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Home My WebLink AboutM-86-0942Cr" OF MIAMI, MORIDA INTEROFFICE M CM ORANDUM1 .87 WTO: Cesar H. Odio DAM November 6, 1966 City Manager SUWECT: FUNDING OF CITY { PROJECTS "I'le ��awkIns REFERENCEP: Vice Mayor EWCLOSVPFF: See Attached Please schedule on the November 13th Agenda a discussion item regarding the removal of City funds from depository banks which refuse to finance City projects in distressed areas. _ 0 al cc: Honorable Mayor and City Commission Members Albert Ruder IA ,a, tit �•a�J r. }r. i .- �j�' - ' r• Ny s t J 2 e ` t .,�•!- , v. f �' rTl_ j r•* .-�C` �, t[� �f rr r i �Yf xj, �.a r t . f! i f + 1 t.• t f-4S'�."tt r.r ', y y,.�J ,•r .. i•JS xx S ,.2 'r+,r; t.: rs .e. ',. x e� v ris5�,� ^f''�'�Sr s' > ' ,x r y �.�y,N � 1 4,.Y n.` y f �,�f i{f• '.,.,{yy iC �r .0 fJ Il'_:.•t+i$? .�: .,C. �-i'y'. �1t��::i-..�-1� ,� a. ��• �} '. ��f, 4 ��S .c✓x-rt-a."->+ '. K Gt�V��r+�—alJn''"rx •�y•rN r •;!- .x.J i• t',�f,� � t j� x ! f ' y?y ,i , `, �. !tr .!e• •.i r3'��"a ,'� � r :�<'F' _ fN 'F'f ^Vlrt atrf i'+pr+ tt• , 1� ��; - J� - yArti} � rie �g }�jr "� icy � � � r n y} f ^ , '•' 1 r { G �, i- ,s `,�i"-yam � . -' .• � '� �:Y s�y'✓�r" r LSr. ti � + 1' , ' ... . ry r j.. ...,. .. r 1 � Jy�'T�'t�i��.F,�¢�� t� �� 6 - - t �„p3✓ .. r � .v. .1.}., ,ti`. }*�;%.4�xpw iwrk, 2.�•!�"yyc --�..1,,,,,.,,�, yy�'a:l:.s ,.ti•-i / ,... z.. � ! , i ,. A n. � r . � ... „ v.. . •'t . i x JF ,� � rw ..- •.-4 -'° -- ar•:sta i..E'%'a}gY"'apt".1t�''43'_.X`1'�.s9"'r4i �y+.L'./ .t - INTIR-OFFICE MjEM0RAPtf VM October �3. 1966 �- Vice, Mayor Dawkins osTsr _ :,I fp Service o OCT 21 Carlos E. roarcia ncrtMENCcs: 1956 'ROM Director of Finance c"CLOSUNts: C,QMM. MILLER D%• WKINS 17A C7 id sis orm per our request. Please find attached hose banksbbeingacalledf for As P y qualified that is currently City investments. Any bank that i can apply bids by finance on "Public Depository by the State of Florida as As required by the City Charter, for City in vestmen ts. in vestm�n is are Dade with the bank offering the highest return o the City. i s a list of investments held by banks as of August Also attached 31. 1986. he City's depository bank. NCNB which is under Additionally, t ervices to the City through contract to Provide banking s Dec ember. 1987 holds approximately ,000 in compensating balances as compensation for their services. CEG:hb Enclosures TO: MAYOR AND MEMBERS OF THE COMM18810 N F. Y.1. jSat.0 TRANSMITTAL. DATE ---....--rr:-- '*•• -.. -'�+�" ter; .�__-•^;...�r�i,•�!+ar:..�-;4i:r.TT'�-'---,:c-r•'^T+r"i+.�-:-�--�- .�, - 'i• :r .ice. ••(... • .v Vr , d , !r' •, - j. t i, .r - r*��. syic;ti�r! ayt/�i[�'1'C,:Fr��``�jr, �sttit.�'?Y�r�,•rj�'li"'s:f.lt!ri,�'i,;ti''.•r a4?r:•;,l';��•j!,�y, �"�: ii;�i�G' y'�rJw}`i 'ro+a•.. �. %,y. �1��.. �'i t �.... } •••r•, br •.Sy t .�-.� N��+��' _e 4.r lVitr :3�5. ' 'i,a .• �`• .. _., / .. y ; � � t 1 tr ��+i� � i 1,.%X �` �? r71 irtr ..Y .`+ 1 . - r t t i _.r rw •f rt,k r. - _ } • 1 / � ior t. . F»•{' Yk+�-•!�S ,af + P.? 33 .. �t.:hs }?....2 ! ia.x t r. t•:_„ .-.... t• .. ,.F 7. i. i•iiI x ,.. - ." t \ 1 rr , .�- .• r •L.1 }F.• .i ' ii4: .r .-. r .. .1 "•.. • 'Y "' taiit�d,�u. aria w li' 1 i.n •�a devised 7/2/86 DID AKALTSIS Bid ! Available Matures Days_ Amount Bid Cior•. 1) 4) 5) 66) .,. nANKS STDDED ii/►Tr C—&pFvT7an'k'oF Miami Mr. DurNe 759-4321 ntercQh inentD an Eddie 577•-0711 Commerce an k.. .ri N.A. _ .. Jose R. Gutierrez 444 -5948 merican avings & Loan Mr. klorrls 673-OD05. I • Fininsul-aa 51& s s oc - Steve 377•-6936 • enae eoralSeL Al Alonso Jr. 358-2122 I Hemisphere flat 1 1 Bank'56-5600 .-.. Jorge Martinez or Odalis Var a. on a flatlon3l Bank .Mark Gibson 1-800-342-2049 ; Freedom Savings 432 00 2Z9-0327 .Valerie G. Ko uti- xt I I Fonc_e_727e Leon fed. h L Assoc. , .Yvonne Santa Maria 442-1220 Atlantic e era 6 Grecia Hernandez 374-1776 nternat onal 3 A L Chris Karamat 374-1700 st American Bank rust Carolyn Greaves 666-1500• .t ota an Dr. Morales -Gomez 358-0241 'Floriaa r Federal Keith M. Embree 1-800-282-6531 Rerrilr LynchCapital arkets ' All son 11. West 285-1000 Nine a er arasota Peter Clemeres 379-6000 I mitn arney Joanna Mora 379-1000 (• anu acturers anover Money Mar e Joe Ma 1-800-228-1085 ' I ru ent a as a SecUrIties Carole J. Wilson 447-1353 • Rs R N 86--942 BANK SUMMARY REPORTS OF TIME DEPOSITS AS OF AUGUST 319 1986 PRINCIPAL s OF AMOUNT TOTAL CAPITAL BANK OF MIAMI $1495009000 20.8% INTERCONTINENTAL BANK 19,500,000 25.2% PONCE DE LEON FEDERAL 4,000,000 5.8% GLENDALE FEDERAL S & L 1798009000 24.1% PENINSULA FEDERAL S & L 39700,000 5.1% HEMISPHERE NAT'L BANK 41000,000 5.8% TOTAL BANK 9,300,000 132% i TOTAL s72,800,000 .100% 0 0 0 - --- ------ K CF:9 0 fil 01 S K. 0111 State General Contractors 595-7097 October 30, 1986 Mr. Miller Dawkins Commissioner, City of Miami. "BANKS NOT INTERESTED IN LENDING IN LOW INCOME" AREAS." Centrust Bank: Will only lend $1 Million or over. This practice will only help big developers and not the small developers and builders. Intercontinental Bank: Not interested. Capital Bank: Not interested. Will only give residential second mortgage. PS: We will inform you of all the banks in this community that neglect lending in Low income areas. IV F . ............. . . . . . . . . . . . . . . . . ri f v, H.. 4'f Z. 4 awk A <.:_.... !_:Sl._`•'_+trta.32a•wk c..-%A _! .r.t.s.. -_... ._ __. ,.t ..< - k ;.,.. `c'^r ._-�. 11 �J STATE GF.NFPA,L CONTRACTORS 11531 S.W. 93rd STREET # WEo_kitt FLORIDA 33176 TELEPHONE: (310S) FPS-7097 August 18, 1966 Carlos Sanchez, Vice President General Federal Savings and Loan Association P. O. Box 350636 Miami, FLorida. 33135 RE: Mortgage Loan Application for: 5513 N. E. Miami Place. (14 Unit) and 21 N. W. 59th. Street. (8 Unit) Dear Air. Sanchez: In connection with the above referenced loan application you will recall that I made mortgage loan applications for both of these properties, however, without explanation the bank turned down my request for a loan. However, Mr. Alfredo Duran an officer in your bank, suggested that a mortgage application should be made to Freddie Mac for these two properties. This application was channeled through your bank. An application fee of $3,000.00 was o_aid and several months passed before we finally heard that these mortgage applications had also been unjustifiably denied. A second request for financing, was then re -submitted to vo»r bank and again the bank without ex- planation denied the moi•tga(;e loan applications. It is only fair that after 'wasting several months of tifr,e and not having satisfactc:. explanation for the denial of both good property and our good credit worthiness that we be refunded the full $3,000.00 application fee. Should you have any questions, please call. PP: rig Sincerely, e ro a aez --r---- •csrr."--. •ate :,' ., :�•;.; d. .7. . _ _ :.i.. .;�^° .K L _ — ' •�� r, 3 j r , '• wry ~ + !�`J � t t .a. � f �i� {N;..�;•� ,,,, y'iw _Y. _ _;a. ,yiy._,, FJkr^.y' .P4„f: 'S •Fro, �yt �n',y,`-�+�,k'.,''$..i•,��t,:%,�; ��i.+�� `,�,:�.: �!t."��'``�.�''w.— �i, 2;.x} ie.k�.. `.s - �''-�'..c l;-.: ,:7. a'. .i. �� a�. ., ' :i�s�'"''i �',i_ � •,�• ,.rig' ti"''� . .. :�� _ ,fir.. .. ,.. ...4... ' � i�1•�� t.Pt .+ � � i ; ..< ' , � � r - �r � Est t 4 , a- ;(,� 'y'''.. �3j'~%��r V , •:T f-. ♦ 1:' : .. r a t ,�. y�,..iY� 1$'"i c«. .fit %iy�� A: � � 2 � t y r J � i.�: r r; �=• t�'^t u Y � ^c " +�r! 1 .t�'... ..4.., �,..f,,..�t.fv. ,�c�.. ..-. .,..�R�! ... .. ..,•d�.:--i.,t y Jt«�rnYb�"J.xr "z"c �i ��r,, �.��'. i H/ "' �'f; �'f.(.5-�1� .lf��y .� Tom. .. � � _ w•Y - _�'`x'�, 14.3 J 0 4, 5r STATE GENERAL CONTR AC -TOPS 11531 S.W. 93rd STREET • VlAw", FLOPIDA 33176 TELEPh ow-: (-in.;) 5? �-1 00_7 September 12, 1986 General Federal Savings & Loan Assoc. 5915 Ponce de Leon Boulevard Coral Gables, Florida. 33146 Attn : *sir. Alf redo Douran RE: Mortgage Loan Application for: 5513 N. E. Miami Pl. (14 Units) 21 N. 11. 59th St. (8 Units) Dear. M,r. Duran: In connection with the above referenced loan application you is will recall that I made mortgage loan applications for both of these properties, however, without explanation, the bank turned down try request for a loan. However, your bank, suggested that a mortgage application should be made to Freddie Mac for these properties. This appli- cation was channeled through your bank. An application fee of $3,000.00 was paid and several months passed before we finally heard that these mcrtgages applications had also been unjustifiably denied. A second request for financing Was them re -submitted to your bank and again the bank without explanation denied the mortgage loan applications. it is only fair that after wasting .several months of time and not having satisfactory explanation for the denial of both good property and our good credit worthiness that we be refunded the full $3,000.00 application fee. The only conclusion that can be drawn for your banks actions are that since the properties lie in a predominantly black neighborhood, that the bank is reluctant to lend against this property, in other words the bank has "red lined" my property. Should you have any questions, please call. Sincerely, PP :r.:a .y�. :Z)kflj. ly 12 tl",:: /sl••,,r''t,, L,. -'tJ: 'i ,. tty j`�-,•t. 'I. :il�t �`T �li `^ti�. i , `t, 1. te}$i .i � tactic}S \�I T�P'rI'; �r ly��l i�tt.�'v+�`'Yf?•��"�YZ •'p I � • ; u1�{.'G f •t'jr ^�v %�}�. � � .f.. 1• �� Y- -r .�.: �, Ic f. -.. _..�.... - ,.. .. ... - .. w _ .. r .. r t ti .L '� ��' („i tl f♦ lf„y r � r^. ; aa�a. .i tr :qf� y '9- t.+yi'xke pp 1 \.. .• .iF tl J �1 }�S 11 - �'� q`s1. �d zE$- � l + ' % {r -�y� " �--�4 ` $ T , ! t {{�1 . .. ... ........... ,-�:F:� .c .. i r i�'x.�j�,s¢3��1 F*}+�S3ai•{ W.� � d. f �l-�.. dY} till $c�.n3 ad 4ri�'41VE.-}_JrSYS.�iI �'SA.C`'.fe _y #'J'�.��W �F.N - rdl :,k�. iq y�f.�ii' .{ ./. r" :'•3� .-'L"llit4d. {'T^T"1.�� oy STATE GFNEPA (_ C.ONTRA, C,TS 11531 S.W. 92rd STREET • WfANI. FLORIDA 33176 TELFr foNE: Q3 j 6IP15-7N-7 October 15, 1996 a Federal Loan Dome Ban} Board of Atlanta j P. Q. Box 56527 Peachtree Center Atlanta, Georgia. RE: Pedro re l ae z and Michael Zogby Loan Applica cx n by General Federal Savings and Loan Gcn—.1emen.: I%lease be adviret= that Michael 7ooby and the urdersigned are t1ic +-;wrners of the, T-rrpc-Pclccatted at 5513 14. E. Miarii P1. and also 21 W. 59 Street, Miami, rloriva. ►�c made an application with General Federal Savings and Moan for a mortgage loan to refinance of both of these properties, however, the bank turned down the application and said that. the General Federal Savings loan request_ .should ,-,e: adaress�d to Freddie I1ac. Based on t a svcliesti•on from the bank, an application fee of $3,000.00 was paid to General. Federal, and several months parsed before aoth of these appli- caticns were'denied. Enclosed are copies of my prior correspondence to General Federal in which I make claim that the bank has unfairly denied the loan appli- cations. To begin with, both of these properties were recently constructed and lie in area called "Li;tic Haiti", which is predominantly a black neioh.borhood. It is my belief that the bank and/or Freddie Mac have unjustly denied the loan and not given sufficient grounds or explanations for such denial. Credit or Financial ability has never been a question and surely, this recently constructed property cannot be the reason for the denial, the quality of construction is more than adequate. What aapears to be involved here is a hesitancy by General Federal to mak:! a loan in a black neighborhood, therefore, it is my par.tner's and my belief that the bank has "red lined" this neighborhood and our property. Your cooperation and attention in helping resolve this matter including assisting us in obtaining a refund of the $3,000.00 application will be greatly appreciated. Should you have' any questions, please call. Sincerely, Pedrof Pe tae; PP : r'..; '}f'1r,• 4 '"r�f,I flip'.•.::1/?� �J,l,}��;1.R.�.:,,�,: ,:p`F�'t,.ly:+ .L ,R �t. ,S.:r �. .•i' •t'-•?, i iAk1� _ ., r �y.� n.�'.^ b} �;�I, y�_. �. - t f y�� 4R � _..• ' 6 " - -.�• ti. �t f � �a� ;r ;`� �{ b. f��ii`��y, Y^jp f.#`�>•� , .:5 E. a%t . ti}i..'4`ixsdssfr azY. :i:�3t• �.d-+•� .L.s..F.:_ f .:�NS�.I .��. .. '4'•aA f7i.. '[i' i. r. 'xfit• '} E' _ a 6 STATE GENEIIAL CONTPACTORS 11531 S.W. 93rd STPFFT f 1.F►AKff, FLORIDA 33176 TELEPHONE: (30 5) -95_ i 097 October 29, 1986 Mr. Douglas M. Brash Southeast Bank. N.A. One Southeast Financial Center Miami, Florida. 33131 RE: Pedro R. Pelaez and Michael Zogby Loan Application forr21 N. W. 59th St. and 5513 N. E. Miami Place. Dear Mr. Brash: You may recall that we first met several months ago at the L.I.S.C. Conference concerning economic development, you informed me that Southeast Bank made real estate loans in black inner city neighborhood of Miami. I was surprised, since it was my belief that Southeast Bank did not made loans in this area. Neverthless, in spite of my doubts, last Monday, Ocotber 20, 1986, I delivered to you the equivalent of a loan application for property that I owed in "Little Haiti". Much to my surprise, you informed me that due to "Internal Problems", the bank was not interested in the loan. Of course, I do not know what your internal problems are, however, on the exterior, it seems to be an example of "red lining". If such is the case, then it is very disappointing that your bank would take this attitude. V I trust that Southeast Bank has not made a final decision in my application. Sincerely, e ro • R. aez PP:ng .._ _±•_ .f. ray-'Y"'�.^.'T.�-s•r ��. •� Jam. ,t•R" - :I• _ •t G::".,,.RM�i�r` j4 �i;:: :",' .. "?r?,•.•.. .��; �1r. ti..t�.�-. -.. .. 'may. y -t..a• :a``. •�'S::' •3i. v7•. ,a-. .i,. i(';'' '1. - •-h -f1 }�^ !tom i4 orb .-r:.�w.i i�£• •'.r'�, '�.r.'•.i' -i r''.`'� � ' rr. .'i.• _ r . '.tii. �.2 .,,i� •�S t'r' ••yo.r� •T.r,4 y .:.,t�� rt: i -%{: n ° l++N 4 �• r �' + ; ' - 1 s ♦ir♦ �' 1 r ,;,i. 'r iy li � f!a li�,�'J>- < ri .,.i :y� r�..js r'.�.. �. L,f Lr J, 111 tt{,�,'•.,,'{,►, �.r`v ,..r. •t�':'r tt� r4. 6. �jj:t.i.1Y'��:[�m�' �'�;rY ..`+t. ,��-a•5�,: �.- ... �-� ..rr. ��«ir`a. Y r.. ,t�i•r 1e �.� tifr.}. r fi � � .. ,i. , � r f) } l e +t� � �•L.} , ;a� -i�" r _ , .� ''t •;� ,r � � _ t r, �r is £.� Atf • � � '�.c��a{t�� t,�,� � , � \ � t ; � _ : r r t. � f �� r r it.'$titer t Yt is ":,••i;'� ` :1 �...'r fl. a �., ... -r , ,. �.ta.t tr.- :-t,.. �.t.e'+� aX•r r414a's.k•',c`rk!:•# hY€a�•' .•ta�.L��i,�•3rt.'h1i•st,4:'t'{':?k.,gl-Ei`��T.rn�r�.''str."-.BI I'r•`i� � rr�r.-.-...aeJic�• L ''I�b�.i9'!R�� '� �r.t•'�n �•7 `+vw,.ew.n-rw'vtAb i?� of .daae�'ab STATE GENERAL CONTnACTORS 11531 S.W. $3rd STRUT v Vlr.Vl, FLORIDA 33176 TELEPHONE (305) C-95-700-7 October 28, 1986 Federal Loan Home Bank Board of Atlanta ; P. 0. Box 56527 i Peachtree, Georgia. Attn: Mar. Gregg Gentry RE: Pedro Pelaez and Mi hael Zo b A Loan Application at First Nationwide Dear Mr. Gentry: Enclosed you will find copies of appraisals and letter given to First Nationwide and Southeast Bank. in !4iami rejecting our • request for mortca(-e on two rental buildings in the City of Miami. We think the'reason they are "red lining" these properties is because the location is predominantly a black neighborhood. • Your cooperation and attention is helping resclve this matter will be greatly appreciated. Should you have any questions, please call. PP:mg Sincerely, e ro R. Pe ae '7c;�'f.'Tt�'�!!!w��'q �....+.�•vr;rr. �T ��r,YC.'1w1. ,-. Z•-�.�.-�.tr:••Z,^_�. 17''-< _ . .._ .r..f--yam r+�-r�!e^R7�';7r LS:�•'�` �.•"1•�►;:�.�� -f>�'�"'�j- �.1f t! ' ••L. 'u • ;,Cel�. 14" >.� a ' � y, a'`i:'i.i` � -^.:r,C�:. ;'.'.r-+. �;. ?.1;t.dG,4 i•`ti � y � ' a y � ..: 5','; c;'t%�.t tij'ir '-y '.A; �,f7. :�A �'+',,, .<+!`!�f 47�rc`,. �~�T'; ,�' �l- r.+�}i.r�•✓i,: ,.rp .t:T�<,.�7.� .• \.�{ .': ... c.'. .-._ .. _ � �� 7}� ��' � t•. "tom `• . _ 4 it �•i. }' f .. 2 ^i4'tgx .. - r ( • l 4 r y+ 1P t. del e S _ SP'}' 7.. l ''�, 1�+4' ` 1,. .r. L y f i 1 4r `, GQJI'�t`q�i1f=4", Ff��E. y Lf l { F xsT7 1•Sr'� •t F G fJ , . , . d a � �.`'p t-iii•%°� t t -1 'A 1 „��< _ r -«,,� `t."c�+anfi .� : f ,..i ... .. .... �.. _ f � �.� - . .. .. ./ ... ! r 1.,..+i x�'.�,�.: ... ... .. � r.- ✓ .i41 - -, - k,��+irA'+8_i9�.,.fi:, '/..$ 7..i. h �•i. '• V �t�i.f.. .:Y� : dl� I `.�w 4`' ;�'.P_{: }FeF'alYl t'�pdi '�`elY 'I ..` .' § e♦ .p" - i .-L .' v.� STATE GENERAL C C.9a4T P A GT OPS 11531 S.W. 93rd STREET WAVI, FL04 `!DA 331T6 TELEPHONE: (1104) Sod ;O9i i October 28th, 1966 k ! 3 Federal Loan Home Bank Board of Atlanta P. 0. Box 56527 Peachtree Center Atlanta, Georgia. RE: Pedro Pelaez and Michael Zo by Loan A-o ication at First Nationwide Bank Gentlemen: Please be advised. that Michael Zogby and I are the owners of the property located at 5513 N.E. Miami Place and also 21 N.W. 59 Street, Miami, Florida. -we made an application with First Nationwide Bank for a mortgage loan to refinance both of these properties for an amount of $430,000.00. The Bank, although approving our request, has agreed to loan only $335,000. The bank's argument for such a small amount, is that the appraisal shows a value of $335,000., which if calculated on per unit basis, results at $15,227.00. Our apartments were built by us — and are only six to seven months old and they cost us substantially more to construct. Enclosed are copies of an appraisal recently obtained which shown the value of the two properties to be $556,000.00 which at 80% loan to value ratio equals $444,800.00. Both of these properties lie -in area called "Little Haiti", which is predominantly a black neighborhood. The bank although approving the loan, has approved such a small suTr that it is tantamount to no loan at all. It is my belief that the bank unjustly denied the loan. Credit or Financial ability has never been a question and surely, this recently constructed property cannot be the reason for the denial, the quality of construction is more than adequate. What • appears to be involved here is a hesitancy by First Nationwide Bank to make a loan in a black neighborhood, therefore, it is my partner's and my belief that the bank has "red lined" this neighborhood and our property. Your cooperation and attention in helping resolve this matter will be greatly appreciated. Should you have any questions, please call. Sincerely, I'?:mg -Pedro R. Pelaez 4�i —.-�n-�--,.:,:;-.—+•-'fir-•-.^!r,-;. _-.;a.+n.,�-+r-'.=,_._.' .R--•�---•[+.'—^v-=7"c.-�.�..r-•r, a,�•,�.2'•-�'----_•- ' •t� I t f r �r +•t ' � r r t`rr •'� 'h _ r a t ' ! � � - �.•..��.A !1,: ,J;; �,� r -.,.•• _ t. L. l[ a .-➢, .�%• ,t a r, : ; t- L.• ,.s , " •, a,� •a i.r�, .+i ' :i'�is ••K7.,;.. ,, a 1r i -,� 1 �jl.. :*��S it tii y j Y-f; )t •,c, '- aJ ,� 4 �••.•5 ✓9t�i -.,?: r Z. r-+�) r. rti @� ycx r- -:. '•`�'.t:`r.�✓1-..i�Y' •t ��(+„ :f i� : .c•i i ..t_a. 1.,^ � •�, - .o �''t � '! ``{• .i i�• t. � .,, i �'. + 1;�y�..c .. _ , ' �t'r �� it - F / _. _ .� •, i .. ,, ,. .. .. .-.. a. - .. _ - ,s- •} [ }' t'�•`i\ P f �,' F 1r4 r - -• + f t r. �J f ti1 6 r A 1 •4.1 ��i ,t�-iP R�-{C .�M1'9"A.+'+� c`371 - 7 r it`._i 1'C7 Fay s� +fit.• ati;3zt [+. _ Y,Y4_ _ i 4i �i) •� X •F r.. .- .. , ,F.V•i , .•S J.'i.f a� F f4� 1:. t^: r��3r+.14, .r,�¢...�t.:.� , '`, �r.f!. .l ... �'.;1.. 6 � �a�Ya•��f�K�°+tsw�'r ' -. - _.. ---- ' - - --- '-- ., .-. �Fa 1 ,y.•. �_._..ai._w.-.s,..was,r.3t.a.�....s�..tri.�-.,f�_i,cai•.r.5rea��;�m�.s'. `..i'tit�"._ tS"%ca.-�',,,..f'ry�•� - r .r ,r 3 4T-t�.`.�yi tA J STATE GENERAL CONTRACTORS 11531 S.W. 93rd STREET • VIAVI, FLORIDA 33176 TELEPHONE: (30S) $95-700-7 October 23, 1986 Steve Nordlinger Vice President lst Nationwide 9250 N. W. 36th St. Miami, Florida. 33178 Dear Mr. Nordlingez: My partner Mich-tel Zoc-by and I have a loan application with your bank for property located at 5513 14. E. Miami Place and 21 N. W. 59th St. Miami, Florida. Our application was for $430,000. which based on recent appraisals is approximately 80% of the appraised price. Lydia Belusco of your b,ink informed us that because of the surrcu din area, First PlationN,ide was willing to 1 can only $3 35 , 000. or approximate:'. $�5,000. less than ariount requested. Both my partner and I were shocked and surprised that your appraiser arrived at a value of $15,227.00 per unit. These apartments are Lrand new and cost u., xr°uch more than your appraisers believes the cos to be: For the record, these apartments lie within a predominantly black neighborhood. It may be that the appraiser has not looked at this property fairly, because of the racial makeup of the neighborhood. Mr. Nordlinger, my partner and I applied for this loan individually, and we back this property with our good name and credit, further, as the builders of the property we know that the collateral is worth far more than $335,000. in addition, the income approach to this property results in an even wider value than the cost method -used by the appraiserr- Please review our application, and reconsider our request for $430,000. so we can finalize this loan. PP:mg Sincerely, Pedro Pe 4rft ..'�..' �7�,,•r-^.'T•,Ti;'.""{`'?�•'.^'�':.-�.q-r.�... ..wr�.t- - - :Oi�r.^., �r.;�,..•,•.+,r�r�t.l�..-_. . ° C• 1.�..t, �Z. tf;si�!*, .j1 r t.h � �•.-li=i•"i . ...•, �. .. .�,wY ,gin. .t. c.t °.;1. �..,a ��°'I..�y.,. 3.-+•. �r4 .f {' t�.t _:tn Y s ' 'i-.hi;` `a-.I� 1 � -+g. "� .$r _: a'. 'i�:.J_ , ..~ a ., .;"7 ,, - - - + Y '?, •.�{ -�,,aye. L. . .�',•. j k'r ?,;��'1,�F4cj a-S - t .Yt�`� Y• 9:t �•T+'-+'4 3�Y'-�� si t ! 3. I' �' • 1' ` � I i :� � � f . 1',h Ay Y Yl ff N � f, l•Er MARCIA K. CYPEN Eswutive Director RENE V. MURAI President JUANITA HORTON let Via President GEORGE CARTER 2nd Via President JENNIFER KRONER Secretary JEFFREY ROSINEK Treasurer 1 LEGAL SERVICES OF GREATER MIAMI, INC. ' Northside Shopping Center, 149 West Plaza, Suite 210 7900 N.W. 27th Ave., Miami, Florida 33147 October 23, 1986 Mr. Herb Ba•fiey i" Assistant City Manager City Hall 3500 Pan American Drive r. '< Miami, Florida 33133 r Rows,; ". • fcf (305) 693.681C Re: Sun Bank Dear Mr. Bailey: Please find enclosed the original and the amended version of our Comment regarding Suntrust's acquisition of Third National Corporation. In the original (page 12) Gerry Gereaux is inadvertently quoted by mistake. Gerry had talked to us previously about NCNB bank and his comments were included in an earlier comment that we had prepared regarding that bank. Because of the short filing deadline for Suntrust, we used our word processor to edit the earlier NCNB Comment. Gerry's remarks were inadvertently left in due to an error by our editor. We have submitted the amendments to the Federal Reserve Board, Suntrust Bank and to Ted Hoepner at Sun Bank/Miami. The Amended Comment deletes Gerry's remarks. The original version of the Comment is inoperative and our Amend- ed Comment is the relevant document for purposes of the Federal Reserve Board's review of the performance of Sun Bank. Please contact me if you need assistance. Sin ely, OHN M. LITTLE Staf f Attorney 'M ijML:bb Enclosures INT2/A34 86-94riC THE PURPOSE OF THIS PROGRAM IS TO PROVIDE LEGAL ASSISTANCE TO PERSONS WHO ARE WIT ATE MEAN5 TQ€MPj&Y_QTHER COUNSEL AMENDED COMMENT ON APPLICATION OF SUNTRUST BANKS, INC. 1 TO ACQUIRE THIRD NATIONAL CORPORATION The Protestants described below are Florida residents and organiza- tions who jointly request that the Board of Governors of the Federal Reserve System not approve the application of Suntrust Banks, Inc. (("Suntrust") to acquire Third National Corporation, of Tennessee, until Suntrust provides adequate assurances that it will meet the con- venience and needs of the low and moderate income persons, and minorities, in their service areas in Florida. There are Florida residents and organizations who have joined in the writing of this comment. They are from counties in which Suntrust is currently operating in Florida. One of the Protestants is a community organization from Dade County composed primarily of black citizens who are actively engaged in It economic development activities. They are represented by Legal Services of Greater Miami, Inc. If 11 86-9441 e 0 01 The Scott -Carver Community Development Corporation, Inc. is a non-profit, tax-exempt organization whose members are primarily public housing residents from the Liberty City area of Miami. The area is characterized by a high percentage of low income residents, and a high incidence of overcrowded and dilapidated housing. The Scott -Carver Community Development Corporation, Inc. is just one of a number of such organizations in the Liberty City area that are working towards economic revitalization. Scott -Carver is participating in this protest for the purpose of encouraging Suntrust to become more actively involved in these efforts. Ms. Ann Adker is a low income resident of Miami's Overtown community. The Overtown community is located directly north of down- town. Ms. Adker is concerned about the deteriorated housing stock in Miami's Overtown community and the lack of safe, sanitary and afford- able housing for low income residents, and because of this she has determined to involve. herself directly in the revitalization process. Ms. Eufala -Frazier is a low income resident of Dade County's Liberty City community. Albert J. Taylor is a low income resident of Duval County who is concerned about lask of investment in his communigy. N .O . A . H . , Inc. is a non-profit community organization from the Belle Glade community of Palm Beach County. The organization is also concerned about lack of investment in their community. t~ ..' The proposed acquisition of Third National Corp. will be the first i . entry by a regional bank holding company into Tennessee. The acqui- -2- 86-940y sition would make Suntrust the largest bank holding company in the South with $Z3.8 billion in assets. About $13 billion of those assets belong to Suntrust's bank subsidiaries in Florida, making Suntrust the state's second largest bank holding company, behind only Barnett Banks of Florida, Inc. The Protestants believe that an examination by the Federal Reserve in its consideration of this application of the prior records of Suntrust in meeting the convenience and needs of low and moderate income persons, and minority persons, in Florida is required by 12 C.F.A. 5225.13(b) . The section provides in pertinent part: In deciding -application under this subpart, the Board also considers the following factors with respect to the applicant, its subsidiaries, any banks related to the applicant through common ownership or management, and the bank or banks to be acquired: (3) Convenience and needs of the communit . The convenience an nee s o the communities to be served, including the record of performance under ,the Community Reinvestment Act of 1977 . .The examination will reveal that Suntrust has failed to adequately service these needs, and that the measures described in the Relief section of this Comment are necessary to assure that these needs will be met by Suntrust. Throughout the state, loan programs that are sorely needed in low and moderate income, and minority neighborhoods are not offered at all by Suntrust, such as FHA, FmHA and VA loans. In many counties _these neighborhoods are redlined by Suntrust in conventional home • ,purchase loans. In 1985. Suntrust did not make a single home purchase loan in a black census tract in Brevard. Broward, Dade. Lee or Voldsia counties, out of a total of 770 home purchase loans in these counties. -3- 86--94�: t In Volusia County, Suntrust has actually withdrawn from black neighbor- hoods in this type of lending after previously having made home purchase loans there proportional to the neighborhoods' populations. In Duval, Palm Beach and Polk counties, Suntrust made only one home purchase loan in a black census tract, out of a total of 271 home pur- chase loans. In Orange County, which contains Suntrust's lead bank for Florida, Suntrust has annually made less than 2% of its home pur- 'a�` chase loans in black census tracts, although 11% of the County's :. population live in those tracts. In each of these counties, there are ug =. sizable black neighborhoods and Suntrust makes a significant number of home purchase loans. Without a program to address these needs, Suntrust's continuing expansion promises to erode even further the housing available to low and moderate income persons, and minorities, in Florida. Suntrust's activity in low and moderate income, and minority neighborhoods in Florida has consisted largely of television advertising that it is "the bright way to bank," and small selective grants to _- minority organizations. The actual credit needs of these communities, meanwhile, have not been met or even due to lack of community input, even ascertained by Suntrust. Suntrust has not been willing to even discuss its creation of a GR written CRA program for Florida. Because of this, negotiations with Suntrust before the filing of this comment were not available to the Protestants. Suntrust's position is particularly unreasonable for two ti i»reasons. First, it is a holding company responsible for establishing N 'writien policies for its subsidiaries, and it refuses to do this with respect to CRA lending. Second, four of Florida's largest bank holding -4- 136-94A. companies have already created written CRA programs that are estab- lished and very effective in making banking services available to all segments of the community. The Protestants request a full investigation by the Federal Reserve of the information on Suntrust contained in this comment that is con- ducted without reliance on the examiners of other agencies which will �1 not consider this application. We further request public meetings to be `held in each of the Protestants' counties to clarify the issues through the public testimony of low income persons and groups residing in these ~ counties who have expressed an interest in presenting their views to the Board, and to not have any other adequate forum in which to express their concerns. The Protestants request adequate time to obtain any further nonpublic information from Suntrust before entering into further negotiations or participating 'in private or public meetings. Finally, if Suntrust will agree to enter into negotiations for the purpose of creating a written CRA program, the Protestants may request modera- tion of negotiations by the Federal Reserve. Below are summaries of the counties in which the Protestants live, authored by the attorneys representing each Protestant, and the Protes- tants requested relief. DADE COUNTY The Scott -Carver Community Development Corporation, Inc. is a non-profit, tax exempt organization whose members are primarily public %'housing residents from the Liberty City area of Miami. Ms. Eufala Frazier is a low income resident of Liberty City. She is a founder of the Tenant Education Association of Miami which is an -5- 86-94* advocate organization for low income persons in Liberty City. She is also a board member of the Magic City Development Corporation, a relatively new community development organization trying to build housing for low income Liberty City. Because of these involvements, Ms. Frazier is accutely aware of the need for greater availability of credit services in Liberty City. The Liberty City area was developed after World War II as a relatively low density site for public housing. At that time the area was not predominantly black. As late as 1950 more than 50% of the residents were white. After that time, Liberty City grew rapidly and merged with an adjoining community known as Brown's Sub and the population became predominantly black. The enlarged area is often referred to as Model Cities which encompasses Census Tracts 10.04, 15.01, 15.02, 18.01, 19.01 and 19.02. The area is characterized by a high percentage of low income residents, and a high incidence of over- crowded and dilapidated housing. Suntrust Bank has not made any housing loans in the Liberty City area in at least the last five years. The Scott -Carver Community Development Corporation, Inc. and Magic City Development Associatica are just two of a number of such organi- zations in the Liberty City area that are working towards economic revitalization. Scott -Carver and Ms. Frazier are participating in this protest for the purpose of encouraging Suntrust Bank to become more ac :vely involved in these efforts. Ms. Ann Adker has long been active in community affairs in Miami's [^ "Overtown Community. She is particularly concerned about the deterio- rated housing stock in Overtown and the lack of safe, sanitary and affordable housing for low income residents, has determined to involve -b- 86-94� 0 U itself directly in the revitalization process. Ms. Adker is a key member of The Overtown Advisory Board which advises the City of Miami on its Overtown redevelopment policy. Through this activity she has become acutely aware of the lack of bank financing for housing revitalization in Overtown. Miami's Overtown community is located directly north of downtown. It encompasses Census Tracts 31 and 34. It is today characterized by vacant lots, high unemployment rates and overcrowded rundown housing. A few small businesses struggle among the abandoned and boarded up buildings. This situation has not always been quite so grim. Overtown, after Coconut Grove, is 'the second oldest black community in Dade County. At one time it was the economic hub of the black community containing black -owned stores, restaurants, nightclubs, and other enterprises. Its economy evolved around commerce, entertainment, and servicing nearby downtown Miami. Originally, it was a tract of land the railroad had bought to house its black laborers. The segregationist laws of the times prevented these workers from living elsewhere as they migrated south to work on the railroads. The heyday of Overtown was in the 1940's. Although it could not compare with the affluence of white Miami, black businesses prospered as well as churches, social and civic associations. During the days of segregation, Overtown was cut off from the social and economic life of the rest of Miami. Miami was not only a prime vacation spot for white tourists but also for the country's leading black professionals. These -blacks, who could not stay at the white owned hotels, stayed in Over- . town along with internationally known black entertainers who were forbidden to stay at the luxury hote'.s where they performed. -7- SE-�94y 0 Overtown continued its relative stability during the 1950's but things changed drastically during the 1960's. By 1965 much of Overtown had been razed for highway construction And 'urban renewal'. Inter- state 95, which today is Miami's primary north -:south artFry, along with the East-West Dolphin Expressway were both constructed directly through the heart of Overtown. Later Mctrorail, Miarni'c new urban mass transit system, was routed through the community causing further dislocation. These same forces that destroyed or altered the physical structures also weakened the social underpinnings of the community. Businesses folded, churches closed, and many residents were forced to leave. Overtown's population has declined from around 40,000 in 1960 to approximately 10,000 today. Slightly more than 40% of all housing units are overcrowded, a 7% increase in the past 10 years. Much of the housing is in need of repair. In 1975, 65% of the housing in the Culmer Park section of Overtown either was dilapidated or needed major repair. Only 10% of the housing in the city as a whole was in such condition. KSuntrust Bank has not made a single housing loan in the Overtown community during the last five years. Suntrust Bank operates in Dade County through its subsidiary Sun Bank/Miami. N.A. (hereinafter Sun/Bank Miami) . Sun Bank/Miami has not adequately met the credit needs of the low income and black commu- nity. Dade County is a rapidly growing and expanding urban area on the southeast coast of Florida covering approximately 300 square miles. 4 •,The county contains 27 municipalities. The City of Miami serves as the county seat. The total county population as of 1980 was 1,625,781. The county is experiencing rapid social and economic change. Daily, -8- 86--942 the downtown skyline is being transformed by increasingly tall sky- scrapers. A new rapid transit rail system is in palce and functioning. Miami is tri-°ethnic and multicultural. Dade County has one of the largest and fastest growing black populations in the United States. In 1982 there was a black population of 335,000 or about 20% of the population. Between 1970 and 1980 the county's black population grew by 47%, a rate exceeded only by Atlanta, Georgia (61%) . Profiles of the Black Population, Metro -Dade Planning Department) . The median income for black families in 1979 was about 63% of the median income of white families. The proportion of black families in poverty (26%) was about three times the proportion of white families in poverty (8.5%) . ( Dade County Characteristics 1983) . North of the Miami River, older established black communities overflowed and merged to form a single area, spreading from downtown Miami all the way north to the Broward County line. (Profiles of the Black Population, supra, p . 33) . These older black communities include Opa Locka, Overtown, and Liberty City/ Brownsville. These communities have gradually merged to form one large black concentration. Housing In the neighborhoods where the county's blacks reside, the build- ings are deteriorating. Many are squalid. Much of Overtown and Liberty City are characterizg!d by overcrowding, severe rodent infesta- tion, and delapidation. These conditions engender apathy, hopelessness, frustration and anger for many of the residents. The need for housing rehabilitation is great. Overcrowded housing is a serious problem in Dade's black commu- nity. Overcrowding is defined as more than one person per room. -9- 86-942 About 12% of all occupied units (74,000) were overcrowded. Of these, about 30% (20,600) were occupied by blacks. Black households averaged 3.25 persons compared to 2.5 in white households. About 28% o. all black renter households lived in overcrowded units compared with only 16.8% for the total population. About 20% of all black owner occupied units were overcrowded compared with only 8.2% for the county as a whole. (Profiles of the Black Population, supra, p. 139). An extremely low vacancy rate has exacerbated the housing situa- tion for black families. The vacancy rate for rental units in predomi- nantly black areas has been less than 1% for the past several years. (See Confronting Racial Isolation in Miami, a Report of the U.S. Civil Rights Commission, p. 66, hereinafter referred to as "Report"). In effect, there are no vacancies at all with little chance of movement. The situation has been made worse by the recent influx of refugees from Haiti and Cuba. Forty-four percent of black occupied. housing units were owned by black homeowners compared to 54% for all households. In addition, the value of black owned homes was less than the value of white owned homes. Six of every ten black owned homes were valued at less than $40,000 in 1980 compared to only 2 in 10 white owned homes. The median value of black owned homes was $37,400, about 70% the median value of all owner -occupied units. (Profiles of the Black Population, supra, p. 133). Sun Bank/Miami has done little to ease this bleak housing situation [" in the black community. There are seventeen census tracts in Dade v 'County that are over 85% black. These Census Tracts are primarily in Liberty City and Overtown. 38% of all housing units in these tracts are -10- 86-942 0 owner occupied. Collectively they have a population of 91,870 people which represents 6% of the cou.nty's population. In contrast, only a small percentage of all home improvement loans made by Sun Bank/Miami has been made to residents of these tracts in each of the last three years as demonstrated in the table below. Dade County Total Sun Bank/Miami Year Housing Loans 1983 $2,494,000 1984 $6,040,000 1985 $9,564,000 Amount of Sun Bank/Miami Loans In Census Tracts 85% Or More Black $ 40,000 ' $213;000 $275,000 Percentage of Housing Loans In Tracts More Than 85% Black 1.6% 3.5% 2.8% Sun Bank/Miami has not made a single home purchase loan in any of these Census Tracts during the last three years (Sun Bank/Miami made $21,672,000 worth of these loans County wide) . This despite the fact that both the City of Miami and the Metro -Dade County government have ma-Je these Census Tracts target areas for purposes of focusing community development and housing assistance funding. These Census Tracts are, in fact, the heart of Dade County's black community. The need for credit services is greater here than in perhaps any other part of the county. ven in mixed race areas, Sun Bank/Miami has not adequately met the community's housing credit needs. There are 39 census tracts in Dade County with more than 50% but less than 85% black population. Collectively they have a population of 243,181 which represents approxi- mately 14% of the total county population. Sun Bank/Miami, however, has not come near to making 15% of their housing loans in these Census Tract. Sun Bank/Miami has an affirmative obligation under the Community Reinvestment Act to make loans in every neighborhood of their service -11- 8E-942 areas. Despite this, the bank is redlining the census tracts within their service areas that have the highest concentrations of black resi- dent!..) -V Economic Development In addition to their needs in housing, Dade's blacks have struggled to participate in the economic mainstream. Unfortunately, present day discrimination and the lingering effects of past discrimination continue to discourage black entrepreneurs from starting or expanding busi- nesses. It is extremely difficult for blacks to obtain venture and operating capital. Consequently there are few black entrepreneurs. Those that exist generally ' own small struggling businesses. In 1977, Miami's 2,148 black owned businesses supported only 380 salaried employees ( Report, p . 82) . A variety of community development organizations have been created to promote business and economic development for black residents. One of the greatest needs of Dade County's various community development corporations, and for minority entrepreneurs in general, is access to financial resources. . Developers in the black community are often turned down for various reasons including the requirement for large "equity" investments, inadequate "track record", and insufficient collateral. Despite professing to serve the entire county, Sun Bank/ Miami has not made much effort to assist community development corporations and minority entrepreneurs. Interviews with officers of several commu- nity development corporations reveal that the bank has not been involved ih their redevelopment efforts. Sun Bank/Miami does not have a branch �in the communities where black entrepreneurs operate. As a result it is difficult for the banks to understand the needs of the community. -12- Miami Capital Development Corporation, Inc. is a quasi -public agency established by the City of Miami to provide financial packaging, business development, and technical assistance service. Leo Solorzano, a loan officer with Miami Capital, reports that Sun Bank/Miami has not had a substantial participation in Miami Capital Development Corporation's loan program to the best of his knowledge. Although he is not person- ally familiar with every loan Miami Capital has made, he is not aware of any participation by Sun Bank/Miami on loans that he has worked upon..] DUVAL COUNTY Jacksonville, the "Bold New City of the South," is the center of the SMSA which includes Duval, Baker, Clay, Nassau and St. Johns counties. 1980 Census of Population and Housing, SMSA Series, Jacksonville, Table P-1 (hereinafter referred to only by table number) . When the City of Jacksonville and Duval County consolidated, Jackson- ville's city limits became the largest in the continental United States. The population of this vast city/county was 571,003 in 1980, with 140,561 black residents. Table P-7. Consistent with its bold motto, Jacksonville has undergone tremen- dous growth in tst ten years, which has been described by Jacksonville Mayor Jack Godbold as a "billion -dollar decade." The Mayor claims to have brought to the downtown area 163 new companies, 88,000 new jobs and $1 billion in completed or planned new construction. The tax base has doubled since 1979, and is valued at $18 billion. Building permits .r shave increased 200 percent in the same period, and residents' buying •s . income is up 133 percent. The Florida Times Union, July 9, 1986, front page, col. 4. -13- 86-94Z Sadly, Jacksonville's renaissance has left a substantial portion of its low income and minority population in the dark ages. Of the city's 151,279 families in 1980, 12.7 percent, or 19,228 families, had incomes below the poverty level. Table P-11. Almost one --third, 31.8 percent, of all black families are poor. Table P-15. In stark contrast to the "Kew City"'s gleaming towers, luxury condominiums and chique boutiques, is the decrepit housing stock inhabited by much of Jacksonville's low income and minority community, caused in large part by the community's inability to obtredit. Whereas 62.6 percent of the city's housing units are owner -occupied, only 18.4 percent of the black population live in their own homes. Table H-1. Of the 24,004 units occupied by black owners, 1,025 units lack complete plumbing, Table H-1, and approximately one-half of the homes owned by blacks are valued at less than $20,000. Table H-3. Sun Bank of Jacksonville, whose service area as defined in its CRA Statement includes all of Duval County, has been an active partici- pant in Jacksonville's commercial growth, as have other Sun Bank subsidiaries in their communities throughout the state. Sun Bank, however, has failed to adequately serve the extensive credit needs of low income and minority individuals and groups. In Duval County, Sun Bank has been unresponsive to the needs of low income and minority business people, home purchasers and small depositors. Springfield Located on the fringes of Jacksonville's new downtown, Springfield r is a residential neighborhood caught between the extremes of decay and y revitalization. The Census shows that 9,810 persons live in Springfield, 5,238 blacks and $4,501 whites. Bureau of the Census Neighborhood -14- e Statistics Program, Narrative Profiles of Neighborhoods in Jacksonville, Florida: Springfield, at 14 (hereinafter referred to as "Springfield Profile") . Only 33.6 percent of housing units are owner -occupied here, contrasted with 62.6 percent for Duval County. Fifty-three percent of housing units arc over 45 years old. Only 20.8 percent have central heating systems and a mere 30.5 percent have air conditioning. The median value for specified owner -occupied homes in Springfield is $16, 300, compared to $31, 700 for. Duval County. Springfield Profile at 20. Nevertheless, gentrification pressures are strong, and the Spring- field Neighborhood Association is fighting to assure that residents, of whom 47 percent fall below the poverty level, Springfield Profile at 18, are not displaced. Home Mortgage Disclosure Act HMDA data provided by Sun Bank to the Protestants reveal the widespread nature of Sun Bank's lack of home purchase loans in Jacksonville's minority and low income neighborhoods such as Spring- field. Nearly one in five Jacksonville residents, 19.1 percent, lives in a census tract in which over one-half the residents are black. Table P-7. Yet from 1983 to 1985, Sun Bank made only one home purchase loan in a black census tract, out of a total of 905 such loans in Jacksonville. This constituted a home purchase loan/100,000 residents ratio of 6.8 per year for white census tracts in Jacksonville, and 0.3 per year for black census tracts there. The effect of Sun Bank's home purchase loan policies since 1983 has been to virtually exclude black d" - ti census tracts its service area. y. As the table below shows, since 1983 Sun Bank has never made more than 1.07 percent of its home purchase loans in black census tracts. -15- 86-940, 9 SUN BANK OF JACKSONVILLE Home Purchase Loans Year Total Loans Black Census Percent of Loans in Tract Loans Black Census Tracts 1985 60 1 •1. 7 1984 25 0 0 1983 10 0 0 Sun Bank's basic banking services expose its lack of concern for the credit needs of low income and minority customers. Sun Bank's basic checking account pays no interest and requires a minimum $400.00 balance for free service. If the balance dips below $400.00, the service charges range from a minimum of $3.00 per month to a maximum of $6.00 per month. These fees would progressively consume the savings of low income customers unable to meet balance requirements. In addition to its failure to provide affordable basic banking ser- vices, Sun Bank has failed to meet other credit needs of low income and minority mers. Mr. Albert J. Taylor has been a Sun Bank depositor since 1974. Nevertheless, when he applied for a home improvement loan in 1980 and again in 1985, his applications were denied evough he had more than sufficient home equity to secure the loan. On June 30, 1986, Mr. Taylor filed a complaint with Sun Bank stating that he felt' that the loan denials violated the Community Reinvestment Act and, in particular. W� the requirement that banks meet the convenience and needs of all members of the community. PALM BEACH COUNTY The western portion of this county is predominantly agricultural. The low income and minority communities are centered in and around Belle Glade, South Bay and Pahokee. The eastern portion of the county is urban. -16- SG®-94Z During 1983-85, Suntrust made a total of 136 home purchase loans in the county. Out of these, only five were made in predominantly black and low income Census Tracts. During this same period, Suntrust made 601 home ianprovement loans in. the county. Of these, a mere 61 were made in low income and minority Census Tracts. In addition, Suntrust has refused to participate in financing hous- ing for low income persons in Belle Glade despite the firm commitment of several other banks to the project. ORANGE COUNTY Orange County, Florida is located in the central part of the state. It contains Disney World, Orlando. and was cited in Newsweek, Septem- ber 2, 1984, for its phenomenal economic growth, particularly in high- tech fields. In 1980, the total county population was 471,016, of whom 69,55? were Black. Population of Census and Housing, PHC 80-2 Series, Orlando SMSA, Table P-7 (hereinafter referred to only by table number) . Orange County is included in its entirety in Suntrust Bank's • market area and covers Orange, Osceola and Seminole Counties. Suntrust Bank has branch offices in this market area, including in Orange County. Suntrust Bank is grossly underserving the Black neighborhoods, and the low and moderate income areas, of Orange County. The major Black, and low and moderate income, neighborhood in Orange County Y • �^,stretches west from Interstate 4 in Orlando to Kirkham Road. mirroring �r ' s the expansion of the Orlando area population in that region over the past 25 years. In addition, there is a small low and moderate income -1?- 8f-94� 1% .i . A area in Winter Park that consists of United States Census Tracts 154.01, 155.02 and 159.01, and a belt of rural Census Tracts to the south and west of Orlando that overall are wealthy, but, at least 20% of their populations have incomes below the federal poverty level. Between Interstate 4 and Orange Blossom Trail, a low income Black community of 9,308 persons, living primarily in pre-1960 rental housing, is located in United States Census Tracts 104 through 106 in Orlando. Tables P-7, 11; H-7. In 1980, the neighborhood's mean household income was $8,766, and 48.9% of its residents had incomes below the federal poverty level. Table P-11. South and west of this community lies a belt of mixed owner - occupied and rental housing neighborhoods, built largely in the 19601s, in which at least 20% of the population in each Census Tract have incomes below the federal poverty level. Tables P-11, H-7. These neighborhoods consist of Census Tracts 114 through 117.02, 119.01 and 146.01. In 1980 their total population was 28,337. Tracts 117.01, 117.02 and 146.01, located to the south of the East-West Expressway, collectively contain 14,961 residents, of whom 94.7% are Black. Tract 119.01, to the north of the Expressway, has 3,899 residents, of whom 68.2 are Black. P-7. Flanking this belt to the north and south are two predominantly Black Census tracts, tracts 118 and 146.02, in which less than 20% of the population have incomes below the poverty level. Table P-11. Tract 118, to the north, had a population of 2,348 and a mean house- 44'hold of $16,348 in 1980. Table P-11. Tract 146.02, to the South, had .y Is. 10,852 residents in 1980, of whom 98.8 were Black. Table P-7. The housing units, built primarily in the 1960's, were 91.0% owner -occupied. Table H-7. -18- 86--944. Suntrust Bank has redlined the predominantly black Census Tracts in all areas of housing credit, through policies they follow that are in violation of the Community Reinvestment Act and related federal law. Suntrust Hank originated only 14 single family home purchase loans from 1.983-1985 although it originated 729 home purchase loans over this period; less than 2% of the home purchase loans have originated in the black community. Approximately 6% of Suntrust clank's home improve- ment loans originated in these Census Tracts over the same time period. Suntrust Bank's provision of housing credit to low and moderate income neighborhoods has been almost equally exclusionary. In 1980, 85,232 residents of Orange- County lived in Census Tracts in which at least 20% of the tract's population had incomes below the federal poverty level, constituting 18.7% of the County's population. From 1983-1985, Suntrust Bank originated only 10% of its single home purchase loans and 11% of its home improvement loan in these tracts. The low and moderate income neighborhoods of 'Orange County desperately need community development funding from the private sector, and access to mortgage loans and home rehabilitation loans. In the Black community in Orlando and south of the East-West Expressway, 1.752 occupied housing units, consisting of 16.5% of the total number, are overcrowded according to the Census definition of more than one person per room. The vacancy rate for rental housing in this community is only 2.56%. Table H-7. An index to the lack of new construction in the major Black, and ti6iow and moderate income, neighborhood in Orange County, described i . "above, is that from 1979 to March, 1980, only 127 of the 17,948 struc- tures built in Orange County were built in it, exclusive of Census -19- Tract 106, in which 207 units were built. Four Census Tracts in this neighborhood did not have a single structure built in them during this time, and one of them, Census Tract. 114, has not: had a structure built in it since 1969. Table H-7. A principal reason for this lack of activity is difficult in obtaining financing, especially in Black neighborhoods. In the Black community in Orlando and south of the East-West Express- way, exclusive of tract 146.02, only 27.4% of home owners moved into their present homes after 1969, compared with a county proportion of 68.0%. Table H-7. The housing stock of the eastern part of the County's major low and moderate income neighborhood is old, and the entire neighborhood's stock is in poor condition. In the Black community east of the Orange Blossom Trail, 27.7% of the year-round housing units were built prior to 1940. Table H-7. In the entire neighborhood, a total of 234 units lack complete plumbing for exclusive use. Table H-7. In the Black community in Orlando and south of the East-West Expressway, 58.6% of the year-round housing units do not have air conditioning, and 40.2% do not have built-in heating units. Table H-7. As a result of these and other problems, the median value of the owner -occupied housing units in the County's major Black, and low and moderate income, neighborhood is less than $30, 000 . Table H-1. Suntrust Bank is not meeting the convenience and needs of the Callahan neighborhood, a low and moderate income community located in the city of Orlando. Callahan consists of United States Census Tract According to information supplied to the Protestants by the y. "Orlando CDBG office, the neighborhood's population is 2,886 persons, 92% of whom were Black. The median household income of Callahan is -20- • 0*4 $7,284, and 42.6% of its population have incomes below the poverty level. The existing housing in Callahan is crowded, old and in poor condition. Fully 16.1% of the occupied housing units are overcrowded according to the Census definition of more than one person per room. The vacancy rate for renter -occupied housing is only 1.9%. Twenty- nine percent of the year-round housing units were built prior to 1940. Fifty of them do not have complete plumbing facilities. As a result of these problems, the median value of owner occupied housing in Callahan is only $20, 300. LAKELANDIPOLK COUNTY Lakeland is the largest city in Polk County, having a population of 54,130 and covering 26.8 square miles; its population swells to 155,300 if contiguous unincorporated areas are included. Lakeland lies smack in the center of Florida, 30 miles east of Tampa and 50 miles southwest of Orlando, between two of the fastest growing metropolitan areas in the United States. The major economic bases in Lakeland and throughout Polk County are the citrus and phosphate industries. After several years of de- pressing citrus freezes and more recent outbreaks of canker, the citrus industry and its labor force are on the ropes; although one-third of the state's citrus business was conducted in Polk County, many growers have already decided to move their operations further south in the near future. The phosphate industry has also suffered equally these past Y few years due to a depressed fertilizer market at home and a strong dollar abroad. In its heyday. the phosphate industry employed 9200 -21- 86-942 Polk workers. After several years in which 2500 workers were laid off, the Florida Phosphate Council in 1983 permanently eliminated 1800 jobs. In any event, Polk's phosphate deposits are expected to run out by the end of the century, with no expectation of new Polk mines being built. As a result of the above calamaties, the incomes of many residents JAM have suffered, as indicated by the sorry Polk unemployment rate which XM was doubled the statewide average in 1984. Polk unemployment was 13.8% in September 1984, with 20,827 unemployed out of a labor force of -7M 150,619. Polk's population was 345,224 in 1983, which was made up of -- 126,500 households. Housing conditions for the county's 48,725 blacks are relatively poor. A disproportionate amount of black housing is more ism than 40 years old, is crowded, or is without central heating equipment. 78% of Polk's blacks live in urban areas and two-thirds of that number live in incorporated cities and towns - in contrast to whites who seem to settle in suburban and rural areas. In Lakeland, the highest percentage of blacks (75%-99.9%) live in census tracts 112.01 and 112.02, and significant percentages of Blacks (20% to 39.9%) live in census tracts 102, 110 and 111. Nevertheless, despite public knowledge of poor housing conditions and racial crowding in the aforementioned contiguous tracts, Suntrust Bank made but two home purchase loans in 1984 and 1985 to deserving individuals. Lakeland's economic needs are further reflected by the fact that the Lakeland -Winter Haven Metropolitan area is counted as one Standard LUetropolitan Statistic Area and ranks 1.6th out of Florida's 20 metropoli- Ytan areas in per capita income of $9,756.00, and 12th in household -22- �E"94� income at $17,816.00.1 In 1980, when Polk's population was 313,226, census data shows that 63,585 people lived below 125% of the federal poverty level; this is an area in need of capital and revitalization. The low income people of Lakeland in particular are living in very substandard housing. In fact, in May 1983, the Lakeland Housing Authority maintained a waiting list of 500 low-income Lakeland residents who needed to recieve rental subsidies under HUD's Section 8 program, and another 300 to 400 families had filed pre-applications.2 Since the government is no longer building decent safe and sanitary housing in Lakeland for low-income persons, the affected population must rent substandard housing because decent rental property is not available in their price range. According to 1980 census data, the median household income for Polk County was $14,275, with about 39,000 household out of 114,000 earning less than $10,000 per year, and with another 21,000 earning between $10,000 and $14,999 and another 18,060 earning between $15,000 and $19,999. Additionally, some 64,753 people in Polk County depend upon some form of Social Security bene- fits to subsist. The housing market in Lakeland has been stagnant for the past two years with an average yearly absorption rate of 5.82 percent of homes offered for sale, with the average sales price fluctuating between $57.990 and $69, 693 during 1985. Nevertheless, there are homes within 1University of Florida Colleges of Business Administration. The ,ledger, October 12, 1985. 2Demand in Lakeland was so great that acceptance of any more applications had been suspended some 18 months earlier. As a result, the Lakeland Housing Authority decided to subsidize 144 existing units of private housing, rather than to build 72 new public housing units. The Ledger, May 15, 1983. - -2 3- 86-942 the means of low and moderate -income persons; during the first 6 months of 1985, 7.7% (42) of the total homes sold were under $25,000 and 39,999, and 25.7% (140) of the total homes sold were between $40,000 to 54,999. .Congress has determined that "regulated financial institutions have a continuing and affirmative obbEation to help meet the credit needs of the local communities". (emphasis added) 12 U.S.C. §290(a)(1). Housing conditions in Lakeland show that the residents, especially low and moderate -income persons, need access to mortgage loans and home rehabilitation 'moans, as well as access to burin-ss loans and "life -line" (checking account) services. Although Suntrust Bank cannot singularly be held responsible for the total deterioration of neighborhoods in Lakeland, SunTrust's<ailure to fulfill its duty hastens that deterioration and maintains the existing racial composition of certain other neighbor- hoods. REQUEST FOR RELIEF The protesting parties seek a resolution to their credit needs and those of the low and moderate income populations, and minority popula- tions, within Suntrust's Florida service areas. As a clear statement of Suntrust's intention to serve the convenience and needs of these groups, Protestants request the following program to be instituted by Suntrust. Protestants believe that for each of the parts of the program described below to be meaningful, they must be structured through negotiation with Protestants so as to take into account the special relationship of a holding company to its subsidiaries, and establish particular obligations of Suntrust that are enforceable by the Federal Reserve. -24- 8E-94 ,:�, . 41b . : A. Suntrust will use its best efforts to inform the low and moderate income and the minority communities, of the lending and other services (as outlined in this request for relief) offered under this CRA program. In this connection, Suntrust will utilize innovative advertising and marketing techniques specifically directed toward low and moderate income groups and minority communities, including minority --oriented media (both print and radio) and direct mailings to realtors (prepared in conjunction with the CRA Taskforce) . Suntrust will consult with the CRA Taskforce in the design of these advertising and marketing efforts. 'Suntrust expects to spend at least $200,000 by November 1, 1987 �.J in its effort to inform the low and moderate income and minority communi- ties that it serves in Florida of the lending and other services referred to in its CRA program. �, P t� The commercial call program of Suntrust will include ongoing If communications iwth realtors about its Community Affairs Policy, that will be prepared in conjunction with the CRA Taskforce, and will also .include minority businesses and community development agencies and corporations. -----Suntrust will utilize minority marketing and advertising firms in its efforts to better inform such low and moderate income and minority a communities of its services, with the goal that no less than 10% of the r contracts to outside suppliers used by Suntrust in these efforts be ,awarded to minority advertising or marketing firms. In this connection, lSuntrust will welcome pertinent input regarding prospects to target and minority firms to use. B. Suntrust will staff at least one Community Affairs officer -2 5- 86--942 W ime responsibility will be to, throughout Florida.: ssess and coordinate the community outreach ;forts of the various Suntrust banks; isure that the Suntrust CRA program is being irried out throughout Florida; :t as a liaison in the involvement of Suntrust ersonnel in community activities, fundraising and ervice; and e a central focal point for corporate involvement trough charitable giving, government liaison and elated matters. Suntrust subsidiary bank in Florida will staff at least one community affairs officer whose responsibilities, full-time if necessary to meet the needs of the community, will be similar to the statewi-le Commu- nity Affairs function, but for the subsidiary bank's service area. Each Community Affairs officer will report to the appropriate level of senior management of Suntrust. -4. Suntrust will take affirmative steps to solicit home mortgages and other home -related loans, commercial, small business, agricultural and community development loans to all minorities and in low and moder- ate income communities. In this regard, Suntrust will make vigorous .,�. a efforts to originate at least $75,000,000 in such loans in tow d moder- ate income communities over the next lz months, and in subsequent years, except in adverse economic conditions. This figure is not an allocation of credit, but an expression of commitment and good faith to its customers in these areas. The loan program will be responsive to -26- 86-942 the growing credit needs of these areas, and will target low and moder- ate income housing, small business and commercial real estate projects. Property to be financed must be located within qualifying areas that will consist of census tracts which have a median income equal to or Iess than 80% of the median household income of the county in which the tract is located. Suntrust's loan program will consist of: * home mortgage and home improvement loans for 1-4 family dwellings for low and moderate income and minority residents. In this connection Barnett will offer FHA, VA and Farmers Home Administration loan programs, including FHA home improvement loans. Borrowers must reside in a qualifying area at the time of the application, and must agree to reside in the property to be purchased or renovated; * permanent mortgage loans and construction or rehabilitation loans to, and equity investments in, nonprofit and other developers for new construction and rehabilitation of housing for low and moderate income and minority residents. Suntrust will not approve applications for projects under this para- graph that would result in the displacement of residents unless suitable replacement housing is - provided to such residents; and Ln ; loans for, and equity investments in, small business y. . with annual sales of less than $5 million in such low or moderate income areas. Loan categories will -2T- 86 -942 include building construction, building improvement, ' machinery/equipment, and working capital. Suh- trust will not pprove applications for projects under this paragraph that would result in the displacement of residents unless suitable replace- ment housing is provided to such residents. In conducting its loan program, Suntrust: • will use its general underwriting criteria, terms and conditions and will use its best efforts to be as flexible as possible in applying these standards. Measures which may be used include: (a) considering location of property in a low and moderate income area to be a positive factor in applying its loan underwriting criteria; (b) using appraisers who are mutually accept- able to Suntrust and the borrower; (c) including government sources of income in calculating applicant income; (d) including self employment and part time employment earnings in calculating income; (e) using income continuity regardless of employer where such an income pattern exists; L (f) accepting as wi:iitC,i verification of income notarized letters from employers, official letters from government agencies, and W-2 forms; -� -28- 8F-942 (g) not disqualifying an applicant on the basis of lacking a prompt payment history where other factors are present that indicate the history should not form a basis for denying the applicant. Such factors shall include a record of prompt payment within the past year, events beyond the applicant's control, and refused offers of payment made within a reasonable time. * will make favorable pricing available. Measures which may be used include 2% below market rate interest, waiver of points for single family perma- nent mortgage and small business loans, a standard loan term for single family permanent mortgage loans of 30 years, acceptance of non-traditional sources of equity, such as sweat equity, and other measures; • will develop programs to minimize closing and related costs for low and moderate income borrowers; + will refund the regular application fee if the loan is not approved; and * will take an active role and serve as a catalyst in assisting in the development with other banks of loan programs that will help to meet the credit needs of low and moderate income neighborhoods, and may seek government and alternative resources _29- _A Y • �j ouch as grants, loan guarantees or interest write / downs . -- D. Suntrust will have a minority enterprise lending policy provid- ing that any lending officer may approve a minority enterprise loan within his or her lending limit, and that in order for a minority enter- prise loan request to be turned down the cancurrence of at least two lending officers will be required. Bank officers will develop management assistance teams in their communities to assist minority business enterprises. Management assis- lance, such as legal advice, account services and technical expertise from private industry is recognized by Suntrust as essential to continued viability of borrowers. Each city office in Florida will designate at least one lending officer to be responsible for monitoring the availability of minority loan programs to assist the bank or minority businesses. E. Suntrust will staff at least one lending resource officer whose full-time responsibility will be to assist bank lending officers, customers and potential customers throughout Florida with such programs as: (i) Small Business Administration loan programs and certified development company programs; (ii) Neighborhood Housing Services programs; . (iii) Urban Development Action Grants; (iv) Community Development Block Grant Programs for housing and economic development; �� : � (v) FHA, VA and Farmers Home Administration •s . loan programs, including FHA home _improve - went loan programs; -30-� • •. _. _ _ _ _ ,., ,_ .:" t.�,1�xN *�1'`�+4`' � + �} =..#�L �T�aS�ye �d .€;;�st• Ee. "f �.� ;?�„ __ _ `s .. (vi) Specialized state and county mortgage pro- grams; and (vii) Other minority or government loan programs available to the bank's customers. Each Suntrust subsidiary bank in Florida will staff at least one lending resource officer whose responsibility, full-time if necessary to meet the needs of the community, will be to assist bank lending officers, customers and potential customers with such programs. Each lending resource officer will report to the appropriate level of senior management of Suntrust. F . Suntrust encourages and supports worthwhile charitable programs, including those within low and moderate income and minority communities. The company will pay particular attention to low income area community -oriented and community -based development organizations in determining the needs of the community for charitable contributions. Suntrust will make contributions to low income area community -oriented and community -based development organizations. Suntrust, with input from the CRA Taskforce, will develop guidelines on making contributions to community -oriented and community -based organizations. G . Suntrust recognizes that community development corporations are important vehicles for promoting economic development benefiting low and moderate income and minority communities. Suntrust -will support appropriate efforts of community development corporations which meet these needs. As part of this commitment, Suntrust will promptly evaluate and respond to specific proposals to provide financial .support to financial intermediaries to assist community development corporations serving low and moderate income communities and minorities. R �• i Suntrust will: • supply technical assistance to community -based development corporations in Florida, in such areas as financial analysis, marketing, loan packaging and servicing, and financial brokering; * participate in cxtcnsions of credit for such community -based development corporations, consis- tent with safe and sound banking practices; and • * make direct contributions to and/or investments in such community -based community development cor- porations . Suntrust would be especially receptive to receiving and considering any surveys or other studies provided by the CRA Taskforce, its clients, or community members pertinent to the banking needs of the local communities that it serves. H. Suntrust supports the concept of providing "life -line" or basic banking services on a reduced cost basis, directed toward low income groups and senior citizens. Suntrust will enact a "life -line" or basic banking service on or before January 1, 1987. In this connection, Suntrust will welcome pertinent input that the CRA Taskforce, its clients, or members of the community can provide. The services of basic banking shall consist of: +' a policy of cashing government checks without charge for customers and noncustomers alike; and * the establishment of accounts for which there are: (a) a maximum of 12 checks per month; (b) no charges or fees other than a total amount -32- 86;-942 targes of no more than $5 for a check that is -ned one or more times; direct deposit of government checks; free access to automatic teller machines; no opening, minimum or average deposit balance irement; holding of checks for a maximum of three ing days for local checks, and five working for out-of-town checks; and no requirement of financial documentation to the account.' an effort to further improve communications between Low and moderate income groups and minorities, Suntrust will elect an individual to the holding company's board of directors for Florida, and each of Suntrust's banking subsidiaries' boards of directors, -_ — from low and moderate income groups, minority groups or other commu- nity groups, involved s, who P are representative of low and moderate income groups and minority groups. These efforts will begin by November 1, 1986 with a goal of accomplishing this by March 1, 1988. J. The Community Affairs officer of each Suntrust banking �y - _ subsidiary will ensurt bank representatives from the subsidiary meet -- with minority an and moderate income community representatives at least twice a year, with legal services involvement. These meetings will include discussf the community reinvestment and credit needs of the community, notification of bank contacts for community affairs matters, i . and Suntrust's efforts to meet these needs. Reasonable notice will be made to the local community prior to these meetings. -33- 1bI=a 9 K . Suntrust will assure that each of its subsidiary banks properly deliniate the communities they serve without excluding low and moderate income areas. Suntrust will assure that hank officials are aware of their responsi- bility in carryin Suntrust's CRA policy, as well as their responsibilities under the CRA and other similar laws. L. Suntrust will arrange a meeting with bank presidents or senior officers from each Florida city in which its banks are located to assure their orientation towards the sensitivities and needs of the economically disadvantaged, the Suntrust philosophy, and the manner in which that philosophy will be implemented in Florida. Suntrust will conduct seminars or meetings with lending officers and staffs of each of its Florida banks for the purposes of advising them of the Suntrust commitment and philosophy, the purpose and function of the enterprise/community banking group and the community affairs office, and related matters. M. Suntrust will actively assist the initiation and operations of govermental and/or private community -based agencies which are engaged in providing counseling regarding home financing and other types of credit to low and moderate income homeowners and low and moderate income consumers. Such assistance may take the fornecessary financing as well as volunteer aid. Suntrust will also service loans consistent with the purposes of this policy to further low and moderate income and minority housing and economic development. As one method of doing j^ - �, this, Suntrust will use collection letters to encourage the use of credit counseling services on appropriate collection accounts. of low and moder- ate income persons. The program will use a form letter which offers to -34- s • • _ S. •�. ate :c .n refrain from immediately filing suit to collect a debt if the debtor consults writh an acceptable credit counseling service, and if the debtor and the credit counseling service contact Suntrustwithin a stated period of time with a mutually satisfactory repayment plan. N. Suntrust will conduct community needs assessment studies in all metropolitan areas of Florida where it conducts its banking operations or into which it expands in Florida, that will seek to determine banking product and credit needs of low and moderate income groups and minorities within these areas, and list and describe resources available to meet these needs. These studies will be conducted by third party consultants under contract' to Suntrust, and will include input from community based organizations, community development organizations other interested or concerned parties. By February 1, 1987, Suntrust will commence such studies for migrant farm workers in Florida, and in Palm Beach County. Lee County, Collier County, and Martin -St. Lucie Counties. U. Suntrust states its opposition to displacement of residents in low and moderate income and minority communities resulting from development in those communities. Suntrust will not pursue a proposed community development project that would result in the displacement of residents in these communities unless suitable replacement housing is provided to such residents. P. Suntrust will establish new branch offices to better serve the low and moderate income and minority communities that it serves in 11orida. To this end, Suntrust would welcome input from community "organizations regarding particular areas within such communities that currently are inadequately served, and will act upon this input to -35- 86 -942 determine whether there is a need for new branch offices in such areas. The establishment of any new branch by Suntrust will be dependent upon the satisfactory completion of an economic feasibility study which will take into consideration, and in appropriate cases use as the justification for the opening of the branch, the community's need for a branch office. Q. Su trust will meet quarterly with representatives of the CRA Taskforce to discuss and monitor the activities of Suntrust in carrying out this CRA program. Respectfully submitted, 4 6HN M. LITTLE egal Services of Greater Miami, Inc. A JE NG Florida Ri6,61 Legal Services - /,/&(-; 4--:� - -- EN LqOOUX acksonville Area Legal Services If A N JED Work oup SG--94A,