August 27, 1998 

Alan Greenspan 

Chairman 

Federal Reserve System 

20th Street & C Street, NW 

Washington, DC 20551 

Alice M. Rivlin 

Vice Chairperson - Governor 

Roger W. Ferguson, Jr. 

Governor 

Edward M. Gramlich 

Governor 

Laurance H. Meyer 

Governor 

Robert deV. Frierson 

Associate Secretary of the Board 

WELJAFARGO/NORWESTMERGER: 

GREENLININGSTRONGLYSUPPORTSCRACOMMITMENT 

Dear Chairman Greenspan, Governors and Associate Secretary 

Mr. deV. Frierson: 

Greenlining Institute has been active in CRA protests since 

1981. We have carefully analyzed the new Wells Fargo CRA 

commitment of August 21, 1998 and have been auditing the 1995 Wells 

Fargo commitment since 1996. 

We strongly support this CRA commitment. Because we have 

criticized America’s largest CRA commitment and urged hearings 

(NationsBank/BofA), we thought it might be helpful for us to 

distinguish between the two pledges. 

1. Unlike NationsBank’s hollow pledge,’ this is an enforceable 

pledge. The key community groups involved in developing the 

pledge will meet with the CEO on a semi-annual basis and will 

be given all necessary data in advance. 

’ Greeting letter to Federal Reserve of July 28, 1998. 
Volume IX, Number 13 / Inside Mortgage Compliance / September 7, 1998 

$180 billion for small business lending; $115 billion 

for affordable housing; $30 billion for general consumer lending (general purpose loans, auto loans, 

home equity loans); and $25 billion in loans to 

community development corporations, CDFIs and 

urban and rural economic development programs. 

American Banker editor-in-chief Phil Roosevelt declined to comment. Cl 

Bank Retaliafes 

NationsBank has not taken criticism of its CRA 

policy lightly, the Greenlining Institute reveals. 

In an August 20 letter to member organizations, 

Greenliming officials reported NationsBank’s retaliation against the American Banker, a daily 

newspaper serving the financial services industry, 

for a commentary it published on August 4. 

Authors John Gamboa, executive director of the 

Greenlming Institute, and Mary Ann Mitchell, 

chairwoman of the National Black Business Council, criticized NationsBank’s $350 billion program 

for its vagueness and urged it to follow the example 

set by Washington,Mutual. Inc. 

The Seattle-based thrift’s acquisitions of American Savings Bank and Great Western Bank over the 

past two years have resulted in specific CRA commitments that have won the support of community 

groups. 

Greenlining officials said NationsBank President 

Kenneth Lewis reacted angrily to the article and 

ordered all of NationsBank’s approximately 250 

subscriptions to the American Banker to be cancelled. They refer to an August 4 note allegedly 

written by Lewis in which he essentially ordered the 

cancellation. 

Addressed to the “general bank management 

team,” the note read: “I do not know if all of you 

read the Comment entitled “NadonsBank Could 

Learn A Lesson from Wamu ‘* in the American 

Banker. If you did, I am sure you are as offended 

and angry as I am about an industry newspaper doing such a thing. Given that we are focused on expense savings, couldn’t we do without this newspaper? 

I obviously think the answer is ‘yes’ and, therefore, I am canceling my subscription.” the memo 

continues. “1 think we should cancel all other subscriptions in the General Bank, including the support units. Please let me know if you feel differently. If I don’t hear from you, I will assume you 

have taken the same action that I have.” 

The order was swiftly carried out, Greenlining 

officials said. 

Screidon said he has no knowledge of the letter. 
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Unlike NationsBank, the headquarters of the new bank (including its CEO) will 

be located in the primary geographical area served. 

Unlike NationsBank, this pledge is geographically specific. 

Unlike NationsBank, this pledge had very substantial and widespread community 

input (240 groups) before being finalized. 

Unlike NationsBank, this pledge is specific as to assisting the most underserved 

- for example, specific minority and low-income goals for business and home 

lending. 

Unlike NationsBank, the philanthropic investment commitments are oriented 

toward the underserved (“toward the barrio, not rhe ballet “) and represent a 

substantial percent of pre-tax income. 

Unlike NationsBank, (IRA-related commitments have been made for 

women/minority owned contracts to small inner-city businesses and for the 

diversity goals Chairman Greenspan so eloquently supported during his Jan 16, 

1998 diversity remarks on Wall Street. 

Unlike NationsBank, Wells has had a policy of not investing abroad and instead, 

investing in the inner-city (“Los Angeles, not Leningrad”). In contrast, see, for 

example, BofA’s 600 million dollars at-risk in Russia and 3.1 billion dollars atrisk in South Korea. 

Unlike NationsBank, Wells has had a long history of securing community input 

and meeting longterm CRA commitments. 

Please keep us informed if there is a public meeting and please put us on the list 

to receive all comments. 

Julie Williams, U.S. Comptroller of the Currency 

Karen Wegmam, Wells Fargo Bank 

Policy Director and 

General Counsel