w:Re@. ,BARBARA I-El? :~ ‘~ ‘; 7-~7-98 ; 8:06Ad .: Rep. Barbar~acLee- 510 ‘ail aa%;* u 0 

BARA LEE 

’ 

uer.cluau 

Testimony Submitted by Barbara Lee, Member of Congress, to the 

Bederd Reserve Board Mectlng on the Merger of the 

BankAmerlca wltb Nations Bank San Fmncisco, Julv 9.1998 

Prestding OffPcer Smith and Other Panelists: 

Thank you for providing this opportunity to me and to my representative, Ma. 

Rchrta BMO~S, to addrese the issue of the merger of the BankAmerica with 

Nations Bank. I very much regret not being here pemumlly to talk to you but I nnly 

leaqed about thlt tnr+ng aakkntally and could not rearrange my tie&h. 

The flmt Iswe I will rake in the regulatory role of the Federal Resemc Board 

relative to the ability or these two banks to merge. Congreaa, thmugh the 1956 Bank 

Holdhg Company Act, gave the Federal Reserve Sy~&.m the responsibility to rcvicw 

mcb mergera and to spesitlcally consider the likely efEcts oP the acquisition on 

competition, and the convwhnce and needs- of the community to be served. Due to 

the inc- g number of mergh in the 1950’S, Congrrs reinforced the 1956 act by 

passing the Bank Merger Act in 1960. 

The Bank Merger &t Strengthened the language of the Federal Resave Board’s 

responsibity. II et&ted that the Federal Reserve may not approve any merger tint 

amld subetantlally redace cqpelition. It aleo was concerned that a merger not 

create a monopoly lmlesr It flu& that the antIcompetitIve effects of the transaction 
BY:Rep. ,&dtBARA iwI?E ; 7- 7-98 ; 8:08PM : Rep. ~Barbara Lee-+, 510~~763.&%38:# a/ 8 

are outwe4ghed by ;the tramactIon’s prubablq beneficial sftecb relplrding the 

amvenlence and n&da of the wmnulxlttytll~~ 

TheneoctLssueIwlshtoeddressisthat~the$eoleoithebanksthatars~. 

The plnmled merger of -cn with NotionsBank would make It the second 

bugeat bank in the U.S., with assets of $580 bllllon, Tbla merpor must be placed in 

the~context not of a slng;le event, but aa the fhat of a serlea uf announo& planned 

mergers: CIticorpPa $72 bINon merger with Travelor~ Corp., and First Chicago 

Carp’s !Wt bin deal with Bane One Corp. Another merger wtth Mar 

@t&once to Callfornln ad Bankiimericn, that OF California Wells Fargo with 

Norwest Corp. The con&idaUon of Wells P with Norwest Carp will make it 

the seve~~th hqpt bank tn the natton, with 

F 

&of$l!MbJnkm. 

This lerlds me to my third point. Given the gulatory responsihLUtie~ of the Federal 

i 

aeeerveSystemandfhegizeoPtheb~rmderconslderation,Iwoulderpect,as 

many of my constituents and eolfeagues on the House Bank$tg Co&ttee do, that 

the Federal Reserve would consider this merger with appropriata gravity. One 

mm of the eeriousuess of the l%deral Reserve would be Its willlngne~n to listen 

and the respect it @I give to the testimony from people who would be affe&d by 

mlchsmexger. * 

1lvraetherefore~rfelngtoleernthatonlgrmaeenaion~tobeheld,oaasingie 

day, in all of Californta. You have undo&t&y tival a great volume of mail on 

thclnrbjcct of your wWngnesa to listen. I understand that aa a consequence of the 

extent of the mail, we the public, now have tie days instead of the ortghd dngle 

day. I run the risk of statlug tb obvious thai a two-day heartng in one part of 

California on the loss of the largest bank iu California ia totally inadequate and, at 

the rtsk of being rude by being clear, unacceptable b&&or from a @vernment 

agencY* 

. 

2 
;t3T BY:Rep. BARIUM LEE ; 7- 7-98 ; 8:OWN ; ; Rep.. Barbara Lee-~ Jl” ,cm DJJO,R 4, 0 

My colleagues on the House Banking Gxnmlttee, Cungresmomen Ludlle RoybalAllard, and Maxine Waters, representing constliuents ln Southern Calllomia, share 

my concern with the negligible time that is being &en by the Federal Reserve to the 

public and to elected representatives to hold the appropriate discourse on this 

merger. Although 1 am pleased that my representative did not hnve to travel to IXIR 

Angeles to voice our concerns, I am dkxnayed that 80 serious a matter should be 

@en so little attention. This Is a merger that affects the entlm natlon, just as 

M.icrosoIt’s practices affect tbe entire nation. I strongly recommend that the 

Federal Reserve hold which either BankAmerica or 

NationsBank hold assets of $1 klon or mo 

I ask that a letter signed by myself, Represen tlve Roybal-AUard and Waters, to 

Hugh McCall, and David Coulter, Chairman 

and CEO of Bank of America be accepted as art 01 my testimony. 

We need heariogm in which to consider the almost countless number of anticipated 

problems that will arise from consolidation of these two banldng giants. Among the 

anticipated pmhlems are these: 

LOSS ol service. There Is great anxiety expressed by my constituents over the steady 

decline, in the Last twenty years or so, of banking servlccs and the accompanying 

tare for even the simplest servhs, such aa using the ATM. The pattern of less 

service and more cost Is so dear as to make this proposed merger a crisis polnt. By 

delegation from Congress, the Federal Reserve System has the respomlbility for 

responding to their concerns. How are you executing this responsibUlty? 

Loss of jobs. How many jobs will bc lost wh& BankAmerica moves from the Bay 

Area to North Carolina? Job holders, famlllea, the public must bc told. 

R-96% 
&T BY.:Rep. BARBARA LEE ; 7- 8-98 ; 3:mw ; Rep. Barbara Lee- CllU /tiJ tiwa;ff 21 z 

Community Development, and Reinvestment BankAmerica’s raeord of eommunlty 

Lnveatmeut is better than Nations. But BaukAmeriea is leavhlg cldiforrda. What 

will the more dominaut NationsBank do for their Cdifomia depositors? 

Corporate b~vestments in the African American aud the Latiuo eomnumiUest The 

most reliable Agures that we can get are dhmaL African Amerhxms are 12 perceut 

of the population. ‘Majority~wned banks lend to Black-owned businesses at a ram 

that is one-half of qne perceut (05) of theii total business loans. The Latino 

Amerii anumuuity receives about one tenth of one percent (.Ol) of the loam by 

majority banks. 

III mnclusion, I want to express my most profound concern that the Federal Reserve 

System, at thin time, respond appropriately to the public’s need for full, open 

hearings and discussion of this merger as the fhwt, of a series of expected met-gets. 

We Americans are quick to criticize Lbe banking methods uf Japan, China, 

Indonesia, and rightly so. Each one of these countries has powerful banks that 

practice in the dark, under the cover of a powerfnl combination of government and 

business. I fear that more Americans are realizing that although we may have the 

Porms of democracy, we have ltttle access to our country’s power+ The figures are 

stark It is hard to ignore the fact that the top one percent of this country owns 40% 

of the wealth or, put another way, the top 20% of the country owns 80% of the 

wealth. The leverage of accessibility is obviously on the side of those with 

overwhelming wealth. 

I trust that the Federal Roseme remembers its birth in this republic and that its true 

loyaltiea will be with the people. 

Thank you. 
zi%’ BY:Rep. BARBARA LEE ; -I- 8-98 ; 3:46t’M ; Rep. Barbara Lee- JIU m:J 63Ju;R 2, z 

Commnntty Devxlopmen~ and ReInvestment BankAmerica’s record of cummunlty 

investment is better than Nations. But BankAmarica is leaving CaBfonda. What 

will the more dominant NationsBank do for their CMfornb~ depositors? 

Corporate investments in the African American and the Latino commnniUex The 

most reliable fignrw that we can get are dismal African Americaas ma I2 perceat 

OP the populntlon. ‘Mnjoritp.wncd banks lend to Black-owned busincssaP at a rate 

that is onehalf of qne percent (0.5) of theii total business loans. The Latin0 

American aunmunity receives about one tenth of one percent (.Ol) of the loam by 

majority banks. 

In mnclusion, I want to express my most profound concern that the Federal Reserve 

System, at this time, respond apprupriately to the poblic’s need for full, open 

hearingt and discussion of this merger as the East, of a series of expected mergers. 

We American8 are quick to criticize the banking methoda or Japan, China, 

Indonesia, and rightly so. Each one of these countries has powerful hanks thal 

practice in the dark, nnder the cover of a powerful combination of government and 

business. I fear that more Americans are realizing that although we may have the 

Porms of democracy, we have little access to our country’s power. The figures are 

stxk_ It i-s hard to ignore the fact that the top one percent of this country owm 40% 

of the wealth or, put another way, the top 20% of the country owns 80% of the 

wealth. The leverage of accessibility is obvioixsly on the side of those with 

overwhelming wealth. 

I trust that the Federal IRwrve remembers its birth in this republic and that its true 

loyaltie will be with the people. 

Thank you. 
FILE No. 887 07/06 ‘98 11:14 ID: 

LUCILLE ROYRAL-ALLARD 

33RD DISTRICT. CALIFORNIA 

July 7. 1998 I 

Hugh McCall 

Chairman and Chief Executive Officer 

NationsBank / 

901 West Trade Street 

Charlotte, North Carolina 26202 

Dear Mr. McCall: 

As a member of the Banking Committee and Chair of the California Democratic 

Congressional Delegation, I am writing to express my concern with the proposed 

merger of Bank of America and NationsBank. I am especially concerned about its 

impact on lending, investing, employment and other financial services for low-income 

and minority Californians. 

This merger will no doubt have a greater impact on California than any other state in the 

country. The relocation of the headquarters of California’s largest financial institution to 

North Carolina particularly concerns me and the merger activity that has occurred in 

California to date reinforces this concern. 

In California alone, more than 60 banks and thrifts have been acquired by other 

institutions since 1996. In 1992, when Bank of America purchased Security Pacific 

Bank. they closed over 400 branches. In 1996, Wells Fargo closed hundreds of 

branches throughout the state after purchasing First Interstate Bank. While we cannot 

fully anticipate the long-term effects of these and future mergers, the obvious and 

immediate impact has been fewer branches and escalating bank fees. 

I commend Bank of America for its prior and current community reinvestment 

commitments to our California communities. Bank of America’s pledge of $140 billion 

over the next 10 years should be applauded, as well as NationsBank and Bank of 

America’s recent announcement of an unprecedented $350 billion commitment to lowincome communities. 

However, I would appreciate receiving details on how this pledge will benefit California’s 

consumers and communities. In requesting this information, I would respectfully point 

out that these specific requests are not unprecedented. and reflect commitments that 

other California institutions have made in the past. Therefore, I am confident that 

NationsBank and Bank of America will continue their good faith efforts to meet the 

needs of our California communities, 
Fl,LE No. 887 07/06 ‘98 11:14 ID: 

Specifically, I would appreciate your response to the following questions: 

1) Does the bank intend to earmark a portion of the 8350 billion to California? 

Given Bank of America’s dominance in California, it is critical that the community 

reinvestment commitment be California-specific and commensurate with the 

proportion of the Bank’s deposits and activities originating in the state. 

2) How will the institution fulfill regional commitments within California given the 

geographical, social and ethnic diversity or our communities? What culturallyappropriate products and services will be available to consumers, considering the 

various credit, investment and economic development needs of our state’s 

communities? 

3) How will the new bank maintain and expand Bank of America’s present programs 

and commitments in California, such as the Community Development Bank, Rural 

2000 Initiative. Economic Development Initiative, the BankAmerica Foundation, and 

affordable housing activities? It is vital that these programs be distinct entities within 

the merged bank and continue to be based in California, given the tremendous need 

in our state and the collective expertise Bank of America has acquired in serving our 

communities. 

4) What will be the bank’s specific goals on the type and amount of loans for 

minority or women-owned small businesses and home loans? 

5) How will the new bank minimize branch closings and increase branch openings 

in regions and communities that are presently underserved by traditional banking 

institutions? 

6) Does the new bank intend to lower or stabilize ATM and bank fees? I am very 

concerned about rising bank fees, and their adverse impact on financially 

underserved. low-income communities. 

A dedicated commitment to California is an exciting and challenging opportunity for 

banks. This merger has the potential to create mutually beneficial outcomes for both 

consumers and banks given California’s ever-growing, entrepreneurial immigrant 

communities, expanding small-business market, and booming economy. 

I look forward to working with you to meet these above-mentioned goals and anticipate 

your prompt reply. 

Sincerely, 

Member of Congress 
, F&E No. 88'/ U//W 'Y8 ll:l> IU: 

LUCILLE ROYBAL-ALLARD 

33RD DISTRICT. CALIFORNIA 

July 7. 1998 

David Coulter 

Chairman and Chief Executive Officer 

Bank of America 

555 California Street 

San Francisco, CA 94104 

Dear Mr. Coulter: - 

As a member of the Banking Committee and Chair of the California Democratic 

Congressional Delegation, I am writing to express my concern with the proposed 

merger of Bank of America and NationsBank. I am especially concerned about its 

impact on lending, investing, employment and other financial services for low-income 

and minority Californians 

This merger will no doubt have a greater impact on California than any other state in the 

country. The relocation of the headquarters of California’s largest financial institution to 

North Carolina particularly concerns me and the merger activity that has occurred in 

California to date reinforces this concern. 

In California alone, more than 80 banks and thrifts have been acquired by other 

institutions since 1996. In 1992, when Bank of America purchased Security Pacific 

Bank, they closed over 400 branches. In 1996, Wells Fargo closed hundreds of 

branches throughout the state after purchasing First Interstate Bank. While we cannot 

fully anticipate the long-term effects of these and future mergers, the obvious and 

immediate impact has been fewer branches and escalating bank fees. 

I commend Bank of America for its prior and current community reinvestment 

commitments to our California communities. Bank of America’s pledge of $140 billion 

over the next 10 years should be applauded, as well as NationsBank and Bank of 

America’s recent announcement of an unprecedented $350 billion commitment to lowincome communities, 

However, I would appreciate receiving details on how this pledge will benefit California’s 

consumers and communities. In requesting this information, I would respectfully point 

out that these specific requests are not unprecedented, and reflect commitments that 

other California institutions have made in the past. Therefore, I am confident that 

NationsBank and Bank of America will continue their good faith efforts to meet the 

needs of our California communities. 
F1.E No. 88’/ u’(/06 ‘98 11:~~ ILJ: 

Specifically. I would appreciate your response to the following questions: 

1) Does the bank intend to earmark a portion of the $350 billion to California7 

Given Bank of Americas dominance in California, it is critical that the community 

reinvestment commitment be California-specific and commensurate with the 

proportion of the Bank’s deposits and activities originating in the state. 

2) How will the institution fulfill regional commitments within Califomia~given the 

geographical, social and ethnic diversity or our communities? What culturallyappropriate products and services will be available to consumers, considering the 

various credit. investment and economic development needs of our state’s 

communities? 

3) How will the new bank maintain and expand Bank of America’s present programs 

and commitments in California, such as the Community Development Bank, Rural 

2000 Initiative. Economic Development Initiative. the BankAmerica Foundation, and 

affordable housing activities? It is vital that these programs be distinct entities within 

the merged bank and continue to be based in California, given the tremendous need 

in our state and the collective expertise Bank of America has acquired in serving our 

communities. 

4) What will be the.bank’s specific goals on the type and amount of loans for 

minority or women-owned small businesses and home loans? 

5) How will the new bank minimize branch closings and increase branch openings 

in regions and communities that are presently underserved by traditional banking 

institutions7 

6) Does the new bank intend to lower or stabilize ATM and bank fees? I am very 

concerned about rising bank fees, and their adverse impact on financially 

underserved. low-income communities. 

A dedicated commitment to California is an exciting and challenging opportunity for 

banks. This merger has the potential to create mutually beneficial outcomes for both 

consumers and banks given California’s ever-growing, entrepreneurial immigrant 

communities, expanding small-business market, and booming economy. 

I look forward to working with you to meet these above-mentioned goals and anticipate 

your prompt reply. 

Sincerely, 

Member af-Congress 
OFFICE OF THE MAYOR 

SAN FRANCISCO 

July 8, 1998 

Ms. Jennifer Johnson 

Secy. of the Board 

Federal Reserve Board 

20”’ & Constitution Ave, NW 

Washington D.C., 2055 I 

I 

WILLIE LEWIS BROWN, JR. 

Dear Ms. Johnson: 

We are writing to express to the Federal Reserve Board (Board) concems of the City and 

County of San Francisco (City) regarding the merger of BankAmerica Corporation 

(Bank) with NationsBank. The Bank has become paIt of the fabric that makes up the 

greater San Francisco Bay Area (Bay Area), and is involved in virtually every aspect of 

the City’s banking activities on behalf of our citizens. 

The City’s relationship with the Bank has evolved over the years into one in which the 

Bank is essential to the financial well-being of the City, as well as our reputation as one 

of the nation’s premier financial cente1.s. Not only is this relationship cmcial in terms of 

lending programs, bond sales, housin g and community development, but the Bank 

contributes to the vibrancy of out. local economy. In 1937, the Bank purchased goods and 

sewices from local vendors totaling 0~51’ $340 million. The importance of the Bank to the 

City cannot be overstated. For example, the City maintains significant deposits and a 

wide an-ay of selyices \vith the Bank including bimonthly payroll deposits approximating 

S30 million. In fact, the City of San Francisco is the Bank’s largest customer in Northern 

California. 

It is quite natual, then, that we, alou, 17 \vith 0111. fello\\; elected City’s ofiicials, would be 

concerned about any changes to the Bank’s structure or its ability to respond to the 

banking needs of tile City. Here aw tile hey ar’eas that \ve feel w-ill b: adversely impactei! 

SRIALL BUSINESS LENDING: A2uch of tile Bay Area’s success in the ne\v global 

economy has been tlri\,en by small businesses \vhich have created o\‘er a third of the 

ne\\,_jobs in the Cit), o\‘el. the last )‘ea~~. hslany of these businesses h:.\.-: been 

established Lvith loans from the Bank, which has been the leading lender to 

small businesses 111 OUI. I-egioli 011 a dollar basis. A larger number- of these 

enterprises we minorit) or \\olnen-owlled. As )‘ou are probably aware, luger, 
merged banks tend to provide fewer loans to small businesses. In 1996, the Bank 

made ovei‘ 2,600 small business loans in the City, totaling almost S150 million. 

CHARITABLE GIVING: The Bank has been a vital player in supporting the 

City’s nonprofit community, which selves the needs of poor, immigl-ant and 

homeless San Franciscans, in addition to other worthy philanthropic endeavors. 

Last year, the Bank and its Foundatioll gave over $35 million to Bay Area nonprofits, conununity groups and cultural institutions. Without the Bank’s presence, 

we are concenled that no other. colyorate partner would have the capacity to 

assume the role of the Bank in this arena. 

JOBS: According to the Bank’s own documents, the Bank employs 9,855 fulltinle and part-time staff in the City. We a1.e already workin closely with state and 

federal officials to meet the requirements of \velfare to work la\vs in order to train 

and hire Lvorkers for an increasingly limited pool ofjobs. Any significant effort by 

the Bank or the !!ew entity to do\vnsize 01. reduce workforce in the Bay Area will 

have an adverse Impact on the Bay Area’s economy, particularly in the new 

welfare to \vor!i eiivil-aliment. 

HOUSING: OUI, K*layor’s Office of Housirl 2 has developed a ~10s: relationships 

\vitll the Bank, and their joint activities ha\,e helped to put San F~ncisco in the 

forefront of national efforts to pl.o\,ide lo\v and middle-income Ilousing in an 

inci-easirigly restl.ictive housing niai.!iet. 

r\ecognizing tile need to add!-ess tile financing needs of affordable housing 

developments in “high costs” colnmunities like the San Francisco Bay Area, the 

Bank created tile BanhAmc~ica Coq)oratiou Communi~ Development Bank 

(B.4CDB), a sepamtc clral.telrd bank and a11 affiliate of the Bank In the San 

Francisco Ha>, At.en, BACDB leas loaned S39 million; this a~noun: ll?s been 

levelasett \\.itl> local and private f(indin, (1 sources to build oi l~enovate 930 

affo~~dnble housing units. 13.4C‘DB I~as also bee11 a Icatlu in de\.?lopirlS other 

iciipoi~tai~l affo~~dnhle housing pu3$l-anis tlli~ou~h the use of \‘ai’iOllj financing 

nlscha~~isn~s It is impeluti\e that tile B.4CDB remain 11) Sal> Frz!>cijco to 

111:11111:l111 11s i,lCCCSS. 
only in capital market access for the City, but also in lower interest rates for our 

taxpayers. 

As a consequence of these concerns, we strongly urge that the Board proceed with 

the utmost caution in its evaluation of the proposed merger. Therefore, we 

recommend that the Board require, at a minimum, that the new entity do the 

following: 

l Make specific written financial and other r-esource commitments (not goals) for 

affordable housing lending and equity in\.estmetrts, small business support and 

lending, and 

l Maintain BACDB as the lead community lending unit for the community 

grants programs 

l Retain employees in San Francisco who make decisions impacting charitable 

giving and community-based programs. 

The’se requirements will help detail for the Board and the public the stated 

commitment of the Bank and NationsBank to providing S350 billion in community 

reinvestment lending. :’ 

If you have any questions regarding our concerns, please feel free to contact us 

cc: Senator. Dianne Feinstein 

Senator Barba1.a Boxet. 

ConaJess\\~olnan Nanc) Pelosi 

Alan Gt-eenspatl 

Joy l-loffman 

Califonria Rein\,ensttnent Cotnmittee 

Greenlinin~ Institute 
OFFICE OF THE MAYOR 

SAN FRANCISCO 

: 

WILLIE LEWIS BROWN, JR. 

July 8, 1998 

Ms. Jennifer Johnson 

Secy. of the Board 

Federal Reserve Board 

20”’ & Constihitioil Ave, NW 

Washington D.C., 2055 I 

Dear h4s. Johnson: 

We are writing to express to the Federal Reserve Board (Board) concerns of the City and 

County of San Francisco (City) regarding the merger of BankAmerica Corporation 

(Bank) with NationsBank. The Bank has become part of the fabric that makes up the 

greater San Francisco Bay Area (Bay Area), and is involved in virtually every aspect of 

the City’s banking activities 011 behalf of our citizens. 

The City’s relationship with the Bank has evolved over the years into one in which the 

Bank is essential to the financial \vell-being of the City, as well as our reputation as one 

of the natioil’s premier financial centers. Not only is this relationship cnlcial in terms of 

lending programs, bond sales, housin g and comn~u~~ity development, but the Bank 

contributes to the vibrancy of our local economy. In 1997, the Bark purchased goods and 

services from local vendor-s totaling o\‘er $340 million The importance of the Bank to the 

City cannot be o\,et.stated. For example, the City maintains significant deposits and a 

wide an-ay of selyices \vith the Bank includin g bimonthly payroll deposits approximating 

S30 million. In fact, the City of San Francisco is the Bank’s lal-gest customer in Northern 

Califoiuia. 

It is quite natural, then, that \ve, along \\:ith our’ fello\y elected Civ’s officials, would be 

concerned about any changes to tile Bank’s structure or its ability to respond to the 

banking needs of tile City,. Here a,~? the key ar’eas that xv2 feel \vill be adversely impacted 

SMALL BUSINESS LENDING: I\luch of the Bay Area’s SLICC~SS in the new global 

economy has been driven by small businesses \\hich have created 01.21 a third of the 

ne\vJobs in the Cit), o\.er the last )‘eal.. klan!, of these businesses hn\.e been 

established \\:ith loans from the Banh, \vhicll has been the leading lender to 

small businesses ilr OIII. l.egion on a dollar basis. A larger number of these 

enterprises are minol~ity or \volnen-o\vned. As you are probably aware, larger, 
merged banks tend to provide fewer loans to small businesses. In 1996, the Bank 

made over 2,600 small business loans in the City, totaling almost $150 million. 

CHARITABLE GIVING: The Bank has been a vital player in supporting the 

City’s nonprofit community, which selves the needs of poor, immigrant and 

homeless San Franciscans, in addition to other worthy philanthropic endeavors. 

Last year, the Bank and its Foundation gave over $3.5 million to Bay Area nonprofits, community groups and cultural institutiolls. Without the Balk’s presence, 

we a1.e concerned that no other colporate pal-tner would have the capacity to 

assume the role of the Bank in this arena. 

JOBS: Accol-ding to the Bank’s o\vn documents, the Bank employs 9,855 fulltime and part-time staff iii the City We are aheady working clojtlj’ with state and 

federal officials to meet tile requirements of welfare to work la\vs in order to tTain 

and hire workers for an incl.easingly limited pool ofjobs. Any significant effort by 

the Bank or the new entity to douxsize or reduce workforce in the Bay Area will 

hayean adverse‘impact on the Bay Area’s economy, particularly in the new 

\velfare to wok en\,ironmeilt. 

HOUSING: Our Mayo?s Office of Nousin 2 has developed a close relationships 

\vith the Bank, and their joint activities have helped to put San Francisco in the 

forefront of national efforts to p~.ovids lo\\, and middle-income housirlg in an 

incl-easingly restl.ictive housing iiiaket. 

Recognizing the need to addt~ess tile finaucins needs of affordable housing 

developments in “higl> costs” communities like the San Francisco Bay Area, the 

Bank cl,eated the BanhAlnel.ica Coq)oration Community Developrn:nt Bank 

(B.qCDB), a sepamtc cl~a~~tc~~etl bank alltl au affiliate of the Bank. In the San 

Francisco Bay Al.ea. R!\CDR l~ns lon~~ecl $39 million; this amount I1l.s been 

Is\,er~aged \vith local nlld pGvate fundin, 17 SOIIK~S to build 01. reno\‘at: 930 

affol.dable housi~ls ullits. B.q\CDB has also beei> a leader in de\,eloping other 

impol~tnnt affordable housing programs through the Use of Yai’iOUj fixmcing 

mechanisms It is impemti\,e that the BACDB remail1 in San Franciic0 to 

Ill~llllliilll Its SIICCC’SS. 
only in capital market access for the City, but also in lower interest rates for our 

taxpayers. 

As a consequence of these conceals, we strongly urge that the Board proceed with 

the utmost caution in its evaluation of the proposed merger. Therefore, we 

recommend that the Board require, at a minimum, that the new entity do the 

following: 

l Make specific written financial and other resource commitments (not goals) for 

affordable housing lending and equity iriveshnents, small business support and 

lending, and 

l Maintain BACDB as the lead community lending unit for the community 

grants programs 

l Retain employees in San Francisco \vho make decisions impacting charitable 

giving and community-based programs. 

The3e requirements will help detail for the Board and the public the stated 

commitment of the Bank and NationsBank to providing $350 billion in community 

reinvestment lending. :- 

If you Ilave any questions regal.dill g our concenis, please feel free to contact us. 

cc: Senator Dianne Feinstein 

Senator Bal.1~11.a Bezel, 

Co~lg~~ess\\-oma~~ Naq l’rlos~ 

Alan Greenspan 

Joy Hofflnan 

Calit’olllia Reinvenstment Comnlittee 

Greenlinin~ Institute