Community Group Says OCC’s Approval Contradicts Goals of the CRA
San Francisco, CA- May 12, 2016—Today, the California Reinvestment Coalition (CRC) strongly criticized a decision by the Office of the Comptroller of the Currency (OCC) to approve a “new” Community Reinvestment Plan by CIT Group which is substantially the same as a CRA plan the OCC rejected in 2015.
In its conditional approval of CIT merging with OneWest Bank, the OCC required CIT Group to revise its plan to clearly describe how the bank will help meet the credit needs of low and moderate income individuals and geographies, including through investments in affordable housing.
However, CIT Group’s “new” CRA plan, which was approved by the OCC, has the exact same overall dollar commitment ($5 billion over four years) as the draft plan that CIT Group and OneWest developed in February 2015 and that the OCC had ordered the banks to improve last July. CRC’s analysis of both plans places the bank at the bottom of its peer banks in California for CRA activities.
Advocates also criticize the new plan for failing to meaningfully target the bank’s commitments to low income and moderate income individuals or geographies. For example, mortgage loans to upper income homeowners in wealthy neighborhoods and loans for luxury multifamily housing can be reported by CIT to its regulators and could count towards the bank’s goals in its plan.
Paulina Gonzalez, executive director of CRC, comments: “The Community Reinvestment Act was enacted in response to the redlining of communities and implementation and enforcement of this law is meant to ensure that low and moderate income communities have access to banks, credit, and other financial services. Unfortunately, those communities are not the main focus of CIT’s new plan.”
CRC members and allies documented and presented to the OCC and Federal Reserve an unprecedented number of issues including an anemic branch presence in LMI communities (see maps below) and low lending to borrowers of color, prompting possible redlining concerns.
OneWest’s record of foreclosures concentrated in neighborhoods of color (68% of the bank’s foreclosures in California occurred in majority-minority zip codes) and questionable reverse mortgage foreclosure practices on seniors and their families also raises fair housing concerns. The OCC heard from impacted consumers at a hearing about the merger and CRC also shared information with the OCC that it obtained via Freedom of Information Act requests to the FDIC and HUD.
Michael Banner, president and chief executive of Los Angeles Local Development Corporation, explains: “The bank’s “commitment” to locating 15% of branches in LMI communities (exactly half the industry average) would be laughable if it weren’t so harmful. Why should anyone believe that the OCC expects CIT Group to meet the credit needs of communities if it doesn’t have branches in them?”
Hyepin Im, founder and president of Korean Churches for Community Development,adds: “OneWest’s record of mortgage lending to Asian American borrowers was less than half the industry average, leading us to question their commitment to serving LA’s diverse communities. This new plan, and the OCC’s approval of it, only adds to our concerns.”
Kevin Stein, associate director of CRC, comments: “One of the main ways OneWest Bank interacted with low income communities and communities of color during the past seven years has been through foreclosing on them. The OCC’s approval of this plan sends the wrong message to banks and to California communities.”
Sharon Kinlaw, executive director of the Fair Housing Council of San Fernando Valley, adds: “The conditional merger approval was an opportunity for the bank and the OCC to address the serious concerns raised by over a hundred organizations in the merger process. Instead, the bank offered a weak plan, and the regulators approved it, hoping advocates like us would go away. But we’re not going anywhere and we will continue to demand accountability for California communities.”
CIT Group’s CRA plan vs. City National’s CRA plan: In contrast to the CIT Group and OneWest merger, as part of its merger with Royal Bank of Canada, City National Bank developed a robust CRA plan with input and support from community members. City National Bank’s CRA plan, released in 2015, commits to $11 billion of CRA activity over five years, or nearly double what CIT Group proposed and the OCC accepted.
Notably, City National doesn’t have a history of reckless foreclosures on communities of color and seniors, subpoenas from HUD, questionable loans to bankrupt Hollywood studios, golden parachutes to departing executives, or unpaid TARP bailouts.