Texas 

Community 

Reinvestment 

Coalition 

1300 Guadalupe. Se. 100 *Austin. TX 78701. 5121477-4431. f: 5121477~8934. email: campan@consumer.org 

THE EFFECT OF THE PROPOSED MERGER OF NATIONSBANK AND BANK 

OF AMERICA ON UNDERSERVED TEXAS COMMUNITIES 

bq 

Angelyque P. Campbell 

Coordinator 

Texas Community Reinvestment Coalition 

Austin, Texas 

Federal Reserve Bank of San Francisco 

Public Hearing on the NationsBank and Bank of America Merger Application 

San Francisco, California 

July 9, 1998 
Testimony of 

ANCELYQUE P. CAMPBELL 

COORDINATOR 

TEXAS COMMUNITY REINVESTMENT COALITION 

before the 

FEDERAL RESERVE BANK OF SAN FRANCISCO 

July 9, 1998 

Comments of Angelyque P. Campbell, Texas Community Reinvestment 

Coalition’, presented at the Federal Reserve Bank of San Francisco, Public Hearing on 

the NationsBank and Bank of America Merger Application, San Francisco, California, 

July 9, 1998. 

INTRODUCTION 

Thank you for the opportunity to appear today. I am Angelyque P. Campbell. I 

am from Texas and I represent the Texas Community Reinvestment Coalition. I come 

today on behalf of TCRC to discuss our concerns about the merger’s impact on low 

income consumers and persons of color in Texas. 

We believe our position in this merger is unique since NationsBank and Bank of 

America are two of our state’s largest financial institutions-NationsBank being the 

largest bank in Texas. If the merger is approved, the new bank will control an even larger 

share of the Texas market. 

As the only statewide community reinvestment group in Texas, TCRC‘s interest 

is ensuring the credit needs of local communities in Texas are not ignored. 

Unfortunately, our most recent HMDA study, “Access to the Drenm: Home Mortgage 

Lending in Texas,” shows NationsBank and Bank of America have problems lending to 

low income consumers and persons of color in Texas, If the merged bank is to lead the 

financial industry in community lending and investment as it asserts it will, then the 

Board should delay this merger for two reasons: 

. to address unresolved questions about the banks’ current performance, and 

. to require conditions prior to approval to assure that all communities’ credit needs are 

met. 
The new mega-bank needs to make firm, geographic- and income-specific 

commitments, and the regulators need to monitor and enforce those commitments in the 

following areas: 

No Branch Closings in Low Income Communities and Communities of Color. 

When Texas suffered from 40 percent of the nation’s bank failures in the 198Os, it 

was our low income neighborhoods who were affected most by bank closures. As banks 

moved out of the neighborhoods, higher-cost non-bank institutions moved in. It concerns 

our coalition that of the total number of NationsBank branch openings and closings that 

occurred in 1996, upper and middle income areas received 40 new branches, while low 

and moderate income areas only received 10. 

Improved Lending Performance to Persons of Color 

In Texas, African-American and Latin0 borrowers are two to three times as likely 

to be denied for a home loan by NationsBank than a White borrower. HMDA data also 

shows NationsBank loaned 86% of their dollars for home loans to white borrowers. In 

some Texas cities, the disparity is worse: 

In the Beaumont-Port Arthur MSA-two majority African-American citiesNationsBank made only four loans to black families. and only one of them in a black 

census tract. Yet, NationsBank holds 9 percent of the deposits in the Beaumont-Port 

Arthur MSA. 

In San Antonio, NationsBank holds 14.5 percent of all deposits in the city, while 

Bank of America controls another 5.5 percent. Yet, NationsBank made only 1.7 percent 

of San, Antonio’s home loans. 

In the Fort Worth-Arlington MSA-another majority African-American cityNationsBank made only two loans in a black census tract area, yet its depository share in 

the city is 15.1 percent. 

Development of Desirable, Affordable Housing Products 

The most recent HMDA data shows Bank of America disproportionately targets 

Texas low income consumers and persons of color with manufactured housing loans. 

The interest rates on these home loans ranged from 11.25 13.25 percent, substantially 

higher than the average 7 percent rate for 30-year conventional loans. Since Bank of 

America’s recent decision to sell its manufactured housing unit to Greenpoint this spring, 

Bank of America has not offered an alternative affordable housing plan which meets their 

community reinvestment obligation.. 
. 

We watch these changes in the banking industry with deep anxiety for the effects 

the mergers will have on our communities. Loss of competition, higher fees, and the 

erosion of CRA come to mind. Regulators cannot remain passive observers as the 

financial services landscape changes. The single most important step that must be taken 

in the wake of bank mergers is to increase accountability of lenders to our communities’ 

unmet banking and credit needs. We trust the Board will do what is necessary to ensure 

banks remain in compliance with our fair housing and lending laws and accountable to 

our credit needs. 
NationsBank’ 
The National Economic Development & Law Center 

2201 Broadway Suite 815 Oakland, California 94612-3024 

REMARKS FOR 

FEDERAL RESERVE HEARING 

0~ A’PPLICATION 0~ NATIONSBANK 

AND BANK OF AMERICA TO MERGE 

JULY 9,199s 

SAN FRANCISCO. CALIFORNIA 

. 

JAjXES W. HEAD 

PRESIDENT 

NATIONAL ECONOMIC DEVELOPMENT 

AND LAW CENTER 

Phone: 510/251-2600 Fax: 510/251-0600 

1 

HandsNet: HN0186 
Good Morning, my name is James W. Head, and I am President of the National 

Economic Development and Law Center, based in Oakland California. The Center is a 

national nonprofit, public interest community and economic development technical 

assistance provider. Our mission is to contribute to the abilities of low-income persons 

and communities to realize their fit11 potentials. We do this by assisting them in 

acquiring the tools to build their economic self-sufficiency -by accessing jobs, work 

skills, and vital support services like child care and family support. I am also the 

Chairman of the Economic Development Sub-Committee of the California Reinvestment 

Committee, and a’Board member of the California Economic Development Lending 

Initiative, as well as a former member and Chairman of the Consumer Advisory Council 

of the Federal Reserve. 

This week I received a call from a reporter with the American Banker newspaper in 

Washington, DC. He wanted to know why I was going to testify before you at this 

hearing. I found his question a little odd and so informed him. He explained that in 

light of the fact that opportunities to present written comments was available, and many 

had done so, what was to be accomplished by appearing and testifying in person. I 

responded to him that it is important for those making decisions in matters like these to 

attach faces and descriptive facts and antidotes to the issues to be decided. This gives 

context, and hopefully some grounding, to the issues to be decided. It is important for 

you to understand the unique issues facing California and other states that will be 

impacted by this merger. Your understanding should be influenced and shaped by the 

2 
information you here from myself and others who are working in communities that can 

be directly impacted, positively and negatively, by your decision regarding the merger. 

My remarks will not focus on whether this merger should or shouldn’t be approved. My 

remarks will focus on some key issues you should consider in coming to a decision about 

the merger. 

Because my time is limited, let me make three quick points, 

I. Loans to Minorities 

There is a continuing perception that minorities, especially blacks, are not able to 

get loans at banks in the same way as their white counterparts. While it has been 

very difficult to verify or dismiss this perception, anecdotal and survey information 

continue to support it. In a Wall Street Journal survey commissioned about four years 

ago, a public-opinion poll of several hundred black business owners found that being 

snubbed by banks is pretty much the norm An overwhelming 92% of black business 

owners said they had been turned down by banks while trying to finance their firms. 

Lack of collateral, a paucity of black lenders and loan offricers, and a public perception 

that blacks lack business acumen are among the major drags on capital flow to blackowned firms, according to the great majority of those surveyed. For all the complaints 

however, banks are where 73% of black-owned firms ultimately obtain capital, according 
to the survey. When asked what would be their preferred source or sources of capital, 

63% of the respondents indicated Banks. 

Does this mean that NationsBank and Bank of America are not lending equitably to all? 

While I cannot speak for NationsBank’s record of lending to minorities, my experience 

with Bank of America is that they have made great efforts, with success, to expand their 

lending to minorities. But if you here from others that this is an issue of concern, and 

you accept the fact that the general perception continues to exist, you should closely 

examine the records ofthese two institutions regarding minority lending, and should 

. 

determine whether merger increases their capacity to be responsive to minorities. 

H. Equity Capital For Start Up And Expansion Businesses 

In a presentation at a Community Reinvestment and Access to Credit meeting in 

Los Angeles in January, 1998, Chairman Alan Greenspan suggested that additional 

debt through loans might not be the most effective solution to meeting the needs of 

communities like South Central. He suggested that equity investments might prove 

more effective and key to immediate and long-term economic revival. For a number 

of years now, California advocates have been discussing and educating Bank of America 

staff on the need for loan products that provide equity or patient capital for new and 

expanding businesses. This need can serve the emerging nonprofit organizations that are 

developing successful for-profit businesses to bring jobs and goods to low income 

communities; the emerging entrepreneurs, like welfare recipients, youth, and skilled 
unemployed or underemployed workers that are identifying small business niches that 

can help them become economically self-sufficient; and emerging and expanding small 

businesses that are trying to continue the creation of employment and economic stability 

in low-income communities. Our discussions with Bank of America have been around 

strategies and mechanisms for developing loan products that will address the credit needs 

of these constituents, and will allow the Bank to make money. We hope that you will 

question NationsBank and Bank of America on their willingness and commitment to 

continue to work towards addressing this critical need. At the very least, we believe that 

the Ferged Bank should commit to being a leader in the development of loan products 

that provide the kind of patient capital needed, and that they will work with us and others 

to experiment and test these products in California and other states. This is cutting edge 

work, and it should not be abandoned or delayed because of the application for merger. 

IE Community Economic Development Initiative 

During the first quarter of 1998, Community economic development leaders and 

Bank of America staff collaborated to develop an innovative community economic 

development philanthropic initiative, titled “Readiness for the 21” Century”, to 

promote economic readiness for individuals, communities, and community based 

organizations. Targeting community-based organizations and groups in all of the states 

where the Bank has a retail presence, this initiative was designed to help organizations 

assist their constituents in qualifying for the loans covered by the Bank’s 1997-98 $140 

billion community lending goals, and addressing ways to help those constituents become 

5 
profitable customers for the Bank. This initiative was partly based on a realization that 

many individuals and communities are not yet in a position to access and benefit from the 

community lending goals set by Bank of America. Providing needed technical 

assistance, grant funding, and loan capital in the states and communities served by the 

Bank through a philanthropic initiative was seen as an effective way to move toward 

greater access. Doing so would also reinforce the Bank’s position as a leader in the area 

of Community Development and enhance its image in the communities it serves. 

Recently, NationsBank and Bank of America announced a new $350 billion, 10 year 

commitment to community development lending and investment in rural and urban 

markets. The question you should ask is should the new merged Bank honor the 

commitment of Bank of America to this initiative as a way to insure full access to this 

new commitment. If the answer is yes, you should strongly recommend, if not require, 

the merged Bank to commit to implementation of this previously agreed upon economic 

development initiative, as well as BofA’s Rural 2000 initiative, and in a manner and 

amount of funding equal to the new strength of the Bank and its new $350 billion 

community development commitment. 

As I conclude, let me return to where I began regarding the question of the American 

Banker reporter. I am convinced that it is important to communicate in person to you 

these issues of importance as you review what is before you. Some feel it will not have 

an impact. Others feel it is risky because I may offend the Banks and that may be 

remembered later. In business, as in life, you gain more by direct dialogue and debate 

than by indirect prose and avoidance. Imagine if we only had Dr. King’s “I have a 

6 
in Washington, or if President Kennedy’s promise of a man on the moon had been only 

an editorial in the Washington Post, rather than the inspired delivery we all have seen. 

Lastly, even in the face of advancing technology like the intemet, some of us are still 

more comfortable making our points in a face to face discussion with those responsible 

for making the final decision. That is why I am here today to speak to you, and why I 

hope you will create opportunities for us to have continued face to face discussions with 

NationsBank and Bank of America. 

Thank you for this opportunity 

7 
FEDERALRESERVE BANKOFSAN FRANCISCO 

~~~R~~~~~~~~~~~R~D~~~c~ NATio”S 

TESTIMONY OF: 

BANK 

-AL SMALL BUSINESS D ‘VELOPMENT CORP. 

SACRAMENTO BLACK CHAMBER OF COMF!ERCE 

GOOD MORNING, MY NAME IS CLARENCE WILLIAMS. I AM :-IERE ON BEHALF OF 

THE SACRAMENTO BLACKCHAMBER OF COMMERCE AND CALIFORNIACAPITAL 

SMALL BUSINESS DEVELOPMENT CORPORATION, IN AS FviUCH AS I SERVE IN 

THE CAPACITY OF PRESIDENT OF BOTH ORGANIZATIONS. IN ADDITION, FOR 

THE RECORD, I AM A FOUNDING AND CURRENT MEMBER OF THE BANK OF 

AMERICA COMMUNITY DEVELOPMENT BANK COMMUNITY ADVISORY BOARD. 

THE SACRAMENTO BLACK CHAMBER OF COMMERCE IS A 501(C)(6) 

MEMBERSHIP ORGANIZATION ESTABLISHED MORE THAN TWELVE YEARS AGO 

FOR THE PURPOSE OF MITIGATING AND ELIMINATING ARBITRARY AND 

DISCRIMINATORY BARRIERS WHICH PRECLUDE AFRICAN r<MERICAN OWNED 

BUSINESSES FROM FULLY PARTICIPATING IN THE MARKE T:jLACE. 

CALIFORNIA CAPITAL IS A NORTHERN CALIFORNIA BASED 501(C)(3) 

CORPORATION, UNDER CONTRACTS WITH THE STATE OF CAL!FORNIA, AND THE 

SACRAMENTO MUNICIPAL UTILITY DISTRICT TO PROVIDE GUARANTEES ON 

BANK LOANS TO SMALL BUSINESSES. IN ADDITION, WE ARE CONTRACTED 

WITH THE SOLANO COUNTY ORGANIZING COMMITTEE TO ADMINISTER A MICRO 

LOAN FUND, AND THE U.S. DEPARTMENT OF AGRICULTURE RURAL 

DEVELOPMENT TO ADMINISTER A RURAL INTERMEDIARY RELENDING PROGRAM 

IN SEVERAL SPARSELY POPULATED NORTHERN COUNTIES. 
TESTIMONY OF CLARENCE WILLIAMS 

PAGE TWO 

THE PURPOSE OF MY TESTIMONY IS TO SUPPORT THE CAUSE OF THE 

FEDERAL RESERVE BANK IN ITS CONTINUING OBLIGATIONS TO COMMUNITY 

DEVELOPMENT AND REVITALIZATION, AND TO EMPHASIZE; AS A CONDITION OF 

THE MERGER OF THESE TWO INSTITUTIONS, A SPECIFIC OVERALL WRITTEN 

COMMITMENT OF DOLLARS, PRODUCTS AND SERVICES MUST BE MADE FOR 

CALIFORNIA AND ITS RESPECTIVE REGIONS, WITH MY CONCERN FOCUSSING 

ON THE SACRAMENTO VALLEY. 

TO DATE, THESE INSTITUTIONS HAVE BEEN UNWILLING TO MAKE A SPECIFIC, 

WRITTEN COMMITMENT TO CALIFORNIA. WITHOUT SUCH A COMMITMENT, 

INNER CITY AND RURAL COMMUNITIES MUST RELY ON A “TRUST US 

COMMITMENT.” 

CONSEQUENTLY, WE ARE BEING ASKED TO ACQUIESCE TO THIS MERGER ON 

THE BASIS OF BLIND FAITH, WHILE THESE INSTITUTIONS ARE PROFIT 

MOTIVATED AND THEIR PRIMARY CONCERN IS RETURN ON INVESTMENT FOR 

SHAREHOLDERS. CREATING JOBS AND COMMUNITY REINVESTMENT IS NOT 

NECESSARILY PERCEIVED AS BEING IN THEIR ECONOMIC INTEREST. 

HOWEVER, OUR COMMUNITIES CANNOT REMAIN SILENT AND INERT AS THE 

NUMBER OF FINANCIAL INSTITUTIONS CONTINUE TO CONTRACT FROM AS 

MANY AS TWENTY FIVE THOUSAND TO A PROJECTED EIGHT, SIX OR FOUR 

THOUSAND. 
TESTIMONY OF CLARENCE WILLIAMS 

PAGE THREE 

THIS CONTRACTION AND THE DEBATE, THEREOF, SHOULD NOT BE RESTRICTED 

TO AN ANALYSIS THAT ONLY PURSUES SUCH GOALS AS INCREASED 

EFFICIENCY AND GLOBALCOMPETITIVENESS IF THEY ARE ATTHE EXPENSE OF 

INNER CITY AND RURAL COMMUNITIES. WE CANNOT ACCEPT COSTS SUCH AS 

INCREASED UNEMPLOYMENT AND DISINVESTMENT BEING SHIFTED FROM THE 

BALANCE SHEETS OF THE BANKS TO THE BACKS OF OUR COMMUNITIES. IF 

FINANCIAL INSTITUTIONS AND THEIR SHAREHOLDERS ARE THE BENEFICIARIES 

OF CON&LIDATION, THEN, OUR COMMUNITIES SHOULD ALSO REALIZE 

SUBSTANTIVE BENEFITS AND NOT ONLY BE REQUIRED TO ABSORB THE COSTS 

OF THIS PROPOSED CONSOLIDATION. 

FURTHERMORE, IT IS OBVIOUS THAT THESE FINANCIAL INSTITUTIONS VIEW 

‘NEGOTIATED WRITTEN COMMITMENTS” AS MITIGATION TO TRANSFERRED 

NEGATIVE COST IMPACTS RESULTING FROM CONSOLIDATION. IF ACCEPTED 

AS MITIGATION BY THE COMMUNITY, WE MUST ASSURE THAT THESE SCARCE 

DOLLARS AND RESOURCES ARE FIRMLY COMMITTED IN WRITING AND 

REINVESTED FOR THE PURPOSE OF COMMUNITY GROWTH, AND ITS 

SUSTAINABILITY. 

I AM CERTAIN THAT THE TESTIMONY AT THESE HEARINGS WILL IDENTIFY 

NUMEROUS AND SPECIFIC INSTANCES WHERE THE PRINCIPALS OF THIS 

MERGER HAVE BEEN UNWILLING TO SPECIFY, IN WRITING, THE COMMITMENTS 

NECESSARY FOR THE APPROVAL OF THIS APPLICATION. HOWEVER, I SHALL 

NOTE, FOR THE RECORD, THEIR FAILURE TO: 
TESTIMONY OF CLARENCE WILLIAMS 

PAGE THREE 

I 

THIS CONTRACTION AND THE DEBATE, THEREOF,SHOULD NOT BE RESTRICTED 

TO AN ANALYSIS THAT ONLY PURSUES SUCH GOALS AS INCREASED 

EFFICIENCY AND GLOBALCOMPETITIVENESS IF THEY ARE ATTHE EXPENSE OF 

INNER CITY AND RURAL COMMUNITIES. WE CANNOT ACCEPT COSTS SUCH AS 

INCREASED UNEMPLOYMENT AND DISINVESTMENT BEING SHIFTED FROM THE 

BALANCE SHEETS OF THE BANKS TO THE BACKS OF OUR COMMUNITIES. IF 

FINANCIAL INSTITUTIONS AND THEIR SHAREHOLDERS ARE THE BENEFICIARIES 

OF CONSbLIDATION, THEN, OUR COMMUNITIES SHOULD ALSO REALIZE 

SUBSTANTIVE BENEFITS AND NOT ONLY BE REQUIRED TO ABSORB THE COSTS 

OF THIS PROPOSED CONSOLIDATION. 

FURTHERMORE, IT IS OBVIOUS THAT THESE FINANCIAL INSTITUTIONS VIEW 

‘NEGOTIATED WRITTEN COMMITMENTS” AS MITIGATION TO TRANSFERRED 

NEGATIVE COST IMPACTS RESULTING FROM CONSOLIDATION. IF ACCEPTED 

AS MITIGATION BY THE COMMUNITY, WE MUST ASSURE THAT THESE SCARCE 

DOLLARS AND RESOURCES ARE FIRMLY COMMITTED IN WRITING AND 

REINVESTED FOR THE PURPOSE OF COMMUNITY GROWTH, AND ITS 

SUSTAINABILITY. 

I AM CERTAIN THAT THE TESTIMONY AT THESE HEARINGS WILL IDENTIFY 

NUMEROUS AND SPECIFIC INSTANCES WHERE THE PRINCIPALS OF THIS 

MERGER HAVE BEEN UNWILLING TO SPECIFY, IN WRITING, THE COMMITMENTS 

NECESSARY FOR THE APPROVAL OF THIS APPLICATION. HOWEVER, I SHALL 

NOTE, FOR THE RECORD, THEIR FAILURE TO: 
TESTIMONY OF CLARENCE WILLIAMS 

PAGE FOUR 

0 

0 

0 

0 

0 

0 

INCREASE BANK OF AMERICA’S 1997 $70 BILLION ALLOCATION TO 

CALIFORNIA; 

SUPPORT NON PROFITTECHNICALASSISTANCE PROVIDERS WHO ASSIST 

SMALL BUSINESS; 

MAKE EQUITY INVESTMENT IN CDCs AND SBICs; 

PROVIDE VENTURE CAPITAL TO MINORITY AND WOMEN OWNED 

BUSINESSES LOCATED IN DISTRESSED AREAS; 

PURCHASE AT LEAST 25% OF ITS GOODS AND SERVICES FROM MINORITY 

AND DISABLED OWNED BUSINESSES; AND 

MAKE A WRITTEN COMMITMENT MAINTAINING BANK OF AMERICA 

COMMUNITY DEVELOPMENT BANK AND ITS INSTITUTIONAL EXPERTISE 

WITH REGARD TO COMMUNITY REINVESTMENT. 

IN CLOSING, I AM AWARE OF THE FEDERAL RESERVE’S SPECIFIED AUTHORITY 

TO ENFORCE NEGOTIATED COMMITMENTS, NOTHING PRECLUDES THIS PANEL 

FROM VERIFYING WHETHER “AGREEMENTS” MADE BY THE PARTICIPANTS OF 

THIS MERGER REPRESENT EITHER BILLIONS OF DOLLARS OF SMOKE AND 

MIRRORS OR A SUBSTANTIVE COVENANT OF COMMITMENTS INVOLVING LONG 

TERM PARTNERSHIPS AND RELATIONSHIPS TO REVITALIZE AND SUSTAIN INNER 

CITY AND RURAL COMMUNITIES. 

THANK YOU FOR YOUR PATIENCE. 
TESTIMONY OF 

CARLOS RICHARDSON 

NEIGHBORHOODS FIRST ALLIANCE (SAN ANTONIO, TX) 

at 

PUBLIC MEETING ON NATIONSBANK AND BANKAMERICA 

FEDERAL RESERVE BANK OF SAN FRANCISCO 

JULY 9, 1998 

1) Written testimony 

2) Analysis of NationsBank HMDA for 1997 

3) Map of redlined census tracts 

4) Letter of support from Mario Marcel Salas, San Antonio City Council, District 2 
Based on the 1997 HMDA data it is reflected that has redlined the eastern San Antonio 

community. There were three loans made in our neighborhood. One loan was made to 

Hispanic ror $14,000, another Lo an African American ror $21,000 and an undisclosed~ 

ethnic group for 626,000. 

NationsBank began negotiations with Neighborhoods First Alliance with the statement “we 

do not sign agrccmcnts with neighborhood groups.” This is a clear demonstration of its lack 

of will in making a commitment. 

NationsBank also refused toi agree to any measurable goals or time tables to rectify the 

problems, thus refusing to be held accountable for ita performance. 

Due to such it~&tu~onal policies as redhning, the eastern sector is economically depraved. 

The neighborhood is populated by the elderly and working poor and has not been a 

participant, in the economical growth of the SMSA. The area is be,aieged by warehouse 

encroachment, tank farms, and hazardous waste. 

The lacli of mortgage lending is destroying the residential nature of the neighborhood and 

encourages the type of investment that destroys the living environment and ultimately the 

neighborhood itself 

After Neighborhoods First Alliance requested Nationsbank’s HYMD,A data, an executive of 

the bank discovered one of the organizations was funded by the United Way. 

The executive called United way and the leader invoked was immediately put on job 

probation. This attempt to cripple our neighborhood leadership demonstrates this 

corporation’s arrogance and willingness to use its power to step on poor communities. 
m 

0 

CITY OF SAN ANTONIO 

MARIO SALAS 

COUNCILMAN 

DISTRICT 2 

July 7, 1998 

Ms. Jcnnifcr Johnson 

Secretary, Board of Governors 

Federal Reserve System 

2O”Street and Constitution Ave., N..W. 

Dear Members of the Board of Governors: ‘1 

As the Councilperson representing San Antonio’s District 2, I submit this letter to 

protest the application filed by NationsBank Corporation of Charlotte, North Carolina to merge 

with the Bank of America of San Francisco, Caliiomia. District 2 is located in East San Antonio 

and is home for much of San Antonio’s African American community. 

According to a community group in my District, the Neighborhoods First Alliance, the 

1997 Home Mortgage Disclosure Act data for NationsBank’s operations in San Antonio shows a 

ve’y poor record of meeting the credit needs of San Antonio’s minority and low-income 

communities. In all of Bexar County, NationsBank made a total of only three loans for the 

purchase of an owner-occupied home to African Americans. To put it bluntly. NationsBank’s 

lending record in San Antonio‘s African American community is shameful. 

NationsBank’s claim that they are serving the communities in which they are chartered to 

do business is clearly false. Allowing the proposed merger with Bank of America will make an 

already bad situation worse by shifting decision making authority and financial resotirces farther 

away from the people al&ted. 

This concerns me because access to credit is crucial to restoring the integrity of District 

2’s neighborhoods. Without credit, homeownership decliies. And without homeowners with a stake 

in its well being, a community suffers encroachment by industries looking for areas lacking the 

political will to keep them out. For too long my district has been singled out as a toxic dumping 

ground, a Mecca for environmental outlaws such as Aztec Ceramics. This terrible legacy is but one 

of the consequences of NationsBank’s redlining. East San Antonio cannot heal itself without 

support for the community-based strategies advocated by groups such as the Neighborhoods First 

Alliance. 

Given their lack of responsiveness and their history of redlining and discrimination, I ask 

the Board of Governors to deny NationsBank and Bank of America’s application to merge, or at 

least remove the application from expedited processing so the Board may more fully investigate 

NationsBank’s compliance with the Community Reinvestment Act. 

Mario Marcel Salas 

San Antonio City Council, District 2 

MAILING: 

PO. BOX 639966 

SAN ANTONIO. TEXAS 78263-3966 

CITY OF SAN ANTONIO. TEXAS 

CITY HALL (210) 207-7040 

FAX (210) 207.7027 
July 8, 1998 

STATEMENT OF LEO AVILA 

(AMERICAN G.I. FORUM) 

. 

The American G.I. Forum is our nation’s most prominent and largest Hispanic 

veteran’s organization. 

We oppose any merger that fails to ensure that the Latin0 community, a 

community that put America first in every war, fully and specifically benefits 

from this merger. We want home loans. We want business loans. And we want 

the banks to move their charitable dollars from the ballet to the barrio. 

Until there are specific commitments, we say to Chairmen Coulter, McCall and 

Greenspanf“No Merger”. Remember the Latin0 community is the future for 

California and any bank that operates here. 
July 8, 1998 

STATEMENT OF STEVE SOT0 

(PRESIDENT AND CEO, THE MEXICAN AMERICAN GROCERS 

ASSOCIATION) 

Our association’s success (over 7,000 members) is a harbinger of the future of 

this state. We can once again be a Golden State if banks tap all of California’s 

minority resources, much as Wells Fargo is attempting to do. 

The BofA/Nations pledge fails to tap this potential. The result is likely to be a 

lack of lending and economic development funds. We urge you and the banks to 

develop specific minority lending and contract goals. Until that is done, our 

support can not be secured and the new bank will not achieve its profit goals. 

Our association also protests the lack of hearings in Southern California. 
July 7, 1998 

STATEMENT OF CEO AND PRESIDENT OF PHOENIX URBAN LEAGUE 

(GEORGE DEAN) 

The Phoenix Urban League has had a very good relationship with the BofA. 

However, we must, no matter what the risk, set forth our cbncems. 

First, NationsBank may not be as sensitive to the unique minority cultures in Arizona; 

Second, all the major banks in the West have recognized the multi-billion dollar 

potential of minority markets and set specific goals. Nations refuses to do so. We 

ask why? 

Third, although community groups appreciate grants, it should be noted that as a 

percentage of profits, the record of the new banks is only half that of its competitors, 

such as Well Fargo. 

Fourth, this merger should be modified to require specific minority lending and 

contract goals and a substantial charitable commitment to underserved communities. 
STATEMENT OF MARK WHITLOCK 

(EXECUTIVE DIRECTOR OF ECONOMIC DEVELOPMENT, FIRST AME 

CHURCH) 

. 

As the Executive Director of a major inner city African-American churchoperated economics development program with 16,000 family constituents, I 

have grave misgivings about absentee landlords. Our community has suffered 

from generations of absentee landlord neglect. 

Second, when all of a bank’s competitors make specific minority pledges, one 

has to wonder as to the motives of the one who refuses. 

Third, many members of our church would like to testify but can not when 

hearings are held only in San Francisco. Please put on an L.A. hearing as we 

previously requested. 

Fourth, the African American market nationwide is over $600 billion dollars. 

Those who ignore us do so at their peril. 

We come to the table not with a beg, but with a desire to create a civil and 

prosperous society. 
July 8, 1998 

STATEMENT OF WILLIS WHITE 

(CALIFORNIA BLACK CHAMBER OF COMMERCE) 

I join with the National Black Chamber, the Black Business Association and the 

National Black Business Council in criticizing a merger that abandons the 

African American community. 

We have never shared in either bank’s loan pool or contract program, nor in 

Golden Parachutes for senior, white males worth over $200 million dollars. Nor 

have we equitably shared in their economic development projects. Consider 

this: BofA alone lent more to South Korea ($3.1 billion dollars) than the total it 

has lent to African American-owned businesses over the last 50 years. And 

remember, BofA has lost $3.1 billion in Korea and nothing in the inner city. 

Until they “show us the money” and “walk the talk” we will criticize this 

merger. 
July 7, 1998 

STATEMENT OF MATE0 CAMARILLO 

(VICE CHAIR, CHICANO FEDERATION OF SAN DIEGO) 

No bank mega-mergers should occur without specific minority and geographical 

pledges. In San Diego, over 40 percent of our county are minorities and the majority of 

potential homeowners and small business entrepreneurs !+re persons of color. 

We in San Diego urge CEO McCall to visit us and pledge that the new bank will set 

specific minority lending and business goals just like WAMU, Well Fargo and Union 

Bank 

7 

~ &2/i_cOrn?~. 

Unless this is done, competition may decide the financial fate of this merger. Why 

should 80 million minorities with a GNP of over one trillion dollars do business with a 

bank that ignores us, when Wells and WAMU court us? 
July 7, 1998 

STATEMENT OF MAI CONG, CEO 

(VIETNAMESE COMMUNITY OF ORANGE COUNTY, INC.) 

The Vietnamese American community has been inadequately served by BofA’s small 

business lending and fears that an absentee landlord with little knowledge of our 

culture will do even worse. Frankly, only targeted minority marketing and goals, as 

recently set by BofA’s competitors such as Union Bank, can correct this lack of capital 

to an emerging U.S. market far greater than many overseas markets. 

On behalf of Orange County’s 160,000 Vietnamese-Americans, I wish to deliver a 

personal message to Chairman Greenspan with whom I recently met. Don’t forsake us; 

compel NationsBank to set specific minority goals for small business lending and 

continuity and to promote people from our community into senior management. 
July 8, 1998 

STATEMENT OF BERT CORONA 

(EXECUTIVE DIRECTOR, HERMANDAD MEXICANA NACIONAL) 

I offer thistestimony on behalf of the nation’s largest immigrant service center 

and advocacy institution, We have offices in Washington, D.C., New York and 

Illinois, as well as in California. I have been an active advocate for minority 

empowerment and economic justice and development since FDR was first 

elected President. 

This merger could be harmful to all communities. It is particularly so for lowincome, immigrant and minority communities, Over the last six decades, we 

have witnessed the dangers of absentee landlords and those that view the poor 

from afar. 

I refuse to testify so that my personal absence is evidence against Chairman 

Greenspan’s decision to prevent low-income persons from voicing their 

concerns, unless they live in the San Francisco area or have a “rich uncle” bank 

to fund their trip. 

In summary, we oppose the merger unless the new bank sets specific community 

and minority lending goals and commits to a low-income philanthropic 

investment program that rivals that of Wells Fargo or Union Bank. It is not 

enough for top executives to draw eight figure salaries while doling out crumbs 

to the community. 

I also question the safety and soundness of a bank which lacks the confidence of 

persons of color. We constitute two-thirds of Los Angeles County’s population, 

a population greater than that of North Carolina. 
July 8, 1998 

STATEMENT OF BERT CORONA 

(EXECUTIVE DIRECTOR, HERMANDAD MEXICANA NACIONAL) 

I offer thistestimony on behalf of the nation’s largest immigrant service center 

and advocacy institution. We have offices in Washington, DC., New York and 

Illinois, as well as in California. I have been an active advocate for minority 

empowerment and economic justice and development since FDR was first 

elected President. 

This merger could be harmful to all communities. It is particularly so for lowincome, immigrant and minority communities. Over the last six decades, we 

have witnessed the dangers of absentee landlords and those that view the poor 

from afar. 

I refuse to testify so that my personal absence is evidence against Chairman 

Greenspan’s decision to prevent low-income persons from voicing their 

concerns, unless they live in the San Francisco area or have a “rich uncle” bank 

to fund their trip. 

In summary, we oppose the merger unless the new bank sets specific community 

and minority lending goals and commits to a low-income philanthropic 

investment program that rivals that of Wells Fargo or Union Bank. It is not 

enough for top executives to draw eight figure salaries while doling out crumbs 

to the community. 

I also question the safety and soundness of a bank which lacks the confidence of 

persons of color. We constitute two-thirds of Los Angeles County’s population, 

a population greater than that of North Carolina. 
July 8, 1998 

STATEMENT OF BERT CORONA 

(EXECUTIVE DIRECTOR, HERMANDAD MEXICANA NACIONAL) 

I offer thistestimony on behalf of the nation’s largest immigrant service center 

and advocacy institution. We have offices in Washington, D.C., New York and 

Illinois, as well as in California. I have been an active advocate for minority 

empowerment and economic justice and development since FDR was first 

elected President. 

This merger could be harmful to all communities. It is particularly so for lowincome, immigrant and minority communities. Over the last six decades, we 

have witnessed the dangers of absentee landlords and those that view the poor 

from afar. 

I refuse to testify so that my personal absence is evidence against Chairman 

Greenspan’s decision to prevent low-income persons from voicing their 

concerns, unless they live in the San Francisco area or have a “rich uncle” bank 

to fund their trip. 

In summary, we oppose the merger unless the new bank sets specific community 

and minority lending goals and commits to a low-income philanthropic 

investment program that rivals that of Wells Fargo or Union Bank. It is not 

enough for top executives to draw eight figure salaries while doling out crumbs 

to the community. 

I also question the safety and soundness of a bank which lacks the confidence of 

persons of color. We constitute two-thirds of Los Angeles County’s population, 

a population greater than that of North Carolina. 
:<a The East F&on Street Grow 

July 6,1998 

STATEMENT OF Zlbt CXNTURY PARTNERSHIP 

(Rev. James H. Daniel, Jr. Chairman /CEO) 

The 21st Century Partnership is a non-profit community 

develoymenl corpuration concerned with many issues pertaining to 

community development here on the east Coast. Among them is 

the changing face of the financial services industry. We as 

ministers and servank to the community believe that mega-mergers 

must create concrete resuits for the traditionally underserved. 

NationsBank’s CRA record is of concern. Ik lack of specific 

commitmenk to those who led the struggle for economic justice,as 

represented by Martin L&hut Kin&Jr, is appalling. 

We, as African American ministers, call on Hugh McCall to 

heed a higher call that is consistent with corporate growth: “Let they 

among you that would be great first be a servant to them all” . 

And,we, serving in the interest and voicing the concerns of 

millions of African Americans, decry the Federal Reserve’s Board of 

Governors refusal to grant us a hearing in each state in which 

NationsBank and BOFA. have failed to render adequate financial 

xx-vices to the un and undexbanked aurung us. 

has prevented us from personally testifying. 
~~ _~ ___ _. ____ -- -~ ~~, - 

The East Fulton Street Group 

July 6,199s 

STA'IEMEN'T OF 2ltst CENTURY PARTNERSHIP 

(Rev. James H. Daniel, Jr. Chairman /CEO) 

The 21st Century Partnership is a non-profit community 

developmenl corpuration concerned with many issues pertaining to 

community development here on the east Coast. Among them is 

the changing face of the financial services industry. We as 

ministers and servants to the community believe that mega-mergers 

must create concrete results for the traditionally underserved. 

NationsBank’s CRA record is of concern. Its lack of specific 

commitments to those who led the struggle for economic justice,as 

reptinted by Martin Lutbur Kin&Jr, is appalling. 

We, an A)riran American ministers, call on Hugh McCall to 

heed a higher call that is consistent with corporate growth: “Let they 

among you that would be great first be a servant to them all”. 

And,we, serving in the interest and voicing the concerns of 

millions of African Americans, decry the Federal Reserve’s Roard of 

Governors refusal to grant us a hearing in each state in which 

NationsBank and BOFA. have failed to render adequate financial 

services to the ran and underbanked among us. 

f funds has prevented us from personally testifying. I/“““\ 
~~ _~ __- -, ____ -- -. .._, -,. 

The East Fulton Street Group J 

July 61998 

STATEMENT OF 2ltd CENTURY PARTNERSHIP 

(Rev. James H. Daniel, Jr. Chairman /CEO) 

The 21st Century Partnership is a non-profit community 

development corpuratiun concerned with many issues pertaining to 

community development here on the east Coast. Among them is 

the changing face of the finanfial services industry. We as 

ministers and servants to the community believe that mega-mergers 

must create concrete results for the traditionally underserved. 

NationsBank’s CRA record is of concern. Its lack of specific 

commitments to those who led the struggle for economic justice,as 

repn?sented by Marlin Luthur King,Jr, is appalling. 

We, an Afriran American ministers, call on Hugh McCall to 

heed a higher ,call that is consistent with corporate growth: “Let they 

among you that would be great first be a servant to them all”. 

And,we, serving in the interest and voicing the concerns of 

millions of African Americans, decry the Federal Reserve’s Board of 

Governors refusal to grant us a hearing in each state in which 

NationsBank and BOFA,have failed to render adequate financial 

services to the un and underbardced among us. 

I-/P@=%, f funds has prevented us from personally testifying.