UEDC/ CRA Proposal

This is a summary of complaints by UAAD pertaining to JPMorganChase Bank


While lobbying Congress and the Office of the Comptroller of the Currency (OCC) regarding JP Morgan/Chase Bank’s non-compliance of the Community Re-Investment Act of 1977 (CRA) a Civil Rights Legislation, the following is my report:

The purpose of lobbying was to present proposals that United Affirmative Action Development Corp (UAAD) a 501c3 non-profit community organization, wished to express of how funds in excess of $800 billion dollars Chase Bank have committed towards fulfilling it’s obligation under CRA can assist the Katrina victims.
It was discovered in talking to the Republican side of the House, that if proposals to strengthen this legislation were proposed, it is likely that they will kill the CRA legislation. Therefore they believe that it will do more good if it is left intact, with little or no enforcement power. Some Democrats take the same position. I was told also that UAAD’s complaint against Chase Bank would be better served if all banks that were not in compliance with CRA were a part of this complaint. I indicated that due to Chase Bank being the largest financial institution in the State of Louisiana, and had what we believe to be a very poor rating in serving the African American Community, our intent was to make Congress, the FDIC, OCC and the world aware of how “this” bank caused and manifested the poverty and lack of financial parity in the minority community “this” bank should have served. Had Bank One negotiated in good faith rather than bad faith in 1995 upon accruing Premier Bank of Louisiana, it is my and others' belief that the poverty that exists in Louisiana would have been diminished.(see FDIC/OCC complaint) Chase Bank in their lack of commitment to CRA has only plagiarized UAAD’s and other community organizations' CRA proposals and presenting them in their Community Partnership presentations as though they are attempting to comply to this important Civil Rights legislation. The purpose of CRA was to eliminate the red-lining and discrimination in the minority communities. Banks, Congress, and federal regulators after Katrina are allowing these victims to further suffer. Chase Bank states that they have provided in excess of $69 billion of the $800 billion they have committed of their CRA funds since April 2004 to the community they serve. After numerous complaints a Shreveport Louisiana Branch of Chase Bank reported that they created division called "Chase Home Finance" and staffed it with a Community Lending Officer. Before this officer was appointed by the bank, UAAD asked for information from Ms. Charlita Cloman VP Community Partnership Mgr. Community Development Group as to how this program worked and how it could assist African Americans under CRA. Ms. Cloman stated she did not have any written proposal she could give UAAD, but that I would have to write a proposal expressing what UAAD had accomplished in developing low income housing etc. Ms. Cloman stated that once UAAD submits a proposal the bank would consider funding. Two weeks ago I met with Ms. Daphne G. Childress the Community Lending Officer / Northern Louisiana who stated she had been in this position for approximately six months and had made in the range of $600-700,000.00 in loans during this period. I asked if she was aware that Chase Bank has committed and spent in other areas approximately $69 billion dollars. When asked if Community Organizations as advised under CRA could assist her and the bank in carrying out their commitment she agreed.
The sooner Chase Bank makes a commitment to African Americans as it has to others, the sooner economic parity will be obtained. Chase Bank should not meet the requirements of CRA mainly because of this legislation. They should feel obligated to serve the needs of the entire community no matter of color or gender. Mr. Mizell Scott who serves as Vice President of Chase Bank's CRA for the State of Louisiana expresses the views of Chase Bank when he has stated on more than one occasion that it is his and Chase Bank’s view that CRA was not meant for African Americans, and Chase Bank doesn't have to adhere to UAAD’s views. Mr. Scott and other Chase Bank CRA officials also express that they are proud of Chase Bank's CRA performance.
According to the latest CRA Performance Evaluation March 31, 2004 by OCC, in my opinion, the State of Louisiana must have the worst report of all the states in which Chase Bank operates. See: www.uedcinc.com/id18.html According to the same report it is recommended by the OCC that Chase Bank should involve community organizations in order to improve their performance. See: http://www.uaadcorp.com/ for more information regarding this complaint.

What is the purpose of the OCC/FDIC?

In 1998 UAAD filed a complaint against Bank One due to bad faith negotiations, and its lack of compliance to CRA. This complaint addressed in particular its practice of discriminating against African Americans. Several other complaints have since been filed. The OCC is responsible for enforcing and listening to such complaints.
The complaint filed in 1998 the OCC recommended that this non-profit hire a Lawyer. E-mails sent regarding UAAD’s complaints recently were unanswered or the answer did not address the issue UAAD was pursuing. Upon attempting to get a clarification on whether Chase Bank was in violation of 12CFR25.43 pertaining to disclosure of the banks public records, conflicting information came from the OCC Houston, Texas office. First I was denied to speak to Ms. Delora Jee who is stated to be The CRA Deputy Comptroller who in charge of JP Morgan Chase Bank compliance to CRA. After discussing with Ms. Jee that one of the reasons I had come to Washington, DC was to meet and present a CRA complaint regarding Chase Banks non-compliance of the CRA regulations, to include 122CFR25.43, Ms. Jee stated she was not the proper official to present this type of complaint, and went on to say that her position would be compromised, due to her being the Deputy Comptroller overseeing Chase Banks CRA involvement. At least that is what I understood her to say. I asked her who in the OCC was there to protect the interest of the community. Ms. Jee first stated UAAD would have to file its complaint with the Houston, Texas office. I related to her that I felt I was being given the run around by her and others, due to the Supervisor in the Houston office had previously told me that complaints regarding CRA had to be filed at the Washington, DC location. Later in our discussion Ms. Jee stated that they did have an OCC representative whose name was David Lewis. Ms. Jee stated she would have Mr. Lewis get in touch with me via cell phone, but did not say when. It was also indicated that the FDIC / OCC usually don’t take such complaints until a merger take place.

From the conversation held with the Deputy Comptroller of CRA for Chase Bank I would suggest that those having issue with Chase and their banks branches disclosure of their CRA performance should demand that these institutions have on file for public view “all” complaints, which is required under 12CFR25.43 of the CRA regulations. It is UAAD’s intent to present our and others complaints to various branches, publicize and ask the public and media to view such complaints. Ms. Jee advised that the purpose of Mr. Lewis’s assignment to the Louisiana area was to address CRA compliance problems with various banks. UAAD will insist that OCC representatives such as Mr. Lewis investigate and make our organization aware of any actions that are taken.

I would imagine that those who are concerned about Katrina victims and others suffering from banks poor and lack of performance in the African American Community should tell these victims that they will have to wait until Chase Bank decide to expand its predatory influence to other areas, before Community Organizations can complain to the Federal authorities about their contributing to their adverse condition. Than we should advise these poor souls that it is not likely that anything will be done in the future, based on what the FDIC and OCC’s poor performance in the past when banks are allowed to discriminate against African Americans in particular, with the support of the Federal Government and Congress.
This so-called Civil Rights Legislation called the Community Re-Investment Act was only passed with stipulations that these racist financial institutions can continue to do business as usual. Now the Republicans, and some Democrats are saying that they can live with it as written, as long as it benefits those it wasn’t intended. How could it have been considered a part of the civil rights legislation, when it was meant for the Banks to continue their racist practices? Why would Congress support the wrongful doings of Chase Bank to provide billions of dollars to Caucasians under the guise of CRA while the poverty stricken African Americans are suffering and were doing so long before Katrina due to Chase Bank’s and their CRA officials version of CRA. Why will this government continue with the deficit in the trillions of dollars not enforce Chase Bank to provide funding to African Americans as they have always provided to Caucasians since banking was formed in America.
Without dwelling in the past, why doesn’t this government insist that all regulations are adhered, whether they benefit African Americans or others? After this administration’s poor performance and lack of performance in the African American Communities past and present, it is time for this administration and congress to provide the necessary leadership, to allow all an equal opportunity and a share of the wealth. With equal opportunities African Americans will become gainfully employed, rather than under-employed and in a larger degree un-employed. The prison population will decrease to a great degree, with equal opportunities jobs will be obtained, education in the minority community will increase, and our society as a whole will benefit.

UAAD and several other Community and Civil Rights Organization are building coalitions to address these particular problems. We ask that Congress hear our plea.

We ask that Congress hold hearings regarding CRA and the lack of African Americans participation in this economy.

We ask that UAAD and this Coalition be put on the agenda for the hearings addressing the Katrina Victims.

UAAD ask those receiving this complaint and solutions reply with suggestions on all or a portion. Comments you agree or don’t agree are welcomed.

UAAD’s and many of it’s Partners believe that a resolution of the mentioned complaints will provide some solutions, that will benefit African Americans, and all Americans. see: http://www.uaadcorp.com/ for more information regarding this complaint and solutions.