers, the three banks made over 8,000 home purchase loans. In 1997, 

after the mergers, Fleet made only 2,000 home purchase loans, a drop of 70%. In low-income 

comrzzunities around the state the drop was 76%. I had also done my own analysis of Fleet’s 1997 

home purchase lending in the Capital District and Orange County and found that the bank had 

extremely low market shares no matter whether the geography was the counties, the cities, or the 

distressed neighborhoods. This was not surprising given the findings for the state. 

Prior to our meeting with Fleet I had called Don Prusak of Fleet and asked him about obtaining 

the results of Fleet’s INCITY Program - the mega-pledge Fleet made when it acquired Shawmut 

in l995. He told me the results could be found in the HMDA data. When I related to him the 

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p”“‘ IGaluW “I LUG IYLJXL aua‘yaca 11cs aa1u ,,,a 5 a1 5 >“‘UG yl”“lum vT1LU U1”Jb I‘uII*“~AJ, J vu 

need to look at our 1998 HMDA data.” Subsequently he supplied me with the 1998 data for the 

Capital District counties and Orange County. 

During our meeting with Fleet we discussed Fleet’s home purchase lending. I had analyzed the 

1997 data and then Fleets’ 1998 data for Capital District counties, cities and distressed 

. . . neignborhoods. ‘Meanwhiie observers in the Capitai District had noted that Fieet has good 

affordable products, however the bank appears reluctant to use them and is not actively seeking 

applications. 

As I mentioned, in 1997, I found that Fleet had very low market shares for home purchase loans 

no matter the geography. By 1998 Fleets home purchase lending had increased by 115% in 

Albany County however the bank made no loans in the distressed neighborhoods in the City of 

Albany. In Rensselaer County the lending stayed flat, the bank made no loans in the City of Troy 

in either 1997 or 1998. In Schenectady County lending went down by 41%, although the dollar 

amount in the distressed neighborhoods went from $59,000 to $82,000, a small increase of small 

dollars. 

During our meeting Fleet related that there had been a problem with their mortgage origination 

department after the mergers -- 60 mortgage originators had left to form their own company. 

Fleet informed us that it had hired new originators, however when I mentioned that they had not 

penetrated the low-income neighborhoods in our region in 1998 they additionally informed us 

that they had recently reworked their commission structure so that each originator got a 

minimum of $500 per loan. We encouraged them to hire a non-commission “community service 

loan officer” like some of their competitors to outreach to community organizations and actively 

seek applications. 

1 h\plehnv thm,n nn;ntc ohcant hn-a ,..,,,.h.-ac.P lanAinn hooQaac,= thee- nrnhlm-nc T\PPIIS-TPC~ awhile Fleet I “b,Ia”“I LI,b.Db p”IIIca c%““UC 1,““‘~ yuIb.IaJb IcI‘IUL‘l~ “_UOJ” CllclJV pl”“IuLILa “VYUI‘WY ..II11V I .vvc 

had a megapledge in place, the INCITY program I mentioned. Fleet has currently offered 

another $14.6 billion pledge with very few specifics. I urge the Federal Reserve to ensure that 
this pledge be made locally specific and locally accountable so we can be certain that this new 

pledge does not go the way of INCITY. 

During our meeting we also spoke about home improvement lending, bank services and 

investments. A disturbing trend noted in all the distressed neighborhoods is that the depository 

institutions are leaving and the sub-prime lenders are arriving, not good news for low-income 

households. For example, in Arbor Hill a low-income neighborhood in Albany, Fleet made no 

home improvement loans in either 1997 or 1998. In 1997 the three largest lenders were Green 

Tree Financial, The Money Store, and United Companies Lending Corporation in this 

neighborhood. Fleet expressed concern about the quality of loans being offered by these subprimes and offered to explore setting up a home improvement pilot program with a local nonprofit. 

Fleet has recently decided to keep a branch open in a.low-income neighborhood that it had 

announced would close. During neighborhood meetings it was made clear that Fleet had not been 

actively offering New York State’s Basic Banking account to encourage the neighborhood 

residents to become a customer. Fleet said it would rectify the situation. 

A meeting in Orange County is pending. Fleet has $108 million on deposit in the City of 

Newburgh, a distressed community. In 1997 the bank only made $54.000 in HMDA reportable 

loans in this city, In Middletown the bank is cnnsiderahlv ___-_-__-__, smaller. ____-____, with $14 million in dennnits it ..-_-_ i_ . __________ --- -_= __--_ __ 

lent $110,000 in HMDA reportable dollars. I hope the pending meeting with Fleet can resuIt in 

much larger dollar amounts being lent and invested into into these communities. 

Fleet had an Outstanding on its investments in New York State. In our communities in there is a 

continuous and great need for investments, for non-profit operating expenses, for financial 

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alternative lending institutions. I hereby ask Fleet to be an active participant in these endeavors 

in New York and I ask the Federal Reserve Board to hold off on deciding this merger until we 

are assured that Fleet’s mega-pledge will truly be a mechanism for community reinvestment. To 

restate, we need a locally accountable pledge and we need time to review it to ensure that it meets 

the needs of our low-and moderate- income citizens. 

Thank you. 
INITIAL DRAFT PROPOSAL FOR FLEET NATIONAL BANK 

LENDING -JNVESTMENTSERVICES 

CAPITAL DISTRICT OF NEW YORK STATE 

INTRODUCTION 

Fleet Financial Group and Bank Boston, have announced they will be merging their institutions to form Fleet 

Boston which will become the eighth largest bank in the United States. The Community Reinvestment Act states 

that ,,,U& rPmllgt& ."~U.UbVU finanrial LI~ILI..".U. inctitldnnc ..W.L...~.".W have . . . ..w “rnntinr:ina ~""."'~"'b nnrl . . .._ nfTirmntive I~~....-...- nhlimtinnr.cl .,""D"--‘eLI, to he!n meet the credit needs of r ------ ---- 

the local communities, in which they are chartered, including low-and moderate income communities.” The law 

also states that banking regulators must take into account an institution’s performance under the CRA in 

considering an application to merge. Below are an analysis, and some comments on Fleet’s “CRA performance” 

in the Capital District of New York State. 

LEN-DING 

Home Purchase - New York State 

I-- _ _ -_..:__J I._._ L__,._ _..l_:_l_ I__1 l_____l___ Since i 9% Fieei Financiai Group nas acquirea two oanks wrucn niiu uraucnes in New YOik StZte, wnhrrM+ I*LIcwG3LuaLlA Daand Shawmut Bank. A Home Mortgage Disclosure Act (HMDA) analysis for all Fleet entities, NatWest, and 

Shawmut in New York showed that the three institutions made 1,146 home purchase loans in LMI census tracts in 

1995. In 1997, after the three institutions combined, this number had dropped to 268, a 77% decrease. The same 

pattern is found for all census tracts in the state, going from 8,069 for the three institutions in 1995, to 2,415 in 

1997 after the mergers, a drop of 70%. 

In 1998, Fleet National Bank received a Low Satisfactory on its lending test for New York State. During this same 

period (from 1995 to 1997) Fleet’s deposits in New York State increased 95%. 

Capital District 

1997 analyses of HMDA data for owner units for all Fleet entities in Albany, Schenectady and Rensselaer 

counties shows very low market shares for home purchase loans, 1.9%, 3.4% and 2.1% respectively. When 

compared to its fellow Capital District depositories the bank had significantly below average rankings for home 

purchase loan to deposit ratios in all three Capital District counties. : 

In low-income areas in these counties Fleet’s market share was uneven, in some cases non-existent. In others 

higher than for the county as a whole but still not over 3%. In most cases, the higher market shares were gained 

through applications taken by Fleet Mortgage Corporation. 

For non-owner unit’s small landlord unit applications, Fleet had a 4% market share in Albany County, an 11% 

share in Schenectady County, and a 5% share in Rensselaer. However, the bank took no applications in the City 

of Albany or the City of Troy. In the City of Schenectady the bank loaned $80,000 for non-owner home 

purchases. 

A comparison of Fleet National Bank’s owner home purchase lending in 1997 and 1998 showed that lending went 

._- I- * It ^^_. 0 ^.._ &. a-1 J_..._ ,:,:&- .,,,*I.. :, ~,.I.,,,,.c,A., . . ..*l. .,a..., 1:++1, ,.I, .3s-._P ;n l?~“~cPl~G.* ‘l-ha hgnt rlirl up Ill Alually LuullLy a,‘" uuwt‘slgluuLalI"L'y 11, 3LIIcIIcLcd"y WlC,, "my ,flllFi b11aup 111 I\bIWJ~,O~,. 1‘1" "c&I_ ULU 

no home purchase lending in the City of Troy, in Albany slightly more in 1997 than in 1998, and in the City of 

Schenectady somewhat less. The only target neighborhoods that saw any home purchase lending in 1998 from 

Fleet National Bank was the LMI Tracts in the City of Schenectady with 3 applications. 

General Observations 

Fleet has several affordable housing products available. Observers in the Capital District have noted that the bank 

does not actively seek applicants and seems reluctant to use the products. 
Observers in the Capital District have noted that Fleet’s turnaround time on mortgage applications (when they are 

submitted) is two or three months. This results in clients not being recommended to Fleet for loans. 

Fleet Mortgage Corporation is selling its loans into the secondary market, as do all mortgage corporations. 

Although the secondary market provides an important source of capital for lending, flexibility of loan products 

can be limited by the required underwriting criteria as can be seen by the chart in Appendix C. 

111 Tn lnw L”I,-*Linrnm~ ‘““L.IV U.vuY STP~C in II. the rstnitnl nictrirt R md C !&ers are taking a higher nronortion of applications than are . ..I ‘“r,....’ YY.. -1. I _--- D _ ___(3____ =. -= -. .._~~ 

the depository lenders for home purchase loans, especially non-owner applications. 

Home Purchase Recommendations for Fleet in the Capital District 

(These recommendation are intended to assist Fleet overcoming its lending weaknesses and improving its test 

__._ A-__. x,_.. “__.I_ or_*_ ___ r,__ _____4 8-23 1 ____, 

scvre JO’IYCW rorn 31Ult: ur1 LllB Ncu LnA c.wlrl) 

1. 

2. 

3. 

4.. Conduct home buying seminars in partnership with non-profits 

5. Low down payment program in non-CRA target areas 

6. Mixed use (residential and commercial) building financing 

7. Flexible credit scoring and underwriting criteria for potential low-income homeowners 

8. Fleet should market a small landlord homeowner product for the cities of Albany and Troy. 

9. Fleet should support our local IDA program. 

10. Fleet should continue its ongoing support of the Affordable Housing Partnership. 

11. Fleet should support community-based housing groups. 

Fleet should affirmatively market its home purchase products in the Capital District. 

Fleet should hire dedicated community loan offtcers and partner with community groups to generate 

applications and institute home purchase counseling. 

Establish a Purchase/Repair Program as many properties in low-income neighborhoods are in need of 

remodeling 

Home Imwovement - Capital Did&t 

In Albany, Schenectady, and Rensselaer Fleet had considerably higher market shares of applications for owner 

home improvement loans than it did for home purchase applications, 8.2%, 9.5% and 8.0% in these counties, 

respectively. The bank was below average on loan to deposit rankings in Albany and Schenectady counties and at 

the ton r in _- Rensselaer. -___________ 

In the central cities of these counties the market shares were lower than in the counties and a breakout of lowincome target areas showed even lower shares. Only the bank, not the Mortgage Company, took home 

improvement applications. 

In the City of Albany target neighborhoods, Fleet only originated $16,000 dollars in home improvement dollars. 

In Schenectady and Rensselaer target neighborhoods the bank had low market shares but at least did some 

lending, $114,000 in Schenectady (check City number) and 134,000 in Rensselaer. 

Fleet had good market shares for non-owner Home Improvement applications for the counties, cities, and even 

target areas in the Capital District. However, the banks denial rates were extremely high in all these markets 

ranging from 100% in the City of Albany to 63% in Albany County. In the City of Albany the bank did not 

originate any loans in spite of a 19% market share of applications, nor did it make any loans in the City of Troy. 

in Schenectady the bank denied 75% of the appiications and oniy did $8,000 in iending for smaii iandiord home 

improvement. 

A comparison of Fleet National Bank’s owner home improvement lending in 1997 and 1998 showed that lending 

stayed the same in Schenectady, dropped somewhat in Rensselear and took a huge decline in Albany. Home 

Improvement lending went up in the cities of Schenectady and Troy and dropped sharply in Albany. In the target 
neighborhoods lending dropped sharply in the LMI tracts in Schenectady, went up somewhat in Troy and up in the 

Capitol Hill, South End and West Hill neighborhoods in Albany. Arbor Hill saw no home improvement loans in 

either year. 

General Observations 

A HUD list of Title One FHA Home Improvement lenders revealed that the vast majority of participants in the 

program were the B and C lenders. 

D,.4l. .-l,..,-.,:+,,, l.O”L‘. nn A Gnonnn ,.r\mr\Q”;nc .aVP t.?t;nn n,l,nPt hnww imnmwvnent annliratinnc in the three U”Ill ucp”3lr”ly “01Ln3 auu lllllll,clcI ~“IIIpaII‘K. a,- run‘,,~ ““,I”. ll”lllV 11I.y.“. V.A.“.LC ‘yy”v....““’ -1. -..- -1.. -- 

Capital District Service cities and their target areas, although Green Tree financial took the most applications in 

the cities of Schenectady and Troy. For non-owner loans the situation is similar. 

Average home improvement prices range from $16,545 to $11,133 in the target neighborhoods. These may be 

somewhat higher than might be needed by LMI households. 

Home Improvement Recommendations for Fleet in the Capital District 

(These recommendation are intended to assist Fieet overcoming its iending weaknesses and improving its tesi 

score for New York State on the next CRA exam) 

1. No minimum home improvement loans. 

2. Refinance and repair program for properties in low-income neighborhoods. 

3. Non-Owner (small landlord) home improvement loans, explore with community groups ways to offset risk of 

these loans. 

4.Explore becoming a Title One home improvement lender - finance companies are taking full advantage of this 

program. 

Refinance - Capital District 

In Albany, Schenectady and Rensselaer counties Fleet had considerably higher market shares for owner home 

refinance loans than it did for home purchase applications, 8.4%, 9.8% and 5.8% in these counties, respectively. 

When compared to its fellow depositories the bank was below average in Albany and Schenectady counties and 

close to the middle in Rensselaer. Fleet Mortgage Corporation also took some Refinance applicattons. 

In the target areas of Albany and Rensselaer counties the bank did some lending although market shares were 

lower than in the county as a whole. The bank took 2 owner refinance applications in the target area of 

Schenectady, both of which were denied. 

Fleet did no non-owner refinance lending in the City of Albany or Schenectady County and originated one 

application in the City of Troy. The Mortgage Corporation originated very few applications. 

A comparison of Fleet National Bank’s owner refinance lending in 1997 and 1998 showed that lending stayed the 

same in Schenectady, went up slightly in Rensslaer and down somewhat in Albany. In the cities lending went 

down slightly in Schenectady, up in Troy and down somewhat in Albany. The target areas of Schenectady and 

Troy saw increases and only Arbor Hill in Albany saw an increase. The bank made no refinance loans in the 

South End in either year. 

General Observations 

B and C lenders are extremely active in the target areas of the Capital District for Refinance loans. 

Fleet has a streamlined FHA refinance program but local observers report that the bank seems reluctant to use it. 

Refinance Recommendations for Fleet in the Capital District 

(These recommendation are intended to assist Fleet overcoming its lending weaknesses and improving its test 

score for New York State on the next CRA exam) 
1. Provide trained bank staff to assist borrowers and community group representatives in obtaining refinance 

loans. 

2. Institute first mortgage refinance program to prevent foreclosures. 

3. Refinance and repair program for properties in low-income neighborhoods as many are saddled with 

burdensome debt. 

Business Lendinp -Capital District 

Fleet has lower market shares in low- and moderate-income census tracts in Albany and Rensselaer counties than 

it does in middle and high-income tracts. In Schenectady the bank had a higher market share in middle and highincome tracts. 

General Observations 

Throughout the Capital District there is an ongoing critical need for technical, monetary, and mentoring assistance 

for low-income entreprenuers. Graduates of micro-enterprise programs cannot get appointments to meet with loan 

officers at local banks. 

Business Lending Recommendations for Fleet in the Capital District 

1. Provide operating support for small-business technical assistance providers, intermediary lenders and microenterprise deveiopers in the Capitai District. 

2. Provide low-cost capital to intermediary lenders. 

3. Make business loans more user friendly - quick turnaround times, reduce paperwork and have flexible 

underwriting criteria. 

4. Support for formal business training programs and individualized technical assistance. 

5. Support local IDA programs. 

SERVICES 

New York State 

Fleet received a Low-Satisfactory rating on its CRA exam for New York State. Twenty-two percent of its 

branches are located in low- and moderateincome areas of the state. 

Capital D&t&t 

Fleet recently agreed to keep a bank branch open in a low-and moderateincome area in the City of Albany that it 

had already announced would close. The bank has asked for community input to help it increase the branch’s 

deposit and business base. 

Low-income areas of Albany and Schenectady are under-served by current bank branching structures. 

Observers have noted that Fleet does not appear interested in the small consumer and fees are way too excessive 

for low-income citizens. 

Service Recommendations for Fleet in the Capital District 

1. Promote New York State’s basic banking account at all branches. 

2. Offer free checking like your competitors in the region. 

3. Keep the Scotland Avenue branch opened indefinitely. 
4. 

5. 

6. 

Partner with community groups and do focus groups to determine the credit needs and perceptions about 

Fleet of low-income people. 

Explore the development of new branches, partner with local municipalities and form a banking 

development district. 

Support alternative financial institutions in the Capital District. 

New York State 

Fleet received an Outstanding on its CRA exam for New York State. According to the exam Fleet invested $11 

million in the state. 

Some specific investments are: 

Purchase of $3 10,OO of stock in a statewide business development corporation 

I- LIP. XT---~ x,. I_ cl ..,I n.._:____ T,__L.__ P.._J Supports me I\ ew r ark 3mau LIusiness v emure r unu 

$10,000 to Leviticus Fund 

$25,000 to Westhab 

Fleet Micro-Enterprise Development Center - Urban League of Northeastern New York, $75,000 

Schenectady Community Action Program - $100,000 

Center City Neighborhood Development Corporation - $5,000 

General Observations 

Fleet is generous with local groups in giving grants, however observers have noted that the grant process is 

complicated. Non-profits have on-going needs for operating support and in-kind technical assistance. 

Investment Recommendations for Fleet in the Capital District 

Partner with local non-profits for on-going credit counseling, foreclosure prevention, and landlord training for 

low-income citizens. 

Establish a pool of funds for community revitalization projects that will be accessed through an application 

process and tie in with ongoing local efforts. 

Establish a foundation using stock dividends from mergers for funding and make the funds available for 

community development lending. 

Simplify your application process to obtain grants. 

Support and help grow local business incubators. 

Fleet Financial Group 

Owner I-4 

1997-1998 Comparison Fleet National Bank 

$ $ % Change 

Loaned Loaned 1997- 

Schenectady 1997 1998 1998 

Schenectady County $ 

Schenectady City $ 

LMI Tracts -Schenectady City $ 

‘il” .~,,~~-,~~-~,~~~*?~~*~~~~~~.~~~~,~~~ *i- d -+,y, 5 _‘_ %,A._. L /\“” ir,r: #$,:<;T;- 4 

~~‘~~~~;a~r,~.~~~...~~~-~~;.~~.~ ;:. “,.C,_.“-L>~~._c.se_ ., 

Rennselaer Coun 

53,000 $ - 

60,000 #DIV/O! 

60,000 #DIV/O! 

Albany County $ 8,368,OOO $ 6,153,OOO -26% 

Albany City $ 931,000 $ 709,000 -24% 

Capitol Hill $ 125,000 $ 116,000 -7% 

South End $ 

Arbor Hill $ 100,000 #DIV/O! 

West Hill $ 250,000 $ 125,000 -50% 
- .._ ..-,-__ r. . .._.. _,____. 

--.__. 

_ 

.~ ._., 
-. . __...-,-._.. ___ 

1999 7 16:24 202-628-9800 

*i .lJ 

NCRC PAGE 0:: 

NCRC Analy8is - State of New York 

Fleet Lending Before and After Mergers 

Home Purchase Lading 

% Chg. 95 %Chg. 

lo97 86 86-87 

Loans to All Borrowers 

%Chg. % of Total % of Total 

95-97 1995 1996 

2,415 -24.1% -36.2% -51.6% 62.0% 88.1% 

0 -82.9% -100.0% -100.0% 37.2% 11.9% 

0 -1 oo.oo/, N/A -100.0% 0.9% 0.0% 

2,415 -46.6% -43.8% m 100.0% 100.0% 

Loans to Blacks 

1995 1996 

Fleet 4,994 3,788 

NatWest 2,995 512 

Shawmut 70 0 

T0tZd 8,059 4,300 

Fteet 716 393 227 -45.1% -42.2% -68.3% 82.0% 91.2% 

NatWest 153 38 0 -75.2% -7 00.0% -100.0% 17.5% 8.8% 

Shawmirt 4 0 0 -100.0% N/A -100.0% 0.5% 0.0% 

Total 873 431 227 -50.6% -47.3% -74.0% 100.0% 100.0% 

Loans to Hispanics 

Fleet 363 224 127 -38.3% -43.3% . -65.0% 77.70% 93.9% 

NatWest 101 15 0 -85.1% -100.0% -100.0% 21.6% 6.3% 

Shawmut 3 0 0 -100.0% N/A -100.0% 0.6% 0.0% 

Total 467 239 127 -48.8% -46.9% -72,8% 100.0% 100.0% 

Loans to Lbw- and Moderate-Income Borrowers 

Fleet 1358 1019 803 -25.0% -40.8% -55.6% 02.5% 94.1% 

NatWest 270 64 0 -76.3% -100.0% -100.0% 16.4% 5.9% 

Shawmut 18. 0 0 -100.0% N/A -100.0% l.q% 0.0% 

Total 1,646 1.083 603 -34.2% -44.3% -63.4% 100.0% 100.0% 

Loans to Substantially-Minority Census Tracts 

00.2% 91.3% 

19.7% 8.7% 

0.1% 0.0% 

100.0% 100.0% 

Fleet 695 432 244 -37.8% -43.5% -64.9% 

Natwest 171 41 0 -70.0% -100.0% -lOO.O% 

Shawmut I 0 0 -100.0% N/A -100.0% 

Total 867 473 244 -45.4% -48.4% -71.9% 

Loans to Low- and Moderate-Income Census Tracts 

Fleet 964 

NatWest 171 

Shawmut 11 

Total 1,146 

603 268 -37.4% -55.6% -72.2% 

30 0 -62.5% -100.0% -7 00.0% 

84.1% 95.3% 

14.9% 4.7% 

1 .O% 0.0% 

100.0% 100.0% 

0 

633 

0 -100.0% N/A -100.0% 

268 -44.8% -57.7% 
v (litvl 16.5 nnn I 

nl I 01 I I I 

01 N/AI $ I 01 N/AI $ 

South End] 

Arbor Hill1 

WO 

Y I 

$ - I 

Alban, -, , 7n9 nnn I 13OLl Q 

. -..,--- -- 

Capitol Hill1 31 0%) $ 116,000 1 41 --%a+-- 

h Fnrll 21 innokl z I II nw.l Q sollt. I L. .U 

Arbor Hill 

West Hill 

; 

m-w,” 7 

0 

“I” v 

50% !§ 100,000 0% $ 

3 0% $ 125,000 5 40% $ 218,000 

I 

Fleet Total Dollars Loaned 

Albany County 

Albany City 

P-m:brrl u:II 

10,858,OOO 

1 ,I 92,000 

4 I7iz nrrn 

..GUC n1111, v m..rT,““” 

Albany County Deposits= 3,167,089,000 

Loan to Deposit Ratio (County) 0.34 
Fleet Financial Group 

Market Share Analysis - Owner 1-4IHome Lending 1997 

Albany Neighborhoods 

Fleet Total Dollars Loaned 

Albany County 

Albany City 

Capitol Hill 

South End 

Arbor Hill 

West Hill 

Albany County Deposits= $2,256,635,000 

$ 17,785,OOO 

$ 4,300,000 

178,000 

: - 

_ 

: 319,000 
Fleet National Bank 

Lending indicators For Albany County 

Owner Housing 

% Market Share Non-LMI HH 

arket Share UDDer Income Tracts 
Market Share Analysis / Non-Owner 1-44Home Lending 1997 

Albany Geographies 

Fleet Total Non-Owner Lending 

Albany County 

Albany City 

Capital Hill 

South End 

Arbor Hill 

West Hill 

Albany County Deposits = $2,256,635,000 

$ 694,000 

$ - 

$ - 

$ - 

$ - 

$ - 
Fleet Financial Group 

Market Share Analvsis - Owner 1_4/Home Lendina 1998 

Rennselaer County 

Fleet Total Dollars Loaned 

Rennselaer County 

Troy City 

TRIP Service Area 

$ 4,394,ooo 

$ 560,000 

$ 310.000 

I 

Rennselaer Countv Deuosits =I 

Loan to Deposit Ratio (County)/ 
0-p $ (&unoD) o!~eu I!sodaa 01 ueol 

ooo‘ooo‘sob $ 

0OO’~SZ $ 

OOO‘ZLE $ 

ooo‘bs1‘P $ 

fm %O %I’0 1 000‘6 11 $ %pP %O’Z 6 

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18OP 1%6Z %L’l L 

= qsodaa bun03 Jaelasuuau 

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L661 Gu!pual auroH/p-C Jaumo - s!sr(leuy aJeqs JayJew 

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Market Share Analysis I Non-owner 14Home Lending 1997 

Rensselaer Geographies 

Rennselaer Coun 

Fleet Total Non-Owner Lending 

Rennselaer County $ 500,000 

Troy City $ 35,000 

TRIP Service Area 8 35,000 

Rennselaer County Deposits $ 105,000,000 
Fleet National Bank 

Lending Indicators For Rensselaer County - 1997 

% Market Share LMI HH 1.3 

% Market Share Non-LMI HH 0.2 

% Market Share Black HH 0 

% Market Share LMI HH 7.6 

% Market Share Non-LMI HH 7.3 

% Market Share Black HH 0 

% Market Share Middle Income Tracts 
Fleet Financial Group 

Market Share Analysis - Owner 1-4IHome Lending 1998 

Schenectady Neighborhoods 

Fleet Total Lending 

Schenectady County 8 5,445,850 $1,789,000 

Schenectady City $ 744,000 $ 389,000 

LMI Tracts -Schenectady City $ 161,000 $ - 

Fleet Deposits- Schenectady County = N/A for 1998 
Fleet National Bank 

Lending Indicators by Geography 

1 Schenectadyl 

% Market Share White HH 

% Market Share Low-Income Tracts 25% 

% Market Share Moderate income Tracts 11% 

% Market Share Middle Income Tracts 16% 

% Market Share Upper Income Tracts 16% 

36 

3A 
Market Share Analysis I Non-Owner IllHome Lending 1997 

Schenectady Geographies 

Neet National 

Bank 

# of Market % $ Total 

Schenectady County 5 16.1% 80% 

Schenectady City 4 26.7% 75% 

LMI Tracts Schenectadv Citv 1 16.7% 0% 

Schenectady County 

Schenectady City 

LMI Tracts Schenectadv Citv 

2 1.9% 100% 

1 1.4% 100% 

1 2.8% 100% 

Fleet Total Non-Owner Lending 

Schenectady County 

Schenectady City 

LMI Tracts -Schenectady City 

I 

$ 559,000 

$ 88,000 

$ 52,000 

Fleet Deposits Schenectady County = $639,000,000 
Fleet Findings for Orange County 

l-4 Owner 

Amlications 

Largest market share in Home Improvement, Refinance Applications of all loan types. 

Home Improvement, Refinance market share lower in Middletown then in Orange County 

Market share among LMI HH for Home Improvement and Refinance loans comparable to NonLMI HH 

Market share among Black HH for Home Improvement and Refinance loans lower than among 

White HH 

Denials 

Fleet’s denial rates for Home Improvement and Refinance loans much higher than the County rate 

All Home Improvement applications denied in Newburgh 

Most Home Improvement applications denied in Middletown 

Loan to Deposit Ratio 

Fleet taking very few Home Purchase applications 

Non Owner l-4 

Applications 

Fleet has a higher market share among Non-Owners than Owners for Home Purchase applications 

Home Purchase applications are being denied at a slightly higher rate than the County rate 

Fleet took no applications for Home Purchase, Home Improvement or Refinance loans from 

Middletown or Newburgh cities for Non-Owner loans. 

Denials 

Fleet denied all Home Improvement applications for the County 

Business Lending 

Fleet had a higher market share in low-income census tracts than other tracts 

Community Development Lending 

Fleet ranks 3 out of 9 in the Community Development to Asset ratio, giving back 7 tenths of a cent 

on the dollar. 

Community Needs 

Better marketing of Home Improvement and Refinance loans among Black borrowers 

Better marketing of Home Improvement and Refinance loans in Middletown 

Marketing-OK in Newburgh 

Find a way to close Owner Home Improvement loans in Middletown and Newburgh 

Find a way to get Home Improvement and Refinance loans to Non-Owners in Orange County 

Housing Counseling needs 

Foreclosure Prevention 

Fleet National Bank 

Lending Indicators For Orange County - 1997 

‘., /., ,;7 ;’ .; :.Orange 

Home Purchase .’ ‘: .:’ .~C&&y 

Loan to DeDosit Ratio Rank 18of21 

% MarkLt Share LMI HH 

% Market Share Non-LMI HH 

% Market Share Black HH 

0.9 

0.2 

0 

% Market Share LMI HH 11 

% Market Share Non-LMI HH 8 

% Market Share Black HH 5.5 

% Market Share White HH 8.7 ;‘; ;,y-;; ,y . ,,.-; .A-- ; ,.I 1 

..‘_ ,I ,‘:‘:. 

. ...>.& a.<..:..I ‘. .,.. i_ 

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I.“AL_,sP., ._,_ &_?.. y.,?_i.&d,, .>.r.A:,$&.* 

Loan to Deposit Ratio Rank 8of21 

% Market Share LMI HH 3.9 

% Market Share Non-LMI HH 3.7 

% Market Share Black HH 2 

% Market Share White HH 4.9 

,, /,. ‘. _-.-*.-x -_ . . - ;;-,-,‘_rr~,~: , ,” -y;> ,.,, _ w 

‘.i ,I .,. ;’ :~‘l~.,..~.;.~~.~.~i~,._;i \ ’~, ,,, Business &$%g ,:y;,,,_y;;:;.z,,; ,_ ; :;z:i,;:, 

% Market Share Low-Income Tracts 8.8 

% Market Share Moderate Income Tracts 5.5 

% Market Share Middle Income Tracts 5.9 

% Market Share UDDer Income Tracts 3.5 
Fleet Deposits 1995-1997 

Albany 

Allegany 

Bronx 

Cattaraugus 

Cayuga 

Chautauqua 

Chemung 

Clinton 

Columbia 

Cortland 

Dutchess 

Erie 

Essex 

Franklin 

Fulton 

Genesee 

Greene 

Herkimer 

Jefferson 

Kings 

Lewis 

Livingston 

Monroe 

Montgomery 

Nassau 

NewYork 

Niagara 

Oneida 

Onondaga 

Ontario 

Orange 

Orleans 

Oswego 

Otsego 

Queens 

Rensselaer 

Richmond 

Saratoga 

Schenectady 

Schoharie 

Schuyler 

Seneca 

St.Lawrence 

Steuben 

Suffolk 

Sullivan 

Tompkins 

Ulster 

Warren 

Wayne 

Westchester 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

1,618,011,000 $ 

134,366,OOO $ 

22,882,OOO $ 

144678,000 $ 

124,971,OOO $ 

173,860,OOO $ 

18,556,OOO $ 

60,833,OOO $ 

87,271,OOO $ 

11,079,000 $ 

39,900,000 $ 

1,083,123,000 !§ 

37,765,OOO !§ 

12,469,OOO $ 

33,664,OOO $ 

78,707,OOO $ 

41,408,OOO !§ 

157,226,OOO $ 

35,187,OOO !§ 

106,003,000 $ 

11,449,000 $ 

67,800,OOO $ 

628,147,OOO $ 

40,175,000 !§ 

711,232,OOO $ 

313,473,ooo $ 

273,364,OOO !§ 

507,492,OOO $ 

674,773,OOO $ 

61,156,OOO $ 

329,038,OOO $ 

49,200,OOO $ 

53,991,ooo $ 

21,608,000 $ 

80,210,OOO $ 

114,761,000 $ 

$ 

105,317,000 $ 

155009,000 $ 

21,187,OOO $ 

20,962,OOO $ 

40,996,OOO $ 

65,222,OOO $ 

109,225,OOO $ 

757,358,OOO $ 

156,829,OOO $ 

50,845,ooo $ 

195,075,000 $ 

52,735,OOO $ 

89,794,OOO $ 

$ 

49,339,ooo $ 

2,159,129,000 $ 

132,802,OOO $ 

259,496,OOO $ 

133,906,OOO $ 

167,405,OOO $ 

145,371,000 $ 

18,861,000 $ 

64,279,OOO !§ 

83,718,OOO $ 

10,666,000 !§ 

41,429,OOO $ 

1,090,915,000 $ 

38,988,OOO $ 

12,096,OOO $ 

21,769,OOO $ 

75058,000 $ 

40,743,ooo $ 

150,222,000 $ 

33,123,OOO $ 

384,252,OOO $ 

11,187,000 !§ 

70,299,OOO $ 

607,792,OOO $ 

122,529,OOO $ 

2,994,629,000 $ 

1,252,240,000 $ 

269,672,OOO $ 

462,477,OOO $ 

676,429,OOO $ 

55,086,OOO $ 

330,811,000 $ 

42,676,OOO !§ 

54,049,ooo $ 

19,563,OOO $ 

553,662,OOO $ 

117,701,000 $ 

87,421,OOO $ 

278,588,OOO $ 

734,032,OOO $ 

21,233,OOO $ 

20,622,OOO $ 

42,507,OOO $ 

63846,000 $ 

107,180,000 $ 

1,810,858,000 $ 

152,071,000 $ 

42,110,OOO $ 

188,315,OOO !§ 

96,814,OOO $ 

85,127,OOO $ 

1,296,492,000 $ 

46,762,OOO $ 

2,256,635,000 

124,810,000 

256,534,OOO 

135,196,OOO 

118,413,000 

129,869,OOO 

16,540,OOO 

84,914,ooo 

10,424,OOO 

42,354,OOO 

858,860,OOO 

11,007,000 

23,940,OOO 

72,176,OOO 

39,807,OOO 

142,079,OOO 

31,166,OOO 

340,700,000 

10,214,000 

71,630,OOO 

540,590,000 

101,913,000 

2,582,379,000 

1,134,340,000 

259,764,OOO 

429,306,OOO 

626,361,OOO 

54,322,OOO 

313,220,OOO 

44,405,ooo 

55,496,OOO 

17,488,OOO 

535,263,OOO 

105,515,000 

85,603,OOO 

241,444,OOO 

639,480,OOO 

17,699,OOO 

20,388,OOO 

43,955,ooo 

60,633,OOO 

109,027,OOO 

4,764,125,000 

148,529,OOO 

39,897,OOO 

192,680,OOO 

43,655,OOO 

75,577,ooo 

1,106,122,000 

45,532,OOO 

-1% 

1034% 

-7% 

34% 

-16% 

2% 

6% 

-4% 

4% 

4% 

1% 

3% 

-3% 

-35% 

-5% 

-2% 

-4% 

-6% 

262% 

-2% 

4% 

-3% 

205% 

321% 

299% 

-1% 

-9% 

0% 

-10% 

1% 

-13% 

0% 

-9% 

590% 

3% 

#DIV/O! 

165% 

374% 

0% 

-2% 

4% 

-2% 

-2% 

139% 

-3% 

-17% 

-3% 

84% 

-5% 

#DIV/O! 

-5% 

-7% 

1021% 

-7% 

-5% 

-25% 

-11% 

-100% 

-3% 

-6% 

6% 

-21% 

-100% 

-12% 

-29% 

-8% 

-4% 

-10% 

-11% 

221% 

-11% 

6% 

-14% 

154% 

263% 

262% 

-5% 

-15% 

-7% 

-11% 

-5% 

-10% 

3% 

-19% 

567% 

-8% 

#DIV/O! 

129% 

313% 

-16% 

-3% 

7% 

-7% 

0% 

529% 

-5% 

-22% 

-1% 

-17% 

-16% 

#DIV/O! 

Yates -8% 
Fleet Financial Group 

Market Share Analysis - Owner I-41 Home Lending 1997 

Orange Geographies 

Fleet National Fleet Mortgage Fleet 

Bank Application Financing Corporation Application Financing Bank 

# of Market % $ % % # of Market % % % # of Market 

Applications Share Denied Loaned Conventional FHA Applications Share Denied Conventional FHA Applications Share Den 

Home Purchase x .__.‘. ‘- ’ .__,, 

-. ,.___]. - ;~. ._. .j---’ :... 

., j,.. .__.. r .‘, ._, ^_ ;,. 

-. 

Orange County -. 16 0.4% 

.3iGo ,s 318201000 

‘100% 0% . -55 1.3% 11.0% 62% 38% 1 b% IO 

City of Newburgh 0 0.0% N/A $ - 0% 0% 0 0% N/A 0% 0% 0 0% I 

City of Middletown 1 0.7% 100% $ - 100% 0% 0 0% N/A 0% 0% 0 0% F 

Kiryas Joel 0 0.0% N/A $ - 0% 0% 0 0% N/A 0% 0% 0 0% 1 

,. 

Home Improvement_,,-,- ’ _I_, _. -. ,,- 

Orange County 158 9.9% 5& ‘$2,285,000 100% 0% .. 0 0% N/A 0% 0% 4 0.1% I 

City of Newburgh 3 8.1% 100% $ - 100% 0% 0 0% N/A 0% 0% 0 0% I 

City of Middletown 4 6.1% 75% $ 25,000 100% 0% 0 0% N/A 0% 0% 0 0% I 

Kiryas Joel 0 0.0% N/A !§ - 0% 0% 0 0% N/A 0% 0% 0 0% I 

Refi&$f.-:~~,: .: 1: 1.:. -- .‘y I. ‘~~~~~~:~;.. I;: ,_::]._;_._ III,i~i ,~::i;c~_;;.,,,I~~~~. ::‘{,;;.A f ,::_,-Ly_ :‘. 

:-Y,:..:-L :.- _::, -_‘.‘( ‘:,.,I_: ~- ::.s. -- ..:I’. -__; .,I : I ,;. -;;-I ._ _,__.: ,_:;r.- 

_ -, __),.,, : I,.- .t-,. -’ ,:,,_ ~-,~~_,:.~:“.: t~,,-~~i.~~, 

Orange County 

: ., . . 

224 5.3% 39% $5,784,000 ” . “;O(-,% (jyo .‘- ‘A ‘-- -.“ 22 

. :.. _c :_-.-..-_ _.... :, .- ..^ _.._. _.: +:> -_.- ;- ~.. 

0.5% 18% 

1oo% ..o% . . :- 1 ‘.5 c ,. . ..:.‘r’:. . . .^. 

0.1% 

4 

City of Newburgh 7 6.7% 57% $ 54,000 100% 0% 0 0.0% N/A 0% 0% 0 0.0% I 

City of Middletown 4 2.7% 50% $ 85,000 100% 0% 2 1.3% 50% 100% 0% 0 0.0% I 

Kiryas Joel 0 O.O%l N/A $ - 0% 0% 0 0.0% N/A 0% 0% 0 0.0% I 

Total Owner Fleet Home Lending 

City of Newburgh $ 54,000 

ICity of Middletown $ 110,000 

City of Newburgh - Fleet has $108,246)300 in deposits. 

City of Middletown - Fleet has $14,002,000 in deposits. 
Fleet Financial Group 

Market Share Analysis - Owner 1-44Home Lending 1997 

Schenectady Neighborhoods 

Schenectady County 

Schenectady City 

LMI Tracts -Schenectady City 

Schenectady County 

Schenectady City 

LMI Tracts -Schenectady City 

Schenectady County 

Schenectady City 

LMI Tracts -Schenectady City 

Fleet Total Lending 

Schenectady County 

Schenectady City 

LMI Tracts -Schenectady City 

32 4.0%1 47%1 $ 504,000 I 6 0.8%1 50%1 

$5,822,000 

$ 728,000 

$ 173,000 

Fleet Deposits- Schenectady County= $639,000,000 

.