Gaming the System

GAMING THE SYSTEM

How Wells Fargo, JP Morgan Chase, Citibank, and Bank of America

Have Subverted the Community Reinvestment Act

A Report by National People's Action

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I. Introduction

The nation’s major banks have subverted their legal responsibilities to meet the credit needs of low and

moderate income communities under the Community Reinvestment Act (CRA) and instead have put

many communities at risk of foreclosure and widespread disinvestment due to their irresponsible

lending practices. This report documents how loopholes in CRA have allowed the nation’s major

banks to make high volumes of costly home loans to lower-income and minority borrowers and at the

same time have allowed these banks to receive the most favorable ratings on their lending performance

under CRA. The major banks have sidestepped CRA by funneling a significant portion of their

destructive and risky home lending to affiliate lending companies and to geographic areas outside of

their graded assessment areas.

In past decades, rampant deregulation and a resulting shift in the mortgage industry have led to the rise

of non-depository institutions as major home lenders, the growth of non-traditional loan products, and

to a greater consolidation of financial institutions. The home lending industry changed but the

Community Reinvestment Act did not.

The changes in the mortgage industry brought more than just a change in the institutions making home

loans, the type of lending changed as well. High-cost and predatory home lending exploded in the late

1990’s and during the first decade of 2000’s. African-American, Latino, and lower-income urban

neighborhoods were the canaries in the coalmine for this type of destructive credit receiving the

highest rates of costly home loans destined to fail. The toxic predatory lending that flooded first

minority and lower income neighborhoods eventually caused a tsunami that devastated not only the

neighborhoods where the bulk of these loans were made, but led to the near-collapse of our entire

financial system, a multi-billion dollar tax-payer funded bail-out of our major financial institutions, the

loss of billions in retirement savings lost, foreclosures on millions of homes, and the worst and longest

lasting unemployment crisis in generations.

So what did CRA have to do with the financial crisis? The vast majority of the home lending with

high rates of default and foreclosure occurred outside of CRA through unregulated mortgage

companies and through the under-regulated practices of the major banks as discussed in this report.

CRA in no way caused the subprime mortgage meltdown.

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As the Federal Reserve Bank of Dallas concluded in 2009;

“Data from the Board’s staff report suggest that the CRA prevented the subprime situation from

being more severe.”1

Unfortunately, CRA could have played a much stronger role in preventing the reckless home lending

that came to dominate the industry and its predictable fall-out of massive foreclosures and

disinvestment. Had CRA covered all of the home lending that was occurring -and had CRA been

effectively administered according the full spirit of the law2- it is likely that the worst of the crisis

could have been averted.

The Community Reinvestment Act: An Overview

The Community Reinvestment Act (CRA) was passed in 1977 with the goal of ending discriminatory

lending based on race or location and to ensure that banks met the credit needs of all the

neighborhoods and populations they serve.3 At this time “redlining” – the bank practice of identifying

certain areas and populations where credit would not be available – was rampant in distressed urban

areas across the country. For affected communities, “redlining” meant more than the absence of

available bank lending. It also meant the prevalence of highly exploitative credit options that

financially ruined borrowers and communities while enriching unscrupulous lenders.4 CRA was

largely successful in bringing an end to redlining while encouraging banks to work with communities

and neighborhood groups to tailor innovative and highly successful reinvestment plans and products.

Together, banks and the neighborhoods they are in existence to serve revitalized communities and built

wealth in low-income and minority neighborhoods.

The intention of the Act was to cover the mortgage lending industry. In the mid-1970s that meant

depository banks originating mortgages from a network of branches. As a result, the CRA exam

1 Banking and Community Perspectives, Issue 1, 2009 Federal Reserve Bank of Dallas “The CRA and Subprime Lending: Discerning the Difference” 2 In 1995, the bank regulators eliminated assessment factors regarding illegal discrimination in CRA exams, leaving uncovering instances

of discriminatory lending up to the subjective opinion of the CRA examiner. As a result, virtually no instances of discrimination, such as over-charging or steering certain populations of borrowers into unsustainable loan products, have been documented in recent CRA exams despite the fact that independent analysis has shown that many subprime borrowers had credit scores that could have qualified them for better loans terms. See: “Subprime Debacle Traps Even Very Credit-Worthy” Wall Street Journal, December 3, 2007. 3 Underlying CRA is the concept that the nation’s financial institutions owe their existence to and benefit from certain publically-granted rights and guarantees, such as federal deposit insurance, and therefore these institutions have an obligation to meet certain public standards in their business practice, including fairness and accountability. 4 Satter, Beryl. Family Properties: Race, Real Estate, and the Exploitation of Black Urban America. Metropolitan Books, 2009. See

Satter’s description of “contract” home buying in Chicago for a description of predatory home lending in the context of redlining.

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conducted by a banking regulator grades only that lending that takes place in a bank’s predetermined

“Assessment Areas” that are based on where the bank has physical branches. In addition, the

regulators grade only those loans originated by the bank portion of a bank holding company and not

the mortgage lending of a banks’ subsidiary or affiliate companies.5 For example, the lending activity

of Wells Fargo Bank is graded, while the substantial lending activity done by Wells Fargo Home

Mortgage and Wells Fargo Financial is not.

Banking regulators examine banks for CRA compliance6 and assign a grade of Outstanding,

Satisfactory, Needs to Improve, or Substantial Non-Compliance. A grade of Satisfactory or

Outstanding is needed for a bank to freely expand through merger or by opening new branches. An

Outstanding rating can also lead to expedited regulatory approval and a longer period of time between

CRA exams.

The vision of CRA was to deliver all neighborhoods, regardless or income or race, from the grasp of

exploitative lenders and into the financial mainstream.7 While there are not specific loan quality

requirements in CRA, it is widely understood that CRA credit is given to banks for originating quality,

affordable loans that are good business for both the borrower and the lender. Guidance from federal

regulators8 has made it clear that predatory lending –often hallmarked by high-cost loans– should not

receive positive CRA credit. But instead of abandoning the risky and destructive lending that came to

dominate the home lending industry, as this report documents, the nation’s leading banks issued high-

cost subprime loans and merely moved this business outside of regulatory scrutiny.

5 Banks may chose to include a portion of their subsidiary or affiliate lending but are not required to do so. 6 CRA ratings are based on lending, investment, and service tests, which assess a bank’s home lending, community development lending, small business lending, community development grant-making, and location of retail branches with a particular focus on the number of loans and projects located in Low or Moderate Income areas within the bank’s defined Assessment Areas. 7 At the time of CRA’s passage, the financial mainstream consisted of banks and thrifts which offered almost exclusively a standard, fixed-rate mortgage product. 8 See OCC AL-2003-3; FDIC FIL-6-2007

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II. Report Primary Findings

A. CRA Grades do not accurately reflect a bank’s actual community reinvestment performance

• Despite contributing substantially to the mortgage melt-down and financial collapse by their

high-cost lending patterns, the “big banks”: Wells Fargo, Bank of America, JPMorgan Chase

and Citibank all received an “Outstanding” rating on their most recent CRA exams.

B. Big banks have used their affiliate lenders to issue a disproportionate amount of high cost loans,

especially to minority and lower-income borrowers.

• Big bank affiliates issued only 17% of the total loan volume, but were responsible for 46% of

all the reported high-cost loans of the major banks.

• More than one in four of big bank mortgage loans made to African-American and Latino

borrowers were made by their affiliate lenders

• Three out of every four African-American or Latino customers of big bank affiliates received a

high-cost loan

• 24% of all big bank loans made to lower income borrowers were made by affiliate lenders

• 57% of low to moderate income customers of big bank affiliates received a high-cost loan

C. Big banks and their affiliates have issued the majority of their high-cost lending outside of their

primary assessment areas and at a highly disproportionate rate to lower-income and minority

borrowers.

• 65% of big banks lending fell outside of a full scope, primary assessment area review in 2008

• More than 80% of high-cost lending to low and moderate-income borrowers occurred outside

full scope review assessment areas in 2008.

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III. Scope of Research

This report examines the national home lending record of the nation’s largest banks and their mortgage

lending affiliates in the context of CRA regulation. It draws on data reported under the Home

Mortgage Disclosure Act (HMDA) in the years 2006 and 2008. The banks and affiliated mortgage

lenders examined in this study together account for a majority (51%) of all home lending nationwide

both before and after the mortgage crisis. The 2006 HMDA data is analyzed to represent the market

conditions of the home mortgage industry leading up to the foreclosures crisis. For 2006, this report

focuses on the nation’s top 7 mortgage lenders and their affiliates and subsidiaries at that time, as listed

below:

Rank

(2006)Company

06 Total Loan

Volume ($ Millions)

06 Market

Share

1 Countrywide $462,501 14.2%2 Wells Fargo & Company $397,640 12.2%

3 Washington Mutual Inc. $196,181 6.0%4 Chase Home Finance $172,900 5.3%5 CitiMortgage, Inc. $169,219 5.2%6 Bank of America $166,494 5.1%

7 Wachovia Bank $104,471 3.2%Total Marketshare: 51.1%

2006 Residential Lending Volume

Source Media, 2007

By 2008, the seven top lenders from 2006 were consolidated through failure and acquisition to form

the four big bank lenders that are the focus of this report.9 This report relies on 2008 HMDA data, the

most recent publicly-available data at time of publication, to analyze lending patterns at the major

banks and their respective mortgage lending affiliates which together represent four of the top five

home lenders at year-end 2009. 10

These four institutions, Wells Fargo, Bank of America, JPMorgan

Chase, and Citibank, together with their respective affiliates also make up 51% of the total home

lending market nationwide.11

9 Bank of America acquired Countrywide, Wells Fargo acquired Wachovia, and JP Morgan Chase acquired Washington Mutual. 10 2008 HMDA data documents a decline in access to credit among many communities and borrowers since the mortgage market collapse See “Paying More for the American Dream IV: The Decline of Prime Mortgage Lending in Communities of Color” May 2010, Woodstock Institute, California Reinvestment Coalition, et al 11 See Appendix A for full list of lenders included in analysis.

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Rank

(2009)Company

09 Total Loan

Volume ($ Millions)

09 Market

Share

1 Wells Fargo & Company $427,211 20.7%

2 Bank of America $391,318 19.0%

3 Chase $155,771 7.6%

5 CitiMortgage, Inc. $81,253 3.9%

Total Marketshare: 51.2%

2009 Residential Lending Volume

Source Media, 2010

IV. CRA Bank Examinations during the past Decade

CRA has recently attracted increased interest and debate since the collapse of the mortgage market in

late 2007.12

A review of CRA examinations during the past decade shows that there was a relative

decline in the number of bank exams administered by the regulators.

CRA Examinations by Rating: 1990-2010

0

1000

2000

3000

4000

5000

6000

7000

1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010

Noncompliance

Needs to Improve

Satisfactory

Outstanding

Source: FFIEC, 2010

During the 1990’s federal regulators examined on average 4,750 banks and thrifts under CRA per year.

In contrast, during the last decade (2000 to 2009) the average number of annual CRA examinations

12 CRA critics, often conservative ideologues, have accused the CRA of forcing banks to make unprofitable and unsustainable loans to lower income borrowers and thereby blaming the decades old regulation for causing the foreclosures crisis. Community groups on the other hand have blamed the regulators and the banking industry for failing to monitor even basic standards of loan quality and investigate issues of discrimination via CRA and other relevant regulations.

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dropped over 60% to approximately 1,825 bank exams per year.13

While the number of exams has

decreased, the percentage of institutions receiving a “Satisfactory” or “Outstanding” rating has

increased somewhat from 95% of all examinations during the 1990’s to 98.6% of exams in the past

decade. Among the banks receiving “Outstanding” rating are the nation’s largest banks (owned by the

major corporate bank holding companies), which have all received the highest rating on their recent

CRA exams.14

CRA Ratings of Major National Banks

Bank Holding Company Bank Name Asset Size* Regulator Exam Date

Overall CRA

Rating

Bank of America Corp. Bank of America, N.A. 1,355,154,455 OCC 12/31/2006 Outstanding

Citibank, N.A. 306,000,000 OCC 6/9/2003 Outstanding

Citibank (West), FSB 96,099,048 OTS 10/12/2004 OutstandingCitibank (New York State) 23,427,477 FDIC 9/1/2003 OutstandingCitibank (Banamex USA) 1,322,720 FDIC 4/1/2009 Outstanding

Citicorp Trust Bank, FSB 18,565,981 OTS 11/9/2009 Outstanding

JP Morgan Chase Bank, N.A 1,378,468,000 OCC 1/1/2007 OutstandingJP Morgan Chase BK 622,388,000 FRB 9/8/2003 OutstandingChase Bank USA, N.A. 88,722,430 OCC 11/2/2008 Outstanding

Wells Fargo & Company Well Fargo Bank, NA 608,778,000 OCC 12/1/2009 Outstanding

* Assest Size as reported at date of exam

Citigroup Inc.

JP Morgan Chase & Co.

Source: FFIEC

In summary, the last decade of CRA practice has been characterized not by an expanded reach or

increased implementation of CRA but rather by: 1) less frequent bank examinations overall, 2) fewer

exams which identify widespread problems in extending credit fairly to low and moderate income

communities,15

and, 3) the country's largest and most important banks receiving almost exclusively

“Outstanding” ratings.

V. Affiliate Mortgage Lenders: How CRA Fails to Cover all Home Lending of the Nation’s

Major Banks

Q: Are the Nation’s Largest Banks Covered by CRA?

A: Only in parts of their business and not where their worst lending took place.

13 The decrease in CRA exams was in part due to consolidation in the banking industry which produced fewer but larger institutions servicing wider markets and thereby making the need for a robust and effective CRA grading system even more critical. 14 When a bank receives an Outstanding rating it is rewarded with less frequent examinations under CRA. 15

Issues which could necessitate a rating of “Needs to Improve” or “Substantial Noncompliance”.

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Since the creation of CRA over 30 years ago, CRA has regulated and applied to “depository

institutions” which are nationally-chartered banks and thrifts and include the nation’s largest banks.

CRA’s coverage is limited to depository institutions (banks, savings and loans), which traditionally

issued almost all of home loans in the country. However, the mortgage industry has evolved greatly in

the last two decades and has been transformed by the entrance of non-depository (or “non-bank”)

mortgage lending companies into the home lending market.16

Most major bank holding corporations

adapted to the evolving mortgage finance industry and have operated non-bank mortgage lending

companies in recent years which have issued a significant volume of home loans.

In 2006 mortgage lending subsidiaries and affiliates of the major banks originated or purchased over

1.37 million mortgages nationwide accounting for 20% of the total home loan volume by the leading

seven mortgage companies during this record-breaking year of mortgage lending.

16 Securitization of mortgages into Wall Street investments was another major development in mortgage lending in the past two decades, which suggests the need for CRA coverage to include non-depository lenders.

2006 Mortgage Originations and Purchases by Top 7 Lenders

Mortgage Lender

Mortgage

Originations

(Retail)

Mortgage

Purchases

(Correspondent)

Total

Originations

and Purchases

Major Banks 2,245,803 991,090 3,236,893

Affliates of Major Banks 466,448 910,967 1,377,415Countrywide Financial (Independent

mortgage company) 1,034,920 1,409,623 2,444,543Totals 4,213,619 4,222,647 8,436,266

Affliates of

Major Banks

20%

Countrywide

Financial

(Independent

mortgage

company)

35%

Major Banks

45%

Source: HMDA 2006

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Top Five Mortgage Lending Affiliates of Major Banks, 2006

Affiliate/Subsidiary Lender Parent

Company 2006 Home Loan

Originations

CitiMortgage Citibank 128,442

Long Beach Mortgage Washington Mutual 103,054

Wachovia Mortgage Wachovia 83,369

CitiFinancial Citibank 77,009

Wells Fargo Financial Wells Fargo 63,072

Source: HMDA 2006

The mortgage lending affiliates and subsidiaries of major banks are of particular concern to the issue of

community reinvestment not only due to the volume of loans issued (upwards of 400,000 loans

annually) but above all for the type of home loans made and the market served by these lenders. The

data shows that loans made by big bank affiliates in 2006 were much more likely to come with high-

interest rates17

. While big bank affiliates issued only 17.1% of the total loan volume for big banks in

2006, these non-bank lenders made close to half (45.5%) of the all reported high-cost loans by the

major banks.

265,972

1,979,831

222,506

243,942

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

Major Banks Subsidiaries and Affiliates

Other Loans

High Cost Loans

17 “High-cost” loans issued by major banks and affiliates in 2006 averaged an initial interest rate of 9.9%. It is likely most of the loans made through affiliate lending channels would be classified as “subprime loans” charging an initial interest rate based on the industry’s use of risked-based pricing where the borrowers with the least wealth pay the most for access to credit. However current limitations of HMDA data prevent a more complete identification of loan and borrower characteristics that is necessary to accurately classify a prime or subprime home loan.

National Home Loan Volumes by Major Banks and Affiliates, 2006

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Given what we now know about subprime loans originated during this time,18

it is evident that the

costly and irresponsible lending that produced high levels of default and foreclosure was a core

business of the big bank affiliate mortgage lenders.

The customer base of the risky lending of subprime affiliates was also heavily concentrated in lower-

income and minority communities. More than one out of four loans (27%) of all home loans made by

the big banks to African-American and Latino borrowers occurred through their affiliate lending

channels19

. The affiliate lenders provided loans to African-American and Latino borrowers at nearly

double the rate of their national banks: 24% of all affiliate lenders customers were African American

or Latino whereas 13% of national bank customers were African-American or Latino. Three out of

every four (74.6%) of minority (African-American or Latino) customers of big bank affiliate home

lenders received a high-cost loans which averaged 10.2% APR on first lien mortgages in 2006.

Together, the big bank affiliate lenders made a greater number of high-cost loans (84,100) to Black and

Latino borrowers than were issued by the major banks directly (60,200) in 2006.

Number of Home Loans to African-American and Latino Borrowers

Issued by Major Banks and Affiliates, 2006

60,216

239,970

28,425

84,166

High-cost Loan by Affiliates

High-cost Loan by MajorBanks

Other Loans by Major Banks

Other Loans by Affiliates

Source: HMDA 2006

Similarly, the lending of big banks affiliates also represented a significant portion of home loan

products sold by the major banks to the Low to Moderate Income (LMI) borrowers20

. One quarter

18 High-priced loans have been found to have over three times the rate of foreclosure, see Laderman and Reid, “Lending in Low- and Moderate-Income Neighborhoods in California: The Performance of CRA Lending During the Subprime Meltdown” 19 The “big banks” or major banks term as used in this report refers to, in the context of 2006 HMDA data, Wells Fargo, Bank of America, JP Morgan Chase, Citibank, Wachovia and Washington Mutual (excluding top Countrywide). 20 A Low to Moderate income borrower is a one with a reported income of less than 80% of Median Family Income of the Metropolitan Area.

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(24%) of all major banks loans made to lower income borrowers in 2006 came through their affiliate

lending channels. Over 57% of LMI customers of big bank affiliates received a high-cost loan

averaging a 9.9% interest rate (first lien mortgages).21

Mortgage Lending Affiliates Since the Subprime Meltdown

Since the onset of mortgage crisis the composition of the mortgage industry has changed dramatically

with the failure of several large banks (Washington Mutual, Wachovia) and departure of most major

independent mortgage companies (most notably Countrywide Financial). However, for the nation’s

largest four financial institutions to survive the market collapse, the overall contraction in the mortgage

industry bought about an increased mortgage lending volume in 2008. The top four banks and

affiliates increased originations 13% from 2006 to 2008. While the mortgage volumes of the big bank

affiliates decreased somewhat in 2008 (12% decrease in origination volume between 2006 and 2008)

they survived in relatively strong position compared to most other competitors in the marketplace.

The future of affiliate and subsidiaries lending channels is as uncertain as the housing market itself; it

is even possible that lending volume could trend down further in 200922

. But it is very likely that the

largest and most complex financial institutions will continue to operate through a variety of mortgage

lending channels including their non-bank mortgage lending companies.23

Loan Volumes of Major Banks in 2006 and 2008

2,245,803

466,448

2,527,536

408,370

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

3,000,000

2006 2008

Subsidiaries/Affiliatesof Major Banks

Major Banks

21 High-cost loans are the only risky loan product identifiable in current HMDA data. Therefore high-cost loans do not represent the full extent of risky and unaffordable mortgage lending and rather serve as a partial indictor of the extent of such practices. 22 In July 8, 2010 Wells Fargo formally closed their principal subprime affiliate lending channel, Wells Fargo Financial. 23 There are some industry experts that predict a return to securitization of subprime mortgages in the near future, see: “Subprime Securitizations may Re-emerge (if Yields Rise)” in Mortgage Servicing News, July 2010 Volume 14, No 7.

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This 2006 data shows that the non-bank mortgage lending affiliates and subsidiaries of the nation’s

largest banks contributed to the risky and unaffordable home lending leading up to the mortgage crisis.

The 2008 data illustrates that affiliate lending is very much a part of the lending performance of the

large banks and continue to have a real impact on the financial health of communities and customers.

However, these non-bank mortgage lending affiliates and subsidiaries are not covered under CRA and

are not subject to examinations24

. In effect, the most risky segment of major banks’ home lending

business, a segment that poses real risks of default and foreclosure to LMI communities and borrowers,

continues to exist outside of any direct and mandatory review under CRA.25

VI. Assessment Areas: How CRA Fails to Cover the Markets where the Majority of High-

Risk Lending to Lower Income Borrowers Occurs

Q: Are the Nation’s Largest Banks Covered by CRA?

A: Only in parts of the country and not where the majority of their riskiest lending

took place.

CRA examinations review and rate a bank’s lending performance within a defined geographic area

called an “assessment area” which are determined according to the location of the banks’ retail

locations (depository institutions). The modern home mortgage market operates through lending

channels which have a nationwide reach and are increasingly online. Certainly mortgage lenders are

not limited to lend only in areas where they operate retail locations and offer consumer checking and

saving accounts. CRA’s coverage of the largest banks, however, is still based on this outdated model

of depository bank lenders which serves to limit the scope and ultimately the effectiveness of CRA

examinations.

Analysis of CRA assessment areas (abbreviated below as “AA”) and recent home lending data of the

four largest banks shows that approximately 60% of the total loan volume issued in 2006 and 65% of

all loans made in 2008 occurred inside the lenders’ CRA assessment areas. While this might suggest a

relatively high level of lending coverage under current CRA assessment areas, further analysis reveals

that only 41% to 50% (in 2006 and 2008, respectively) of the high-cost loans issued by the big banks

24 Although their lending record may be reported on a CRA exam at the discretion of the bank parent company 25 Loans made by affiliates and subsidiaries need to be included in CRA examinations, but beyond this there is an overarching need to assess loan quality and disparate use of risky or costly loan products in the context of a CRA examination. This approach should be adopted together with additional disclosure of needed loan quality and borrower information in HMDA.

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and their affiliates occurred within an assessment area. In the most recent year of data, a majority

(54%) of the high-cost loans made by the nation’s top four banks to Low and Moderate Income (LMI)

borrowers were outside their assessment areas and therefore not subject to review under CRA.

The coverage of big bank’s home lending under CRA is even further limited when one considers the

different levels of review performed on many CRA examinations. Assessment areas of large banks are

often divided into “full scope” or “primary” review areas and “limited-scope” review areas. 26

Lending within the full-scope reviews areas are the primary factor listed on the examination report for

determining the bank’s overall lending test rating. Limited-scope areas on the other hand and

addressed much more briefly in the CRA exam report and receive little substantive analysis. For major

lenders, “limited” reviews areas often are found to “not influence the lending test rating” even when

performance was “weaker than the overall performance.”27

Given this approach, it is reasonable to

assume that the only the “full review” assessment areas are likely to receive an adequate review of

lending performance under CRA.

2006 Home

Loans

2006 High-

Cost Loans

2008 Home

Loans

2008 High-Cost

Loans

08 Loans to

LMI Borrowers

08 High-Cost

Loans to LMI

Borrowers

In Assessment Area 1,213,038 146,651 1,534,236 108,787 730,536 64,704

In Primary AA 627,107 69,982 814,279 52,589 323,632 26,970Out of AA 769,786 209,523 773,183 107,775 553,617 75,613

Total Loans 1,982,824 356,174 2,307,419 216,562 1,284,153 140,317

% IN AA 61.2% 41.2% 66.5% 50.2% 56.9% 46.1%

% in Primary AA 31.6% 19.6% 35.3% 24.3% 25.2% 19.2%

Loans Made by Big Four Banks by CRA Assessment Area, 2008

Source: HMDA, OCC, OTS, FRB

This analysis finds that only 35% of all big bank lending in 2008 occurred within a primary assessment

area which receive a “full” review under CRA. Most notably only 19.2% of the high-cost loans made

by a major bank in 2008 to low or moderate-income borrowers occurred in a county or metropolitan

statistical area receiving a full-scope review. Thus, three out of four all high-cost loans and four out

of five high-cost loans made to LMI borrowers by a major bank nationwide in 2008 occurred in areas

of the country not subject to a thorough review under CRA. This finding is further illustrated by the

case of Wells Fargo and Citibank.

26 According to CRA guidelines, a “Full Review” under the CRA lending test rates performance according to qualitative and quantitative factors whereas a “Limited Review” only uses quantitative factors, which are typically limited to reporting the number and dollar amount of home loans and the proportion of these loans in LMI census tracts. Bank of America, Wells Fargo, and JP Morgan Chase all have assessment areas defined by full and limited-scope reviews on their most recent CRA examinations, where as Citibank N.A.’s CRA exam does not differentiate assessment areas. 27 See Wells Fargo Bank, NA CRA examination administered by the OCC, December 2009

15

Wells Fargo and affiliates issued approximately 52% of home mortgages within its assessment area in

2008, however only 22% of the total loan volume and only 15% of their high-cost loan volume

occurred in a primary AA receiving a full scope review.28

VII.

28 See Appendix C. for loan totals and maps for Major Bank Lending Volumes and CRA assessment areas.

Wells Fargo Home Loans by County and CRA Assessment Area, 2006 & 2008

CA

TX

NY

FL

IL

PA

OH

MI

NJ

GA

NC

VA

MA

IN

WA

TN

MO

WI

MD

AZ

MN

LA

AL

CO

KY

SC

OK

OR

CT

IA

MS

KS

AR

UT

NV

NM

WV

NE

ID

ME

NH

RI

MT

DE

SD

ND

VT

WY

Map layersCountyLimited Scope Assessment AreaFull Scope Assessment Area

State (Low)

Well Fargo Home Loans, 2006 & 2008

25000

125006250

Home Loans 2006

Home Loans 2008

Well Fargo’s home lending in 2006 and 2008 outside of the bank’s CRA assessment areas and

therefore not subject to review occurred in many parts of the Midwest and virtually every major

urban area on the East coast and in Southeast, including: New York, NY, Miami, FL, Philadelphia,

PA, Raleigh-Durham, NC, Atlanta, GA, Washington, DC, and St. Louis, MO.

Wells Fargo’s Top Home Lending Markets Not Reviewed under CRA

16

Similarly, while roughly half (51%) Citibank’s home lending in 2008 occurred within their CRA assessment areas,

only 21% of their high-cost loans and 16% of high-cost loans to LMI borrowers occurred in their CRA assessment

areas.

Citibank Home Loans by County and CRA Assessment Area, 2006 & 2008

CA

TX

NY

FL

IL

PA

OH

MI

NJ

GA

NC

VA

MA

IN

WA

TN

MO

WI

MD

AZ

MN

LA

AL

CO

KY

SC

OK

OR

CT

IA

MS

KS

AR

UT

NV

NM

WV

NE

ID

ME

NH

RI

MT

DE

SD

ND

VT

WY

0 300

Miles * Includes all Citigroup affiliates and subsidiaries

Map layersCountyCRA Assessment Area

Citibank Home Loans by County, 2006 & 2008

30000

15000.57500.75

Home Loans 2006Home Loans 2008

TX

Citibank’s Top Home Lending Markets Not Reviewed under CRA

Citibank’s recent home lending falling outside of the bank’s CRA assessment areas and not

subject to CRA examination occurred in many states in the Midwest, South, Southeast, and

Northwest, which cover the major urban areas of Phoenix (Maricopa County), AZ; St.

Louis, MO; Seattle (King County), WA; Detroit (Wayne County); MI, Atlanta (Fulton

County), GA; and Hartford, CT.

17

VIII. Report Conclusions and Recommendations

Large banks and mortgage lenders must be held accountable for the practices of high-cost lending to

low and moderate-income and minority borrowers. One way to accomplish this is through the

modernization of the Community Reinvestment Act grading and examination regulations and by

updating the law itself.

Regulatory Changes:

The four banking regulators have recently undertaken a rulemaking process to update the Community

Reinvestment Act. As this report indicates, the current structure of the law is riddled with loopholes

that need to be closed.

Loan Quality Standards

Specific loan quality standards must be put into place. Charging more for credit is a destructive

practice that certainly does not further the Community Reinvestment Act goal of meeting the credit

needs of the community.

Automatic Failure for Discriminatory Lending

The targeting of the worst credit to low- and moderate-income and minority communities is evidence

of discrimination. Examiners should be specifically tasked with identifying and acting upon evidence

of discrimination in outcomes as well as in practice.

Assessment Areas

As this report makes clear, the current Assessment Area designations are inadequate as they fail to

reflect where banks are making a large amount of their loans to LMI borrowers. Banks should be

examined based on where the company is actively making loans, not where they would like to be

graded.

Affiliate and Subsidiary Lenders

Not including in CRA grading and examination the entirety of a bank holding company’s lending

business, regardless of where in the company that lending occurs, is antiquated and counter-productive

and gives a certain size and class of bank a safe harbor from the law.

18

APPENDIX A. - Home Lending Institutions: Major Banks and their Affiliates and Subsidiaries

The following home lenders were used in the analysis, listed below in order by parent bank name followed by

lender name. All lender institutions listed below were used in analysis of 2006 home lender. For the analysis of

2008 home lending, institutions of Washington Mutual and Wachovia were excluded. Lender name and parent name is reported as it appears in HMDA data.

HMDA ID Lender Name Parent Name

1 0000013044-1 BANK OF AMERICA, N.A. BANK OF AMERICA CORP. 1017362 x

2 0002977601-2 CITIFINANCIAL CITIBANK OVERSEAS INVEST CORP 2544 x

3 0000902270-2 CITIFINANCIAL SERVICES, INC. CITICORP HOME EQUITY, INC. 5417 x

4 0002817118-2 CITIFINANCIAL, INC. CITICORP HOME EQUITY, INC. 12561 x

5 0000014470-4 CITICORP TRUST BANK, FSB CITICORP TRUST BANK, FSB 171262 x

6 0002752321-2 CITIFINANCIAL COMPANY(DE) CITIFINANCIAL CREDIT COMPANY 4854 x

7 0002752684-2 CITIFINANCIAL CORPORATION CITIFINANCIAL CREDIT COMPANY 2338 x

8 0002751801-2 CITIFINANCIAL SERVICES, INC. CITIFINANCIAL CREDIT COMPANY 3670 x








16 0002751968-2 CITIFINANCIAL, INC. CITIFINANCIAL CREDIT COMPANY 5895 x







23 0003103489-2 CITIFINANCIAL MTG CO (FL, LLC) CITIFINANCIAL MTG CO (FL, LLC) 9936 x

24 0061104540-4 CITIFINANCIAL MTG CO, INC CITIFINANCIAL MTG CO, INC 92287 x

25 0003073694-2 CITIFINANCIAL MTG CO, LLC CITIFINANCIAL MTG CO, LLC 5662 x

26 0003106181-2 CITIFINANCIAL CORPO CITIFINANCIAL, INC. 6579 x

27 0002751995-2 CITIFINANCIAL EQUITY SERVI CITIFINANCIAL, INC. 13595 x

28 0002751913-2 CITIFINANCIAL OF VIRG CITIFINANCIAL, INC. 101 x

29 0000001461-1 CITIBANK, N.A. CITIGROUP INC. 255216 x

30 13-3222578-1 CITIMORTGAGE, INC CITIGROUP INC. 729846 x

31 25-1834994-1 AMERICAN ACCESS MORTGAGE, LLC JPMORGAN CHASE BANK 21 x

32 05-0541360-1 BAILEY MORTGAGE, LLC JPMORGAN CHASE BANK 4 x

33 22-3566214-1 CAMBRIDGE MORTGAGE SERVICES JPMORGAN CHASE BANK 294 x

34 0000023160-1 CHASE MANHATTAN BANK USA, NA JPMORGAN CHASE BANK 127534 x

35 20-1961099-1 CHESCO FINANCIAL SERVICES, LLC JPMORGAN CHASE BANK 11 x

36 20-0367622-1 EQUIBUILD MORTGAGE, LLC JPMORGAN CHASE BANK 10 x

37 20-2971210-1 LIFESTYLE MORTGAGE, LLC JPMORGAN CHASE BANK 4 x

38 20-5424817-1 PRIMARY HOME FINANCE, LLC JPMORGAN CHASE BANK 8 x

39 23-3042457-1 PRIME ONE MORTGAGE, LLC JPMORGAN CHASE BANK 28 x

40 20-2356201-1 RESIDENTIAL MORTGAGE GROUP JPMORGAN CHASE BANK 69 x

41 20-2548042-1 SIERRA HOME LOANS, LLC JPMORGAN CHASE BANK 4 x

42 20-2433622-1 SOUTH CENTRAL MORTGAGE, LLC JPMORGAN CHASE BANK 6 x

43 20-0017254-1 TOTAL FINANCIAL SERVICES, LLC JPMORGAN CHASE BANK 14 x

44 52-2335728-1 TOWN AND COUNTRY MORTGAGE, LLC JPMORGAN CHASE BANK 28 x

45 20-4651133-1 URBAN HOME MORTGAGE, LLC JPMORGAN CHASE BANK 74 x

46 20-0258466-1 VALUE MORTGAGE, LLC JPMORGAN CHASE BANK 5 x

47 20-5251727-1 COMMUNITY LIFE MORTGAGE, LLC JPMORGAN CHASE BANK, NA 19 x

48 0000000008-1 JPMORGAN CHASE BANK JPMORGAN CHASE BANK, NA 756551 x

49 0000008551-4 WASHINGTON MUTUAL BANK WASHINGTON MUTUAL, INC 887744 x

50 0330703444-4 LONG BEACH MORTGAGE CO. WASHINGTON MUTUAL, INC. 186401 x

51 0000011905-4 WASHINGTON MUTUAL BANK, FSB WASHINGTON MUTUAL, INC. 839 x

52 0000001741-1 WELLS FARGO BANK, NA WELLS FARGO & CO 1282942 x

53 0001847305-2 WELLS FARGO FIN'L ALABAMA, INC WELLS FARGO & CO 7680 x

54 0001845002-2 WELLS FARGO FIN'L ALASKA, INC WELLS FARGO & CO 3423 x

55 0002039488-2 WELLS FARGO FIN'L AMERICA, INC WELLS FARGO & CO 7947 x

56 0001426027-2 WELLS FARGO FIN'L ARIZONA, INC WELLS FARGO & CO 11632 x

57 0001847275-2 WELLS FARGO FIN'L CALIFORNIA WELLS FARGO & CO 37113 x

58 0001844993-2 WELLS FARGO FIN'L COLORADO INC WELLS FARGO & CO 5751 x

59 0001868177-2 WELLS FARGO FIN'L CRED SERV NY WELLS FARGO & CO 6736 x

60 0001845057-2 WELLS FARGO FIN'L DELAWARE,INC WELLS FARGO & CO 966 x

61 0001845039-2 WELLS FARGO FIN'L GEORGIA, INC WELLS FARGO & CO 6709 x

62 0001847332-2 WELLS FARGO FIN'L HAWAII, INC WELLS FARGO & CO 707 x

63 0001847323-2 WELLS FARGO FIN'L IDAHO, INC WELLS FARGO & CO 3272 x

64 0001845020-2 WELLS FARGO FIN'L ILLINOIS INC WELLS FARGO & CO 14570 x

65 0001844975-2 WELLS FARGO FIN'L INDIANA, INC WELLS FARGO & CO 5145 x

66 0002040381-2 WELLS FARGO FIN'L IOWA 3, INC WELLS FARGO & CO 4642 x

67 0001844966-2 WELLS FARGO FIN'L KANSAS, INC WELLS FARGO & CO 2231 x

68 0001844957-2 WELLS FARGO FIN'L KENTUCKY INC WELLS FARGO & CO 3161 x

69 0001844948-2 WELLS FARGO FIN'L LOUISIANA WELLS FARGO & CO 4101 x

70 0002040402-2 WELLS FARGO FIN'L MAINE, INC WELLS FARGO & CO 1001 x

71 0001844939-2 WELLS FARGO FIN'L MARYLAND,INC WELLS FARGO & CO 4989 x

72 0002266659-2 WELLS FARGO FIN'L MICHIGAN WELLS FARGO & CO 677 x

73 0001844920-2 WELLS FARGO FIN'L MINNESOTA WELLS FARGO & CO 6069 x

74 0003144576-2 WELLS FARGO FIN'L MISSISSIPPI WELLS FARGO & CO 3341 x

75 0001844984-2 WELLS FARGO FIN'L MISSOURI INC WELLS FARGO & CO 5603 x

76 0001844836-2 WELLS FARGO FIN'L MONTANA, INC WELLS FARGO & CO 1654 x

77 0001844331-2 WELLS FARGO FIN'L NEBRASKA,INC WELLS FARGO & CO 2824 x

78 0002040961-2 WELLS FARGO FIN'L NEVADA 2,INC WELLS FARGO & CO 4754 x

79 0001844283-2 WELLS FARGO FIN'L NEW JERSEY WELLS FARGO & CO 4282 x

80 0002040989-2 WELLS FARGO FIN'L NEW MEXICO WELLS FARGO & CO 5486 x

81 0002041007-2 WELLS FARGO FIN'L NO CAROLINA WELLS FARGO & CO 3968 x

82 0001844845-2 WELLS FARGO FIN'L NORTH DAKOTA WELLS FARGO & CO 1363 x

83 0002041034-2 WELLS FARGO FIN'L OHIO 1, INC WELLS FARGO & CO 11640 x

84 0001844827-2 WELLS FARGO FIN'L OKLAHOMA,INC WELLS FARGO & CO 3087 x

85 0001847369-2 WELLS FARGO FIN'L OREGON, INC WELLS FARGO & CO 6270 x

86 0001847378-2 WELLS FARGO FIN'L PENNSYLVANIA WELLS FARGO & CO 14290 x

87 0001847172-2 WELLS FARGO FIN'L RHODE ISLAND WELLS FARGO & CO 855 x

88 0001847163-2 WELLS FARGO FIN'L SO CAROLINA WELLS FARGO & CO 3556 x

89 0001845011-2 WELLS FARGO FIN'L SOUTH DAKOTA WELLS FARGO & CO 1480 x

90 0002134936-2 WELLS FARGO FIN'L SYS FLORIDA WELLS FARGO & CO 21585 x

91 0002135401-2 WELLS FARGO FIN'L SYS VIRGINIA WELLS FARGO & CO 5707 x

92 0003315853-2 WELLS FARGO FIN'L TENN 1, LLC WELLS FARGO & CO 6136 x

93 0001844818-2 WELLS FARGO FIN'L TENNESSEE WELLS FARGO & CO 408 x

94 0001843606-2 WELLS FARGO FIN'L TEXAS, INC WELLS FARGO & CO 26320 x

95 0001843624-2 WELLS FARGO FIN'L UTAH, INC WELLS FARGO & CO 4007 x

96 0002041098-2 WELLS FARGO FIN'L WASHINGTON 1 WELLS FARGO & CO 10362 x

97 0001844265-2 WELLS FARGO FIN'L WYOMING, INC WELLS FARGO & CO 1422 x

98 0002041418-2 WELLS FARGO FINL MASSACHUSETTS WELLS FARGO & CO 2912 x

99 0002040970-2 WELLS FARGO FINL NEW HAMPSHR 1 WELLS FARGO & CO 869 x

100 0001844340-2 WELLS FARGO FINL WEST VIRGINIA WELLS FARGO & CO 2302 x

Loan Applications

Reported (2006)

Major

Bank

Affiliate or

Subsidiary

19

APPENDIX A. - Home Lending Institutions (Continued)

HMDA ID Lender Name Parent Name101 0001844359-2 WELLS FARGO FINL WISCONSIN INC WELLS FARGO & CO 5013 x

102 41-1704421-1 WELLS FARGO FUNDING, INC WELLS FARGO & CO 315132 x

103 20-0617801-1 1ST CAPITAL MORTGAGE, LLC WELLS FARGO BANK, N.A. 10 x

104 20-5338059-1 A G EDWARDS MORTGAGE, LLC WELLS FARGO BANK, N.A. 13 x

105 52-1996388-1 ADVANCE MORTGAGE WELLS FARGO BANK, N.A. 69 x

106 20-2068985-1 ADVANTAGE HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 7 x

107 74-3110518-1 ADVANTAGE MTGE PARTNERS, LLC WELLS FARGO BANK, N.A. 4 x

108 20-4072771-1 ALASKA BEST MORTGAGE, LLC WELLS FARGO BANK, N.A. 18 x

109 20-3075822-1 ALLIANCE HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 12 x

110 20-1823088-1 ALPHA HOME LOANS, LLC WELLS FARGO BANK, N.A. 3 x

111 20-2518656-1 AMBER MORTGAGE, LLC WELLS FARGO BANK, N.A. 6 x

112 72-1459489-1 AMERICAN PRIORITY MORTGAGE LLC WELLS FARGO BANK, N.A. 65 x

113 20-1401376-1 AMERICAN SOUTHERN MORTGAGE SRV WELLS FARGO BANK, N.A. 32 x

114 20-1379530-1 APM MORTGAGE, LLC WELLS FARGO BANK, N.A. 4 x

115 20-4310279-1 ARIZONA COMMUNITY MORTGAGE,LLC WELLS FARGO BANK, N.A. 22 x

116 58-2539277-1 ASHTON WOODS MORTGAGE, LLC WELLS FARGO BANK, N.A. 189 x

117 20-0487675-1 AVENUE FINANCIAL SERVICES, LLC WELLS FARGO BANK, N.A. 1 x

118 20-1401154-1 BELGRAVIA MORTGAGE GROUP, LLC WELLS FARGO BANK, N.A. 12 x

119 20-2069480-1 BELLWETHER MORTGAGE, LCC WELLS FARGO BANK, N.A. 11 x

120 80-0066631-1 BENEFIT MORTGAGE, LLC WELLS FARGO BANK, N.A. 32 x

121 20-3872195-1 BERKS MORTGAGE SERVICES, LLC WELLS FARGO BANK, N.A. 6 x

122 20-1671472-1 BHS HOME LOANS, LLC WELLS FARGO BANK, N.A. 20 x

123 20-0049096-1 BUILDERS MORTGAGE COMPANY, LLC WELLS FARGO BANK, N.A. 54 x

124 91-2120981-7 BW MORTGAGE, LLC WELLS FARGO BANK, N.A. 16 x

125 05-0528802-1 CAPITAL PACIFIC HOME LOANS, LP WELLS FARGO BANK, N.A. 1 x

126 20-3371374-1 CAPSTONE HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 32 x

127 20-4648575-1 CENTENNIAL HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 32 x

128 20-2069641-1 CENTRAL BUCKS MORTGAGE, LLC WELLS FARGO BANK, N.A. 4 x

129 52-1993435-7 CENTRAL FEDERAL MORTGAGE CO WELLS FARGO BANK, N.A. 20 x

130 20-1782538-1 CERTIFIED HOME LOANS, LLC WELLS FARGO BANK, N.A. 23 x

131 20-3677145-1 CHL HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 3 x

132 20-2957317-1 CHOICE HOME FINANCING, LLC WELLS FARGO BANK, N.A. 133 x

133 20-2368435-1 CHOICE MORTGAGE SERVICING, LLC WELLS FARGO BANK, N.A. 8 x

134 20-4221925-1 CITYLIFE LENDING GROUP, LLC WELLS FARGO BANK, N.A. 15 x

135 84-1542642-1 COLORADO MORTGAGE ALLIANCE LLC WELLS FARGO BANK, N.A. 46 x

136 27-0032837-1 COLORADO PROFESSIONALS MORTGAG WELLS FARGO BANK, N.A. 17 x

137 01-0595595-1 DH FINANCIAL, LLC WELLS FARGO BANK, N.A. 28 x

138 20-1001259-1 DISCOVERY HOME LOANS, LLC WELLS FARGO BANK, N.A. 7 x

139 20-1018158-1 EASTERN MORTGAG AUTHORITY LLC WELLS FARGO BANK, N.A. 4 x

140 42-1472314-1 EDWARD JONES MORTGAGE, LLC WELLS FARGO BANK, N.A. 235 x

141 20-5522367-1 ELITE HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 9 x

142 41-2064761-1 ENNIS HOME MORTGAGE, LP WELLS FARGO BANK, N.A. 17 x

143 20-0830196-1 EXPRESS FIN'L & MORTGAGE SERVC WELLS FARGO BANK, N.A. 22 x

144 20-0011823-1 FAMILY HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 14 x

145 20-2069793-1 FIRST ASSOCIATES MORTGAGE, LCC WELLS FARGO BANK, N.A. 10 x

146 20-4436381-1 FIRST COMMONWEALTH HOME MTGE WELLS FARGO BANK, N.A. 19 x

147 20-0749218-1 FIRST MORTGAGE CONSULTANTS LLC WELLS FARGO BANK, N.A. 26 x

148 20-1526290-1 FIRST RATE HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 16 x

149 20-4795415-1 FIVE STAR LENDING, LLC WELLS FARGO BANK, N.A. 3 x

150 82-0564743-1 FOUNDATION MORTGAGE SERVICES WELLS FARGO BANK, N.A. 13 x

151 20-2784791-1 FULTON HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 73 x

152 20-4222161-1 GENERATION HOMES MORTGAGE, LLC WELLS FARGO BANK, N.A. 4 x

153 20-0749370-1 GENESIS MORTGAGE, LLC WELLS FARGO BANK, N.A. 16 x

154 20-4554076-1 GLOBAL GENERAL MORTGAGE, LLC WELLS FARGO BANK, N.A. 8 x

155 74-3110521-1 GOLD COAST HOME MORTGAGE WELLS FARGO BANK, N.A. 21 x

156 33-0858269-7 GOLD COAST MORTGAGE WELLS FARGO BANK, N.A. 5 x

157 20-1401247-1 GREAT EAST MORTGAGE, LLC WELLS FARGO BANK, N.A. 38 x

158 20-4436455-1 GREATER ATLANTA FINANCIAL SERV WELLS FARGO BANK, N.A. 28 x

159 03-0419145-1 GREENRIDGE MORTGAGE SERVICES WELLS FARGO BANK, N.A. 7 x

160 20-3851378-1 GRIFFIN FINANCIAL SERVICES,LLC WELLS FARGO BANK, N.A. 9 x

161 32-0095778-1 GUARANTEE PACIFIC MORTGAGE LLC WELLS FARGO BANK, N.A. 4 x

162 75-3011781-1 HALLMARK MORTGAGE GROUP, LLC WELLS FARGO BANK, N.A. 20 x

163 33-0668396-1 HEARTHSIDE FUNDING, LP WELLS FARGO BANK, N.A. 14 x

164 02-0638418-1 HENDRICKS MORTGAGE, LLC WELLS FARGO BANK, N.A. 20 x

165 20-4361491-1 HERITAGE HOME MORTGAGE GROUP WELLS FARGO BANK, N.A. 7 x

166 20-0790865-1 HEWITT MORTGAGE SERVICES, LLC WELLS FARGO BANK, N.A. 52 x

167 36-4480286-1 HOME LOAN EXPRESS, LLC WELLS FARGO BANK, N.A. 1 x

168 20-4222524-1 HOMELIFE FINANCIAL, LLC WELLS FARGO BANK, N.A. 32 x

169 41-1914032-1 HOMESERVICES LENDING, LLC WELLS FARGO BANK, N.A. 2043 x

170 20-1017813-1 HORIZON MORTGAGE, LLC WELLS FARGO BANK, N.A. 22 x

171 20-2889369-1 HUBBLE HOME LOANS, LLC WELLS FARGO BANK, N.A. 19 x

172 36-4486508-1 ILLUSTRATED PROPERTIES MTG CO WELLS FARGO BANK, N.A. 35 x

173 20-4310371-1 ILUMINA MORTGAGE, LLC WELLS FARGO BANK, N.A. 2 x

174 20-3576214-1 INTEGRITY HOME FUNDING, LLC WELLS FARGO BANK, N.A. 8 x

175 33-0697309-1 JOHN LAING MORTGAGE, LP WELLS FARGO BANK, N.A. 62 x

176 20-4554037-1 JONES & MINEAR FINL SERV, LLC WELLS FARGO BANK, N.A. 5 x

177 20-0305738-1 JTS FINANCIAL, LLC WELLS FARGO BANK, N.A. 7 x

178 20-3207908-1 KD MORTGAGE, LLC WELLS FARGO BANK, N.A. 13 x

179 20-2232700-1 KELLER MORTGAGE, LCC C WELLS FARGO BANK, N.A. 21 x

180 20-3525128-1 LAUREL HILLS MORTGAGE, LLC WELLS FARGO BANK, N.A. 1 x

181 41-2090587-1 LEADER MORTGAGE, LLC WELLS FARGO BANK, N.A. 7 x

182 31-1406492-1 LEGACY MORTGAGE WELLS FARGO BANK, N.A. 199 x

183 33-0875305-1 LINEAR FINANCIAL, LP WELLS FARGO BANK, N.A. 393 x

184 20-2953610-1 MARBEN MORTGAGE, LLC WELLS FARGO BANK, N.A. 9 x

185 20-3243854-1 MASTER HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 5 x

186 36-4477404-1 MAX MORTGAGE, LLC WELLS FARGO BANK, N.A. 19 x

187 20-0482176-1 MC OF AMERICA, LLC WELLS FARGO BANK, N.A. 14 x

188 20-4795336-1 MCZ/CENTRUM MORTGAGE CO, LLC WELLS FARGO BANK, N.A. 3 x

189 04-3612766-1 MERCANTILE MORTGAGE, LLC WELLS FARGO BANK, N.A. 250 x

190 74-3082948-1 MERIDIAN MOME MORTGAGE, LP WELLS FARGO BANK, N.A. 27 x

191 36-4475681-1 MJC MORTGAGE COMPANY, LLC WELLS FARGO BANK, N.A. 9 x

192 06-6130942-1 MORRISON FINANCIAL SERVICES WELLS FARGO BANK, N.A. 150 x

193 16-1661962-1 MORTGAGE 100, LLC WELLS FARGO BANK, N.A. 8 x

194 34-1842620-7 MORTGAGE ONE WELLS FARGO BANK, N.A. 28 x

195 04-3721145-1 MORTGAGES ON-SITE, LLC WELLS FARGO BANK, N.A. 67 x

196 47-0896939-1 MORTGAGES UNLIMITED, LLC WELLS FARGO BANK, N.A. 9 x

197 65-0904482-7 MSC MORTGAGE, LLC WELLS FARGO BANK, N.A. 41 x

198 30-0073253-1 MUTUAL SERVICE MORTGAGE, LLC WELLS FARGO BANK, N.A. 5 x

199 20-2992559-1 NATIONAL CONDO LENDING, LLC WELLS FARGO BANK, N.A. 14 x

200 20-0617912-1 NDC FINANCIAL SERVICES, LLC WELLS FARGO BANK, N.A. 16 x

Loan Applications

Reported (2006)

Major

Bank

Affiliate or

Subsidiary

20

APPENDIX A. - Home Lending Institutions (Continued)

HMDA ID Lender Name Parent Name201 20-3059656-1 NEW WEST MORTGAGE SERVICES,LLC WELLS FARGO BANK, N.A. 7 x

202 42-1449557-7 NEXT HOME MORTAGE WELLS FARGO BANK, N.A. 4 x

203 20-4795531-1 NHI HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 6 x

204 20-2339107-1 NORTHWEST HOME FINANCE, LLC WELLS FARGO BANK, N.A. 19 x

205 34-1846468-7 OHIO EXECUTIVE MORTGAGE CO WELLS FARGO BANK, N.A. 8 x

206 20-3401142-1 PACIFIC COAST HOME MORTGAGE WELLS FARGO BANK, N.A. 6 x

207 20-3539651-1 PAGEANTRY MORTGAGE, LLC WELLS FARGO BANK, N.A. 27 x

208 20-2784662-1 PARAMOUNT MORTGAGE OF POLK CO WELLS FARGO BANK, N.A. 13 x

209 20-2392456-1 PARKWAY MORTGAGE FINANCIAL CTR WELLS FARGO BANK, N.A. 13 x

210 20-0233909-1 PCM MORTAGE, LLC WELLS FARGO BANK, N.A. 93 x

211 20-1823155-1 PEAK HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 3 x

212 36-4483896-1 PERSONAL MORTGAGE GROUP, LLC WELLS FARGO BANK, N.A. 46 x

213 88-0419519-1 PINNACLE MORTGAGE OF NEVADA WELLS FARGO BANK, N.A. 38 x

214 20-4318400-1 PLATINUM RESIDENTIAL MORTGAGE WELLS FARGO BANK, N.A. 6 x

215 20-0940438-1 PLAYGROUND FINANCIAL SERVICES WELLS FARGO BANK, N.A. 28 x

216 20-3207833-1 PNC MORTGAGE, LLC WELLS FARGO BANK, N.A. 3420 x

217 20-1304561-1 PRECEDENT MORTGAGE, LLC WELLS FARGO BANK, N.A. 1 x

218 20-0052711-1 PREMIER HOME MORTGAGE WELLS FARGO BANK, N.A. 5 x

219 20-0013136-1 PRIVATE MORTGAGE ADVISORS, LLC WELLS FARGO BANK, N.A. 104 x

220 20-0479222-1 PROFESSL FINL SERVS OF ARIZONA WELLS FARGO BANK, N.A. 8 x

221 65-1113234-1 PROPERTIES MORTGAGE, LLC WELLS FARGO BANK, N.A. 13 x

222 54-1685390-7 PROSPERITY MORTGAGE COMPANY WELLS FARGO BANK, N.A. 2272 x

223 06-1645233-1 PROVIDENT MORTGAGE COMPANY LLC WELLS FARGO BANK, N.A. 1 x

224 59-3365197-1 REAL ESTATE FINANCIAL WELLS FARGO BANK, N.A. 2 x

225 95-4833804-7 REAL ESTATE LENDERS WELLS FARGO BANK, N.A. 9 x

226 04-3588591-1 REAL LIVING MORTGAGE, LLC WELLS FARGO BANK, N.A. 199 x

227 20-1001630-1 REALTEC FINANCIAL SERVICES LLC WELLS FARGO BANK, N.A. 2 x

228 04-3594252-7 REALTY HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 24 x

229 42-1526507-1 RELATED FINANCIAL, LLC WELLS FARGO BANK, N.A. 93 x

230 20-0315363-1 RESIDENTIAL COMT'Y MORTGAGE CO WELLS FARGO BANK, N.A. 54 x

231 20-0011291-1 RESORTQUEST MORTGAGE, LLC WELLS FARGO BANK, N.A. 28 x

232 20-1665277-1 RIVER CITY GROUP, LLC WELLS FARGO BANK, N.A. 50 x

233 20-2594480-1 RIVERSIDE HOME LOANS, LLC WELLS FARGO BANK, N.A. 10 x

234 91-2141825-1 RODDEL MORTGAGE COMPANY, LP WELLS FARGO BANK, N.A. 22 x

235 72-1604171-1 RUSS LYON MORTGAGE, LLC WELLS FARGO BANK, N.A. 28 x

236 20-3207725-1 RWF MORTGAGE, LLC WELLS FARGO BANK, N.A. 12 x

237 74-2949159-7 SANTA FE MORTGAGE, LLC WELLS FARGO BANK, N.A. 46 x

238 80-0066627-1 SECURITY FIRST FINL GROUP, LLC WELLS FARGO BANK, N.A. 65 x

239 20-1068765-1 SECURSOURCE MORTGAGE, LLC WELLS FARGO BANK, N.A. 20 x

240 20-1888739-1 SERVICING MORTGAGE COMPANY LLC WELLS FARGO BANK, N.A. 12 x

241 20-1823399-1 SILVER STATE HOME FINANCIAL LL WELLS FARGO BANK, N.A. 5 x

242 39-1871324-7 SKOGMAN MORTGAGE COMPANY WELLS FARGO BANK, N.A. 17 x

243 54-0737619-1 SKYLINE HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 5 x

244 20-0479324-1 SMART MORTGAGE, LLC WELLS FARGO BANK, N.A. 16 x

245 22-3889307-1 SMITH FAMILY MORTGAGE, LLC WELLS FARGO BANK, N.A. 11 x

246 75-3011794-1 SOUTHEAST HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 36 x

247 20-3981881-1 SOUTHEAST MINNESOTA MORTGAGE WELLS FARGO BANK, N.A. 12 x

248 02-0647942-1 SOUTHERN OHIO MORTGAGE, LLC WELLS FARGO BANK, N.A. 23 x

249 58-2531174-7 SPH MORTGAGE, LLC WELLS FARGO BANK, N.A. 162 x

250 20-0830019-1 STEINBECK ADVANTAGE MORTGAGE WELLS FARGO BANK, N.A. 6 x

251 42-1570515-1 STOCK FINANCIAL SERVICES, LLC WELLS FARGO BANK, N.A. 24 x

252 20-0772714-1 STONERIDGE MORTGAGE, LLC WELLS FARGO BANK, N.A. 4 x

253 20-1671394-1 SUMMIT NATIONAL MORTGAGE, LLC WELLS FARGO BANK, N.A. 16 x

254 20-4557612-1 SUNBELT FUNDING SERVICES, LLC WELLS FARGO BANK, N.A. 3 x

255 20-1207590-1 SUNSOUTH MORTGAGE, LLC WELLS FARGO BANK, N.A. 1 x

256 20-1018313-1 TOUCHSTONE HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 8 x

257 20-2070075-1 TRADEMARK MORTGAGE, LLC WELLS FARGO BANK, N.A. 35 x

258 20-0749298-1 TRIPLE DIAMOND MORTGAGE & FINL WELLS FARGO BANK, N.A. 3 x

259 42-1520259-7 UBS MORTGAGE LLC WELLS FARGO BANK, N.A. 356 x

260 20-0130222-1 UNITED MICHIGAN MORTGAGE, LLC WELLS FARGO BANK, N.A. 1 x

261 20-5124553-1 VILLAGE COMMUNITIES FINANCIAL WELLS FARGO BANK, N.A. 5 x

262 20-5337985-1 VILLAGE MORTGAGE, LLC WELLS FARGO BANK, N.A. 4 x

263 20-0167002-1 VISTA MORTGAGE, LLC WELLS FARGO BANK, N.A. 2 x

264 20-2957478-1 WASHINGTON MORTGAGE, LLC WELLS FARGO BANK, N.A. 23 x

265 20-0666038-1 WATERWAYS HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 3 x

266 20-5284590-1 WCI MORTGAGE, LLC WELLS FARGO BANK, N.A. 27 x

267 99-0332905-1 WELLS FARGO HOME MORTG HAWAII WELLS FARGO BANK, N.A. 1018 x

268 20-0883590-1 WF/TW MORTGAGE VENTURE, LLC WELLS FARGO BANK, N.A. 52 x

269 20-0830091-1 WINDWARD HOME MORTGAGE, LLC WELLS FARGO BANK, N.A. 59 x

270 20-4361405-1 WINMARK FINANCIAL, LLC WELLS FARGO BANK, N.A. 21 x

Loan Applications

Reported (2006)

Major

Bank

Affiliate or

Subsidiary

21

APPENDIX B. - CRA Reporting Institutions

The following banks were used in the analysis of CRA reporting institutions. Assessment areas were

determined as listed in the most recent CRA examination of the reporting institution available via the bank

regulator's website. Only CRA examinations within the last ten years (since 2000) were used in this analysis.

Note: the banks reporting in CRA do not necessarily correspond to home lenders reported in HMDA.

Major Banks and their CRA-covered institutions:

Bank Holding Company / Parent Company Name Bank Name Regulator

Wells Fargo Bank, Na OCC

Wells Fargo Bank Northwest, Na OCC

Wells Fargo Financial NB OCC Wells Fargo & Company

Wells Fargo Financial Bank FDIC

Citibank, N.A. OCC

Citibank USA, N.A. OCC

Citibank, Federal Savings Bank OTS

Citibank (West), FSB OTS

Citibank (New York State) FDIC

Citibank (South Dakota), N.A. OCC

Citicorp Trust Bank, FSB OTS

Citibank (Banamex USA) FDIC

Citigroup, Inc

Citibank (Delaware) FDIC

Bank of America Corp. Bank Of America, N.A. OCC

JPMorgan Chase Bank, N.A OCC

Chase Bank Usa, N.A. OCC

JPMorgan Chase Bk FRB JP Morgan Chase & Company

J.P. Morgan Trust Company, N.A. OCC

22

APPENDIX C. - Major Banks and Affiliates Home Loans by CRA Assessment Area, 2006 & 2008

Wells Fargo 2006 Loans2006 High-Cost Loans

2008 Loans2008 High-Cost Loans

08 LMI Loans08 High-Cost

LMI Loans

In Assessment Area 409,028 62,890 495,737 37,889 495,737 37,889

In Primary AA 165,009 19,298 205,527 12,059 205,527 12,059Out of AA 407,166 94,098 442,282 42,146 442,282 42,146Totals 816,194 156,988 938,019 80,035 938,019 80,035

% IN AA 50.1% 40.1% 52.8% 47.3% 52.8% 47.3%

% in Primary 20% 12% 22% 15% 22% 15%

JPMorgan Chase 2006 Loans2006 High-

Cost Loans2008 Loans

2008 High-

Cost Loans08 LMI Loans

08 High-Cost

LMI Loans

In Assessment Area 284,390 51,623 359,188 31,176 91,694 12,112In Primary AA 137,035 24,710 181,892 14,830 43,116 5,632

Out of AA 112,572 24,903 142,552 13,032 56,682 6,000Totals 396,962 76,526 501,740 44,208 148,376 18,112

% IN AA 71.6% 67.5% 71.6% 70.5% 61.8% 66.9%% in Primary 35% 32% 36% 34% 29% 31%

Bank of America 2006 Loans2006 High-

Cost Loans2008 Loans

2008 High-

Cost Loans08 LMI Loans

08 High-Cost

LMI Loans

In Assessment Area 374,511 9,952 526,817 26,776 113,842 9,418In Primary AA 179,954 3,788 274,366 12,754 45,726 3,994Out of AA 52,259 2,695 43,283 2,590 8,156 696Totals 426,770 12,647 570,100 29,366 121,998 10,114

% IN AA 87.8% 78.7% 92.4% 91.2% 93.3% 93.1%

% in Primary 42% 30% 48% 43% 37% 39%

CitiGroup2006 Loans

2006 High-Cost Loans

2008 Loans2008 High-Cost Loans

08 LMI Loans08 High-Cost

LMI Loans

In Assessment Area 145,109 22,186 152,494 12,946 29,263 5,285Out of AA 197,789 87,827 145,066 50,007 46,497 26,771

Totals 342,898 110,013 297,560 62,953 75,760 32,056% IN AA 42% 20% 51% 21% 39% 16%

23

APPENDIX C. (Continued)

JPMorgan Chase Home Loans by CRA Assessment Area, 2006 & 2008

CA

TX

NY

FL

IL

PA

OH

MI

NJ

GA

NC

VA

MA

IN

WA

TN

MO

WI

MD

AZ

MN

LA

AL

CO

KY

SC

OK

OR

CT

IA

MS

KS

AR

UT

NV

NM

WV

NE

ID

ME

NH

RI

MT

DE

SD

ND

VT

WY

Map layers County Limited Scope Assessment Area

Full Scope Assessment Area

JPMorgan Chase Home Loans

30000

15002.5

5Home Loans 2006Home Loans 2008

Bank of America Home Loans by CRA Assessment Area, 2006 & 2008

CA

TX

NY

FL

IL

PA

OH

MI

NJ

GA

NC

VA

MA

IN

WA

TN

MO

WI

MD

AZ

MN

LA

AL

CO

KY

SC

OK

OR

CT

IA

MS

KS

AR

UT

NV

NM

WV

NE

ID

ME

NH

RI

MT

DE

SD

ND

VT

WY

Map layers CountyLimited-Scope Assessment Area

Full-Scope Assessment Area

Bank of America Home Loans 2006 & 2008

50000

25005

10Home Loans 06Home Loans 08

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