Inner City Press Presents:

CitiFinancial (& WaMu Finance & the law) State-by-State:

Predatory Bender: Not Just a Book Title, It's What Citi's On

WaMu Finance states, click on name to go there: Alabama, California, Delaware, Florida, Georgia, Idaho, Illinois, Indiana, Kansas, Kentucky, Louisiana, Maryland, Mississippi, New Mexico, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, South Carolina, Tennessee, Texas, Utah, Virginia, Washington, West Virginia (others states below, too, alphabetically)

Alabama

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has 18 branches in the state of Alabama. On December 1, 2003, Inner City Press submitted this comment to the Alabama State Banking Department:

Dear Superintendent Humphries, Ms. Bressler, others:

   On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its nineteen branch offices in Alabama. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in your state.

   That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by your web site, which lists the following offices:

--http://www.bank.state.al.us/ACCA_licenses.asp?search=washington+mutual

  Click here for the continuation of ICP's Comment    Here's the state of the (state) law:

   A proposed Alabama Predatory Lender's Act, a/k/a "Consumer Equity Protection Act," House Bill 29, Senate Bill 204 -- was introduced March 4, 2003, got referred to committee - and was then apparently forgotten. Here are some related proposals, --House Bill 529; Senate Bill 273; HB 206 (all in pdf format) and the Alabama State Legislature. On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its office in Alabama (709 Azalea Road in Mobile) into a branch of a federal savings bank, to escape state laws...

  ICP/Fair Finance Watch has for example fought Birmingham-based AmSouth, when it made a move on First American / Deposit Guaranty (see “Groups Say Loan Denial Rates High,” The Tennessean), which later settled (see  “Bank settles 'unfair lending' claims,” The Tennessean).

  In Predatory Bender, Tom Bain tracks Amsouth.  Jack Bender and his daughter Zalie, starting from their days together in Charlotte, North Carolina, have always liked Waffle House.  What's not to like?

This - here are five CitiFinancials in and around Birmingham, AL:

260-E West Valley Avenue, Birmingham, AL 35209 - 205-945-9484
5415 Beacon Drive, Birmingham, AL 35210 - 205-956-0040
266 Gadsden Highway, Birmingham, AL 35235 - 205-833-2867
655 Fieldstown Road, Gardendale, AL 35071 - 205-631-9900
174 Centre At Riverchase, Birmingham, AL 35216 - 205-823-7997

Return to Predatory Bender's Citi States Map, @ Inner City Press

Alaska

State Mortgage bank Regulator:
Alaska Division of Banking Securities & Corporations

  Here ICP/Fair Finance Watch, along with Alaska PIRG, fought Wells Fargo Financial, see, “Watchdogs Challenge Wells Fargo's Alaska Plans,” by Ron Leuty, San Francisco Business Times, April 24, 2000, and, from grassroots newspaper not on the Web, “Groups Want to Halt Wells Fargo Merger,” by E. Burkett, Mat-Su Valley Frontiersman (Alaska), April 25, 2000, Pg. A1; “Move to Delay National Bank of Alaska Takeover,” Kodiak (AK) Daily Mirror, April 19, 2000, etc.. The town of Homer, on the Kenai peninsula, helped inspired Inner City Press' Alaska Report. Among ICP's Alaska favorites is this site for pro se litigants. Its side focus on domestic violence would not favor Jack Bender -- maybe that's why Jack hasn't yet been to Alaska...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Arizona

State Mortgage bank Regulator:
Arizona State Banking Department

  In February 2003, House Bill 2414, "Home loans; prohibited activities," was introduced.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its nine offices in Arizona into branches of a federal savings bank, Chase FSB, to escape state laws... Also in Feb. 2003, ICP/Fair Finance Watch filed the following Freedom of Information appeal, with the Arizona Attorney General's office, regarding real-live predatory lender Household International:

Dear Assistant AG Kane, Attorney General Goddard, and FOI Appeals Officer:

   On behalf of the Inner City Press/Community on the Move and its members, and of the Fair Finance Watch (collectively, "ICP"), this replies to, and appeals from, Assistant Attorney General Kane's Feb. 11, 2003, letter (the "Denial") denying access to records responsive to ICP's Jan. 10, 2003, request.

   Despite the arguments made in AAG Kane's Denial, we wish to inform you that we have received from other states' Offices of Attorney General numerous documents, including many sent to and from to <sandra.kane [at] AG.state.AZ.US >. Given that some of these communications are with regard to the payment of funds to the State of Arizona and to other states, under most readings of the public disclosure statute this makes their withholding, in the face of the month-old request, particularly inappropriate. ICP's focus, however, is that your Office address Household's and HSBC's characterizations of the Settlements, to regulators and to the public. These documents make it clear that many the records to which AAG Kane is denying access are otherwise publicly available, and are not viewed as falling within the (identical) confidentiality provisions of the Household Consent Judgments (which ICP in any event contends are contrary to public policy and the principles of open government, see below).

   The remainder of the Denial seems to claim (1) that a requested "financial analysis" (referred to on the Washington State Attorney General's web site) is somehow "attorney" work product (in this regard we note that other states' AG's Offices have provided us with various financial reports they collected / considered during the multi-state negotiation with Household); (2) that the investigations of Household are still "pending" (despite the release in the Consent Judgment -- if the argument is that until all funds are paid in March, it's all confidential, that logic is contrary to public policy: no review of governmental deal until five months after it was announced, and three months after it was filed in court, and portrayed as "final" by the allegedly predatory lender - see also, Cox Arizona Publications, Inc. v. Collins, 175 Ariz. 11, 14, 852 P.2d 1194, 1998 (1993), wherein the Arizona Supreme Court reversed the court of appeals' ruling that the public is not entitled to examine police reports in "an active ongoing criminal prosecution." The Arizona Supreme Court held that such a "blanket rule… contravenes the strong policy favoring open disclosure and access." Thus, public officials bear the "burden of showing the probability that specific, material harm will result from disclosure" before it may withhold police records. Mitchell v. Superior Court, 142 Ariz. 332, 335, 690 P.2d 51, 54 (1984) -- and (3) that all "inter-agency" communications can be withheld. By that logic, a comment letter by the Attorney General to, for example, the Federal Reserve, in a rulemaking proceeding, would be withheld. That clearly is not the law. The improperly withheld records should be released, under the fee waiver ICP has requested.

   The Denial acknowledges that your Office received ICP's December 2002 letter regarding HSBC's proposed acquisition of Household; we note that we never received any response from your Office, despite the central role you played in the Settlement with Household. Please consider: we have been informed by others in the multi-state group (with whom your Office is clearly in contact, as reflected by documents we've been provided with) that they "do not have any comment on the scope of the settlement since we believe the Consent Decree adequately addressed the issue." That quote is from the Florida Attorney General's Office; it is substantially identical to a recent statement from the Washington State Attorney General's Office, which was also very involved in the Settlement, along with the New York Banking Department and Superintendent, your Office's communications with which we are specifically requesting in connection with this appeal, due to conflict of interest issues which have arisen in light of Household's Jan. 31, 2003, disclosure that it formally retained Goldman Sachs, where the N.Y. Superintendent's husband is a managing director, on May 1, 2002, to find a buyer for all or part of Household's business. Your Office's withholding of responsive records ill-serves not only consumers, including in Arizona, but also the public interest and principles of open government.

  As Jack Bender might say, "That and a token will get you on the subway." Except that, in New York City at least, they no longer accept tokens... In 2002 in the Phoenix MSA, for conventional home purchase loans, the mormally-priced CitiMortgage denied loan applications from African Americans 4.27 times more frequently than applications from whites. This is much worse than other lenders in this MSA: the denial rate disparities for the industry as a whole in 2002 were 2.0 for African Americans.   Here are three subprime-lending CitiFinancials in and around Phoenix, AZ:

5563 N. 7th Street, Phoenix, AZ 85014 - 602-266-7055
5830 N. 43rd Avenue, Glendale, AZ 85301 - 623-939-7620
9201 N 29th Avenue, Phoenix, AZ 85051 - 602-943-6601

Return to Predatory Bender's Citi States Map, @ Inner City Press

Arkansas

Arkansas Securities Department

  The Arkansas Home Loan Protection Act, House Bill 2598, became effective on July 16, 2003, as "Act 1348 of 2003." On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its three offices in Arkansas (Little Rock, Springdale and Bentronville) into branches of a federal savings bank, Chase FSB, to escape state laws...Land of Clintons and Wal-Mart, and one of the states, like Delaware, which limits access to documents under FOIA to citizens of the state. ICP appealed:

Dear Deputy Attorney General Hansen and Attorney General Beebe:

   On behalf of the Inner City Press/Community on the Move and its members, and of the Fair Finance Watch (collectively, "ICP"), this regards Mr. Hansen's Jan. 14, 2003, Denial of ICP's request, under the Arkansas Freedom of Information Act and otherwise, for records related to your Office's recent Settlement with Household International, Inc. ("Household"), etc..

   The context of ICP's request, in brief, is that Household has been charged in all fifty states with predatory lending, has entered a settlement that many consumers' organizations including FFW contend is too limited, and has now proposed to be acquired by the London-based Hongkong Shanghai Banking Corporation ("HSBC"). It is in the public interest to disclose the specifics of any and all complaints against Household (and, for comparison's sake, certain of its peers) in Arkansas, and to disclose the specifics of the Settlement in Arkansas. We note again that on Dec. 19, 2002, Household issued a press release stating that "[a]ll 50 states and the District of Columbia have agreed to participate in the program." For your information, numerous Attorney General's Offices in other state have provided ICP, without cost, with copies of complaints and other records in response to nearly identical Jan. 10, 2003, requests from ICP.

    Deputy Attorney General Hansen's Jan. 14, 2003 letter (the "Denial") provided not a single document. Rather, the Denial cites to the "citizens of Arkansas" provision of Arkansas FOIA, without addressing the case law thereunder and its applicability to ICP's request. For example, Arkansas Hwy. & Transp. Dep't v. Hope Brick Works, Inc., 294 Ark. 490, 744 S.W.2d 711 (1988), held that the FOIA's intent includes a corporation doing business in this state as being a party entitled to information. Hence, representative of corporation is entitled to receive any information that any other person would be entitled to receive pursuant to the FOIA.

    For your information, Inner City Press is inter alia a news media organization, which serves and has readership in Arkansas, including via <www.InnerCityPress.org>. While it should not be necessary, we note for example that InnerCityPress.org is listed on the Federal Financial Institutions Examination Council's Web site as a nationwide resource on the Community Reinvestment Act (see also, e.g., the Arkansas Democrat-Gazette of April 11, 1999, "The color of home loans in central Arkansas," quoting ICP on lending discrimination in central Arkansas).

   The appeal was denied - but ICP will soon (12/03) be litigating this issue, in at least one of the four states...

Return to Predatory Bender's Citi States Map, @ Inner City Press

California

State Mortgage bank Regulator(s):
California Department of Corporations
California Department of Real Estate

    CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has 28 branches in the state of California. On December 1, 2003, Inner City Press submitted this comment to both the California Department of Financial Institutions and the Department of Corporations:

Dear Commissioner Boutris, and Commissioner Meyer:

   On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its 28 branch offices in California. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, including Cal. Gov't Code § 6253 (a), for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also, in the spirit of Ms. Carlson's October 2003 communications with ICP, a formal request for a hearing, and for an investigation into CitiFinancial's practices in California.

   That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by WaMuFinance.com, which lists the following offices:

5119 Ming Ave., Bakersfield, CA 93309; 6150 Birdcage Centre Lane, Citrus Heights, CA 95610; 750 S. Lincoln Ave. #105, Corona, CA 92882; 18225 Brookhurst St. #17, Fountain Valley, CA 92708; 770 E. Shaw Ave., Ste. 120, Fresno, CA 93710; 1571 S. Harbor Blvd., Fullerton, CA 92832; 8898 La Mesa Blvd., Ste. 102, La Mesa, CA 91941; 5909 South St., Lakewood, CA 90713; 11421 Carson St., Ste. D, Lakewood, CA 90715; 17030 Devonshire St., Northridge, CA 91325; 960 N. Mountain Ave., Ontario, CA 91762; 1132 E. Katella Ave., Ste. A14, Orange, CA 92867; 2067 N. Oxnard Blvd., Oxnard, CA 93036; 508 Contra Costa Blvd., Pleasant Hill, CA 9452; 7000 Indiana Ave. #120, Riverside, CA 92506; 5419 N. Rosemead Blvd., San Gabriel, CA 91776; 4880 Stevens Creek Blvd., San Jose, CA 95129; 22803 Hawthorne Blvd., Torrance, CA 90505; 423 N. Azusa Ave., West Covina, CA 91791; 6490 Platt Ave., West Hills, CA 91307

CClick here for the continuation of ICP's Comment   Here's the state of the (state) law:

   Los Angeles passed a predatory lending ordinance, 01-1476, available here (in pdf).  Oakland passed Ordinance 001299a. Statewide, there's AB 489, adopted as Chapter 732 of 2001, and effective July 1, 2002.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 54 offices in California into branches of a federal savings bank, Chase FSB, to escape state laws... The 2002 fight against Citigroup - Golden State Bancorp (another ICP collaboration with CRC) unearthed much dirt from Citigroup's closet, including for example about the ROCopoly compensation scheme, "incenting" employees to hard-sell insurance... 

  In 2002 in the Oakland MSA for conventional home purchase loans, Citibank (Citibank FSB and CitiMortgage together) denied loan applications from African Americans a whopping 12.62 times more frequently than applications from whites. Citibank denied Latinos 7.5 times more frequently than whites. This is much, much worse than other lenders in this MSA: the denial rate disparities for the industry as a whole in 2002 were 2.66 for African Americans, and 1.87 for Latinos. Citibank's much higher-than-aggregate denial rate disparities are certainly not explained by any greater-than-normal outreach with normal-priced credit to African Americans or Latinos. For these three groups, the aggregate made 8.1% of its loans to African Americans, and 20.9% to Latinos. For Citibank, the figures were both lower: 4.8% of loans to African Americans, and 11.6% to Latinos...

   In 2002 in the Los Angeles MSA for conventional home purchase loans, Citibank (Citibank FSB and CitiMortgage together) denied loan applications from African Americans 4.43 times more frequently than applications from whites. Citibank denied Latinos 5.67 times more frequently than whites. This is much worse than other lenders in this MSA: the denial rate disparities for the industry as a whole in 2002 were 1.95 for African Americans, and 1.62 for Latinos.  As in Oakland, Citibank's higher-than-aggregate denial rate disparities are not explained by any greater-than-normal outreach with normal-priced credit to African Americans or Latinos. In 2002 in this MSA, Citibank made 357 conventional home purchase loans to whites, only 21 to African Americans, and only 122 to Latinos. For the record, the aggregate industry in this MSA in 2002 made 6619 such loans to African Americans, 28,391 to Latinos, and 54,916 to whites. For these three groups, the aggregate made 7.4% of its loans to African Americans, and 31.6% to Latinos. For Citibank, the figures were notably lower: 4.2% of loans to African Americans, and 24.4% to Latinos.

  California: land now of the Terminator,once the headquarters of Bank of America; world's sixth largest economy and its celluloid dream-space, to which Jack Bender with his daughter flees, burning rubber and more ways than one... In and around that commercial soap box,  Los Angeles, here are some CitiFinancials:

4215 Atlantic Avenue, Long Beach, CA 90807 - 562-426-5941
14408 E Whittier Boulevard, Whittier, CA 90605 - 562-698-7966
12031 Firestone Boulevard, Norwalk, CA 90650 - 562-863-4795
7808 Florence Avenue, Downey, CA 90240 - 562-927-2177
6253 Atlantic Avenue, Bell, CA 90201 - 323-771-2707    A bit further south:

2278 East Lincoln Avenue, Anaheim, CA 92806 - 714-535-2247   
13771 Newport Avenue, Tustin, CA 92780 - 714-734-9454
10130 Warner Avenue, Fountain Valley, CA 92708 - 714-964-8389

   Then all the way to the Mexican border and beyond...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Colorado

Colorado Department of Law

    New predatory lending regulations are effective in Colorado on January 1, 2003 - click here for the guidelines, published by the Colorado Attorney General; also, 2003 Session Laws, Chapter 295.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its ten offices in Colorado into branches of a federal savings bank, Chase FSB, to escape state laws... Meanwhile, Colorado is another battleground with Wells Fargo Financial, see "Wells Fargo Accused of Predatory Lending," Denver Post, July 29, 2003, and "Wells Fargo Accused of Unfair Lending," Rocky Mountain News, July 29, 2003, Pg. 6B. Here's four CitiFinancials around Denver:

98 Wadsworth Boulevard, Lakewood, CO 80226 - 303-235-0673
650 S. Wadsworth Boulevard, Lakewood, CO 80226 - 303-727-8302
7450 West 52nd Avenue, Arvada, CO 80002 - 303-420-4191
334 South Chambers Road, Aurora, CO 80017 - 303-745-3230

Return to Predatory Bender's Citi States Map, @ Inner City Press

Connecticut

State Mortgage bank Regulator:
Connecticut Department of Banking

  The Connecticut Abusive Home Loan Lending Practices Act became effective on October 10, 2001... The Banking Commissioner has sued Wachovia -- but then (Nov. 2003) sought to deny a FOIA fee waiver. ICP appealed:

Dear Commissioner Burke, et al.:

   On behalf of the non-profit public interest organization Inner City Press/Community on the Move and its members and affiliates, and the Fair Finance Watch (collectively, "ICP"), this supplements two [FOIA] letters ICP has recently submitted to you... Earlier today I spoke with Don Kitt of your office, who indicated a non-favorable response to ICP's request for a fee waiver. For your information, numerous other states' banking regulators routinely grant ICP FOIA fee waivers, as do each of the federal regulators. The Connecticut statute (further discussed below) is substantially similar to those of other states which have granted ICP fee waivers. We point, for example, to. Conn. Gen. Stat. § 1-212(d), providing for fee waivers if disclosure benefits the general welfare. Annexed hereto is a fee waiver grant to ICP, from Maryland, under precisely this standard. ICP has also been granted fee waivers by state agencies in such states as Missouri (attached) Wisconsin, North Carolina, Kansas, Texas (attached), and, significantly, by the Federal Trade Commission (the "FTC"). ICP was granted a fee waiver by the FTC with regard inter alia to complaints in the FTC's possession against CitiFinancial, with which the FTC announced a predatory lending settlement in September 2002. FTC FOIA Request No. 2003-23, letter granting fee waiver annexed hereto. We would be surprised, including in light of your litigation with Wachovia and its mortgage company, if your Office consciously decided to be less transparent, and more difficult for consumer and public interest organizations to obtain documents from, than your federal counterparts...

  Connecticut, at least as to FOIA, is not a city on the hill. Although some document withholdings, including about predatory lending, do get resolved:

Dear Mr. Hennick [and others at the Connecticut Freedom of Information Commission]

  Hello. This responds to your message of October 28, 2003, and Assistant Attorney General Cobb's letter of October 24, 2003, and the attachments thereto [regarding FIC # 2003 - 088 - Inner City Press v. Attorney General]. At your suggestion, on October 3, 2003, we limited the scope of the documents, responsive to the Jan. 10, 2003, request made by Inner City Press / Fair Finance Watch ("ICP"), which we most wanted. Under cover letter dated October 24, AAG Cobb sent copies of a number of consumer complaints against Household International, represented that ICP now has "all documents in the possession of this Office concerning 'how and why the scope of the predatory lending settlement with Household was limited'" -- that is, AG Blumenthal's December 9, 2002 response to ICP's request that the settlement's scope be expanded to include loans Household makes through brokers, and e-mails among some of the AGs' offices. That these are the only responsive documents is troubling to ICP -- but the FOIC may not be the best venue in which to pursue this substantive policy, rather than FOI / transparency, issue.

  AAG Cobb's letter also states:

"Pursuant to your request for clarification... in accordance with paragraph 40 of the consent judgment entered into between Household and the States, this Office is only obligated to notify Household of any FOIA requests for documents that were either provided to the States by Household, or otherwise contain Household's proprietary information that would be exempt from disclosure... as confidential commercial or financial information."

  We appreciate the "clarification," and accept it in a sense (that is, that this is how the AG's Office will implement the consent judgments) -- but that is not what the consent judgment says; even as partially quoted by AAG Cobb, it provide for notifying Household of any requests "relative to... the negotiation of the Agreement in Principle of this Consent Judgment," etc. -- i.e., requests regarding the Attorneys General's communications, regardless of whether the communications contain Household's proprietary commercial or financial information. We still think this violates the letter and spirit of the FOI laws, and encourage the AGs office to modify these provisions of the agreement with Household. It has, however, been explained to us that the FOIC is not the venue in which this could be accomplished. Accordingly, and in light of the FOIC's (voice-mail recorded) statement of lack of resources, and in light of the AG's Office's diminishing intransigence, including on fee waivers and question-answering, once AAG Susan Quinn Cobb was assigned to this matter, ICP hereby confirms that no FOIC hearing on this appeal is necessary, on Nov. 18 (as it was re-scheduled), or otherwise.

   Not for nothing is ICP called The Peacemaker...  In the Bridgeport, Connecticut MSA for refinance loans, Citibank (Citibank FSB and CitiMortgage together) denied loan applications from African Americans 5.23 times more frequently than applications from whites. Citibank denied Latinos 6.28 times more frequently than whites. This is much worse than other lenders in this MSA: the denial rate disparities for the industry as a whole in 2002 were 3.05 for African Americans, and 2.59 for Latinos... Here's just three of the CitiFinancials in Connecticut:

656 New Haven Avenue, Derby, CT 6418 - 203-734-1646
321 Boston Post Road, Milford, CT 6460 - 203-783-9977
1040 Barnum Avenue, Stratford, CT 6614 - 203-385-8512

Return to Predatory Bender's Citi States Map, @ Inner City Press

Delaware

State Mortgage bank Regulator:
Delaware Office of the State Bank Commissioner

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has three branches in the state of Delaware. On December 1, 2003, Inner City Press submitted this comment to the Delaware Department of Banking:

Dear Commissioner Glen, others:

   On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its three branch offices in Delaware. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under Delaware's freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. We make this request as New York residents, under the privileges and immunities clause of the U.S. Constitution, see, "Lawsuit Challenges Delaware Records Law: Nonresidents Denied Use of Freedom of Information Act," Wilmington News-Journal, Nov. 27, 2003, <www.delawareonline.com/newsjournal/local/2003/11/27lawsuitchalleng.html>.This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in Delaware.

  That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by WaMuFinance.com, which lists the following offices in Delaware:

2435 Kirkwood Hwy., Wilmington, DE 19805

4601 S. DuPont Hwy., Ste. 6, Dover, DE 19901; and

619 N. DuPont Blvd., Milford, DE 19963

Click here for the continuation of ICP's Comment   Here's the state of the (state's) laws:

   Given the flocking of corporations, water-craft and credit card companies to Delaware, ICP has an ongoing Delaware Watch, click here to view... On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its three offices in Delaware (Dover, Newark and Dehoboth Beach) into branches of a federal savings bank, Chase FSB, to escape state laws. On October 30, 2003, the state banking commissioner approved -- in part because Chase FSB would be based in Delaware... The state's lucky to have advocates, less lucky to have an insurance commissioner who's elected, and who takes campaign contributions from the industry, including Household and Citigroup... Meanwhile, state agencies claim that Delaware's FOIA is only for state residents - something about to be challenged. Developing... Here's just two of the CitiFinancials in Delaware; these are in Wilmington:

3505 Silverside Road, Wilmington, DE 19810 - 302-478-8070
4541 Kirkwood Hghwy, Wilmington, DE 19808 - 302-994-5721

Return to Predatory Bender's Citi States Map, @ Inner City Press

District of Columbia

State Mortgage bank Regulator:
District of Columbia Office of Banking & Financial Institutions

  The DC Home Loan Protection Act became effective March 6, 2002; there's also the regulation, Title 26A of the DC Code, Chapter 20 of 2002. This is governmental ground-zero, and base of NCRC, and yet the predators run wild. See, for example, Hargraves v. Capitol City Mortgage Corp. (D.D.C.), the summary and/or a DOJ amicus brief...   In 2002 in the Washington DC MSA for conventional home purchase loans, Citibank (Citibank FSB and CitiMortgage together) denied loan applications from African Americans 5.67 times more frequently than applications from whites. Citibank denied Latinos 3.03 times more frequently than whites. This is much worse than other lenders in this MSA: the denial rate disparities for the industry as a whole in 2002 were 3.04 for African Americans, and 2.38 for Latinos. For refinance loans in this MSA in 2002, Citibank denied applications from African Americans 4.38 times more frequently than applications from whites. This is much worse than other lenders in this MSA: the comparable denial rate disparities for the industry as a whole in 2002 were 3.06 for African Americans... Here are sample CitiFinancials, one above and one below DC:

13486 New Hampshire Avenue, Silver Spring, MD 20904 - 301-622-6503
7219 Commerce Street, Springfield, VA 22150 - 703-866-4950

Return to Predatory Bender's Citi States Map, @ Inner City Press

Florida

State Mortgage bank Regulator:
Florida Department of Banking & Finance

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has 29 branches in the state of Florida. On December 1, 2003, Inner City Press submitted this comment to the Florida Department of Financial Services:

Dear Director Saxon, others:

   On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its 29 branch offices in Florida. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, including Fla. Stat. § 119.01(a), for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in Florida.

  That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by WaMuFinance.com, which lists the following offices in Florida:

1963 W. Lumsden Rd., Brandon, FL 33511; 4650 Cleveland Ave., Ste. 1B, Ft. Myers, FL 33907; 1993 S. Federal Hwy., Ft. Pierce, FL 34950; 4401 NW 25th Pl., Ste. L, Gainesville, FL 32606; 9825 San Jose Blvd., Unit 35, Jacksonville, FL 32257; 7001 Merrill Rd., Ste. 30, Jacksonville, FL 32211; 2510 W. US Hwy 90, Ste. 103, Lake City, FL 32055; 3207 S. Florida Ave., Lakeland, FL 33803; 3665 E. Bay Dr., Ste. 212, Largo, FL 33771; 4412 N. University Dr., Lauderhill, FL 33351; 2229 N. Citrus Blvd. #6, Leesburg, FL 34748; 5000 Stack Blvd., Ste. A-5, Melbourne, FL 32901; 7094 S.W. 117th Ave., Miami, FL 33183; 1242 N. Airport Rd., Ste. 700, Naples, FL 34104; 4776 US Hwy. 19, New Port Richey, FL 34652; 515 N.E. 25th Ave., Ocala, FL 34470; 6436 W. Colonial Dr., Orlando, FL 32818; 5037 Crill Ave., Palatka, FL 32177; 6024 N. 9th Ave., Ste. 4, Pensacola, FL 32504; 3405 McLemore Dr., Pensacola, FL 32514; 935 N. Beneva Rd., Ste. 713, Sarasota, FL 34232; 1301 Beville Rd., Ste. 4, South Daytona Beach, FL 32119; 168 State Rd. 312, St. Augustine, FL 32086; 4362 66th St., N., St. Petersburg, FL 33709; 1252-D S. Walnut St., Starke, FL 32091; 500 Capital Cir. SE., Ste. B-1, Tallahassee, FL 32301; 7520 W. Waters Ave., Ste. 10, Tampa, FL 33615; 5661 E. Fowler Ave., Tampa, FL 33617; 2695 N. Military Trail #1, West Palm Beach, FL 33409; 1963 W. Lumsden Rd., Brandon, FL 33511; 4650 Cleveland Ave., Ste. 1B, Ft. Myers, FL 33907; 1993 S. Federal Hwy., Ft. Pierce, FL 34950; 4401 NW 25th Pl., Ste. L, Gainesville, FL 32606; 9825 San Jose Blvd., Unit 35, Jacksonville, FL 32257; 7001 Merrill Rd., Ste. 30, Jacksonville, FL 32211; 2510 W. US Hwy 90, Ste. 103, Lake City, FL 32055; 3207 S. Florida Ave., Lakeland, FL 33803; 3665 E. Bay Dr., Ste. 212, Largo, FL 33771; 4412 N. University Dr., Lauderhill, FL 33351; 2229 N. Citrus Blvd. #6, Leesburg, FL 34748; 5000 Stack Blvd., Ste. A-5, Melbourne, FL 32901; 7094 S.W. 117th Ave., Miami, FL 33183; 1242 N. Airport Rd., Ste. 700, Naples, FL 34104; 4776 US Hwy. 19, New Port Richey, FL 34652; 515 N.E. 25th Ave., Ocala, FL 34470; 6436 W. Colonial Dr., Orlando, FL 32818; 5037 Crill Ave., Palatka, FL 32177; 6024 N. 9th Ave., Ste. 4, Pensacola, FL 32504; 3405 McLemore Dr., Pensacola, FL 32514; 935 N. Beneva Rd., Ste. 713, Sarasota, FL 34232; 1301 Beville Rd., Ste. 4, South Daytona Beach, FL 32119; 168 State Rd. 312, St. Augustine, FL 32086; 4362 66th St., N., St. Petersburg, FL 33709; 1252-D S. Walnut St., Starke, FL 32091; 500 Capital Cir. SE., Ste. B-1, Tallahassee, FL 32301; 7520 W. Waters Ave., Ste. 10, Tampa, FL 33615; 5661 E. Fowler Ave., Tampa, FL 33617; 2695 N. Military Trail #1, West Palm Beach, FL 33409

Click here for the continuation of ICP's Comment  Here's the state of the (state) law:

  The Florida Fair Lending Act, formerly known as Senate Bill 2262, "provides legislative findings; specifies prohibited acts re high-cost home loans; specifies required disclosures for high-cost home loans; requires lenders of high-cost home loans to provide notice to borrowers prior to taking foreclosure actions; allows borrower to cure default; provides that lender who violates this act forfeits interest in high-cost home loan; " etc.. Effective Oct. 2, 2002, its main purpose is to preempt all municipalities' and counties' anti-predatory lending legislation...

  Among various Florida campaigns, there are these, of predatory lending, redlining, and even money-laundering: "Group Targets Meritage Loan Practices," by Mark Gordon, Florida Times-Union (Jacksonville), January 15, 2002, Pg. F1;  "SunTrust buy challenged: Bronx jeer: NYC group questions minority lending, terrorist accounts in Florida," Orlando Business Journal, December 10, 2001

  Despite hoopla about Florida's open records law, and the availability of autopsy photos of crashed NASCAR drivers, ICP found the Florida Attorney General's Office to be among the least responsive:

Dear Assistant AG Mary Ann Clark, Attorney General Crist, and FOI Officer:

   On behalf of the Inner City Press/Community on the Move and its members, and of the Fair Finance Watch (collectively, "ICP"), this regards and appeals from Assistant Attorney General Clark's Jan. 27, 2003, letter purporting to unilaterally extend the time to provide records responsive to ICP's Jan. 10, 2003, formal request for records related to your Office's recent Settlement with Household International, Inc. ("Household"), etc.. After a 17-day delay, we are told that the Office of Civil Rights "will notify you of our response in a timely fashion." But this non-responsive response is already untimely. For your information, numerous other states' offices of the attorney general have already provided responsive documents, including summaries of complaints against Household, and copies of their communications with Household. For the reasons set forth below, ICP is troubled by your Office's delay, and intuits that it may be attributable to the highly-questionable agreement to privatize public records that is contained in some states' December 2002 settlement with Household. Along with the already-delayed records we requested on Jan. 10, 2003, we ask to be provided with copies of any and all communications between your Office and Household regarding requests for Settlement-related information, and with an explanation of how Chapter 119, Florida Statutes, is not violated by the concluding sections of your Office's settlement agreement with Household.

   The context of ICP's request, in brief, is that Household has been charged in all fifty states, including Florida, with predatory lending, has entered a settlement that many consumers' organizations including FFW contend is too limited, and has now proposed to be acquired by the London-based Hongkong Shanghai Banking Corporation ("HSBC"). It is in the public interest to disclose the specifics of any and all complaints against Household (and, for comparison's sake, certain of its peers) in Florida, and to disclose the specifics of the Settlement in Florida.

   On Dec. 3 and Dec. 9, 2002, ICP/FFW asked your Office to consider the ramifications of the Nov. 14 proposal by Household be to acquired by HSBC Holdings plc ("HSBC") prior to finalizing the settlement. On Dec. 9, 2002, AAG Clark wrote to ICP that " You raise important questions, which I believe are best addressed in the context of state and federal regulatory proceedings related to approval of that transaction."

   As stated in our Jan. 10, 2003, request, we need these records in connection with the "state and federal regulatory proceedings" to which AAG Clark referred. On Dec. 18, 2002, AAG Clark responded to ICP's Dec. 9, 2002, letter, stating that "The Florida Attorney General shares your concern for consumers and appreciates hearing your thoughts regarding this settlement. On Friday, December 13, 2002 this Office and representatives of Household submitted a Consent Decree to the Court...". Now the Consent Decrees are being used by HSBC as a basis on which its applications to acquire Household should be approved, without any public hearings, and your Office has already delayed 17 days and counting in providing any documents about the settlement. This is why the already 17-day delay is galling. This letter should be considered an appeal; it should be considered by the ultimate decision-maker at your Office on record requests under Chapter 119, Florida Statutes.

   To expedite matters, we note that Fla. Stat. § 119.07(3)(l)(1) only allows (while not requiring) withholding of records "prepared by an agency attorney... which reflects a mental impression, conclusion, litigation strategy, or legal theory of the attorney or the agency... until the conclusion of the litigation or adversarial administrative proceedings." Emphasis added. The Household litigation / proceeding has concluded (see supra) -- the responsive records must be released.

   But they never were... Here's just three of the CitiFinancials in Florida, these in Miami:

8223 W. Flagler Street, Miami, FL 33144 - 305-262-4670
5352 West 16th Avenue, Hialeah, FL 33012 - 305-820-0270
7508 SW 117th Avenue, Miami, FL 33183 - 305-598-0018

Return to Predatory Bender's Citi States Map, @ Inner City Press

Georgia

State Mortgage bank Regulator:
Georgia Department of Banking & Finance

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has 15 branches in the state of Georgia. On December 1, 2003, Inner City Press submitted this comment to the Georgia Department of Banking & Finance:

Dear Commissioner Sorrell, Dep. Commissioner Bechtel, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its 15 branch offices in Georgia. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in Georgia.

    That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by WaMuFinance.com, which lists the following offices in Georgia:

2622 Dawson Rd., Albany, GA 31707; 164 W. Clayton St., Athens, GA 30601
10 Huntington Rd., Ste. A-5, Athens, GA 30606; 2115 Windsor Spring Rd., Augusta, GA 30906; 3412 Wrightsboro Rd., Ste. 901, Augusta, GA 30909; 2730 Manchester Expy., Ste. A, Columbus, GA 31904; 1525 N. Expressway, Griffin, GA 30223; 119 Main St., LaGrange, GA 30240; 3654 Eisenhower Pkwy., Ste. A, Macon, GA 31206; 2926 Canton Hwy., Marietta, GA 30066; 1510 Southlake Parkway, Morrow, GA 30260; 130 Hicks Dr., Rome, GA 30161; 13040 Abercorn St., Savannah, GA 31419; 1835 E. Park Place Blvd., Stone Mountain, GA 30087; 1803 Knight Ave., Waycross, GA 31501

Click here for the continuation of ICP's Comment  Here's the state of the (state) law:

  This was the locus of showdown, because democracy (and the state legislature) and the subprime lenders, including Chase Manhattan, which is trying to convert its twelve offices in Georgia into branches of a federal savings bank, Chase FSB, to escape state laws... The rating agencies, Standard & Poor's and Fitch, conspired to overturn legislation by threatening to refuse to rate pools of loans made in the state.  HB 1361, October 2002, preempted all municipalities' and county's legislation (for example, Tlanta's Ordinance 01-O-0843 and 01-O1488, and DeKalb County's Predatory Lending Ordinance of 2001. "How does it feel," some asked Georgians, "to be treated with a Third World country?"

Return to Predatory Bender's Citi States Map, @ Inner City Press

Hawaii

State Mortgage bank Regulator:
Hawaii Department of Commerce and Consumer Affairs

Introduced on the same day - Feb. 10, 2003 -- were HB 374 - the :Hawaii Home Loan Protection Act to protect the homes and equity of individual borrowers," and HB 1438 - (prohibiting mortgage brokers from engaging in predatory lending practices)...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Idaho

State Mortgage bank Regulator:
Idaho Department of Finance

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has five branches in the state of Idaho.  On December 1, 2003, Inner City Press submitted this comment to the Idaho Department of Finance:

Dear Director Gee, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its five branch offices in Idaho. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, including Idaho Code § 9-338, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also, in the spirit of our communications regarding Household International and its sale of Orchard Bank to Panhandle State Bank, a formal request for a hearing, and for an investigation into CitiFinancial's practices in Idaho.

    That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by WaMuFinance.com, which lists the following offices:

1551 S. Five Mile Rd., Boise, ID 83709;
240 S. Woodruff Ave., Idaho Falls, ID 83401;
1702 21st St., Ste. 109, Lewiston, ID 83501;
396 Yellowstone Ave., Ste. A, Pocatello, ID 83201; and
1139 Falls Ave., Ste. E, Twin Falls, ID 83301

Click here for the continuation of ICP's Comment.  Here's the state of the (state) law:

  Idaho, or at least its Attorney General's Office, shamelessly accommodated Household in late 2002, allowing Household to jettison its subprime credit card-lending Orchard Bank, to Panhandle State Bank, connoting either change-begging or pancakes.  ICP commented -- see, "Group Challenging Purchase by Panhandle: Complaint Seeks Review of Banks' Lending Practices," The Spokesman-Review (Spokane, WA), November 27, 2002 -- but the Idaho regulator hauled off and approved the sale, while the Idaho attorney general's office withheld virtually all documents about the settlement with Household... Click here to view HB 28, "A Bill to Amend the Licensing Practices For Mortgage Brokers Or Mortgage Bankers."

Return to Predatory Bender's Citi States Map, @ Inner City Press

Illinois

State Mortgage bank Regulator:
Illinois Office of Banks & Real Estate

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has seven branches in the state of Illinois. On December 1, 2003, Inner City Press submitted this comment to the Illinois Department of Financial Institutions:

Dear Mr. DeSusa, Ms. Byrne, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its seven branch offices in Illinois. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in Illinois.

    That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by your web site, which lists the following offices:

WASHINGTON MUTUAL FINANCE, LLC: 305 S. KENNEDY DRIVE, BRADLEY IL 60915; 2525 N. MAIN STREET, DECATUR IL 62526; 434 E. 162ND ST., SOUTH HOLLAND IL 60473; 100 E. ROOSEVELT RD. SUITE 34, VILLA PARK IL 60181; 8605 W. 95TH ST., HICKORY HILLS IL 60457; 1530 LAKELAND BLVD., MATTOON IL 61938; 1713 FORT JESSE RD., UNIT F, NORMAL IL 61761; as well as WASHINGTON MUTUAL FINANCE, LLC, 3405 MCLEMORE DRIVE, PENSACOLA FL 32514

Click here for the continuation of ICP's Comment.  Here's the state of the (state) law:

  On August 20, 2003, the High Risk Home Loan Act became law. Click  here for the text of SB 1784 / PL 93-0561, in pdf format (together, as enacted, they are Public Act 93-0561); click here for an analysis. There were also Cook County Ordinance 240684 of 2001 and Chicago Ordinance SO2000-2145. On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 18 offices in Illinois into branches of a federal savings bank, Chase FSB, to escape state laws...

  Of the windy city, what's not to like? Certainly not Woodstock...  But Bank One N.A. (IL), in the Chicago MSA in 2002 for home purchase loans, denied 75% of African Americans' application, and less than one percent of (over 100) applications from whites... In 2002 in the Chicago MSA for conventional home purchase loans, Citibank (Citibank FSB and CitiMortgage together) denied loan applications from African Americans 4.23 times more frequently than applications from whites. Citibank denied Latinos 3.74 times more frequently than whites. This is worse than other lenders in this MSA: the denial rate disparities for the industry as a whole in 2002 were 3.83 for African Americans, and 2.62 for Latinos... Here's just three of the CitiFinancials in Illinois: Chicago and lovely Oak Park:

6500 Irving Park Road, Chicago, IL 60634 - 773-283-4200
5533 West Cermak Road, Cicero, IL 60804 - 708-652-4435
1119 Lake Street, Oak Park, IL 60301 - 708-386-6272

Return to Predatory Bender's Citi States Map, @ Inner City Press

Indiana

State Mortgage bank Regulator:
Indiana Department of Financial Institutions

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has a branch in the state of Indiana. On December 1, 2003, Inner City Press submitted this comment to the Indiana Department of Financial Institutions:

Dear Director Phillips, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its branch office(s) in Indiana. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, and Ind. Code § 5-14-3-8(k), for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. See, e.g., <www.in.gov/pac/advisory/2003/2003fc17.html>. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in Indiana.

    That CitiFinancial's target, WaMu Finance, is under your jurisdiction, is reflected by your website, which at <www3.dfi.state.in.us/dfidb/frlicid.asp?licid=7772> lists

WASHINGTON MUTUAL FINANCE/ BLAZER FINANCIAL SERVICES INC OF INDIANA
License Type: Licensed Lenders
Business Description: LICENSED LENDER GENERAL FIN
8395 KEYSTONE CROSSING, SUITE 200 INDIANAPOLIS IN

Click here for the continuation of ICP's Comment. Here's the state of the state, on matters predatory:

  Home of Conseco, which bought the subprime lender Greentree then blew up. Click here to view Senate Bill 478, concerning among other things predatory lending.  Inner City Press appealed the Indiana AG's denial of access to Household-related documents to the state's Public Access Counselor, resulting in this decision (html).   On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its five offices in Indiana into branches of a federal savings bank, Chase FSB, to escape state laws...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Iowa

State Mortgage bank Regulator:
Iowa Division of Banking

  Headquarters of Wells Fargo Financial, which shook the taxpayers down for corporate welfare and "incentives" in 2003.  Surprisingly unfriendly on FOIA, too, at least the state AG's Office, on fees:

Dear Special Assistant Attorney General William Brauch:

Thank you for your January 28, 2003, letter responding to (though in large part denying) the Public Records Act request I submitted on Jan. 10, 2003, on behalf of Inner City Press/Community on the Move and the Fair Finance Watch ("ICP"). You state among other things that "records reflecting any consideration [y]our office may have given to revisiting the Agreement reached in October following HSBC's announcement of the proposed acquisition of Household" would "not be open records pursuant to Iowa public records law," and that "[t]here are no records of communications between [y]our office and representatives of HSBC." You in essence deny our fee-waiver request, stating that your "resources, like those of most states, are stretched very thin." You ask us to narrow the scope of the one request in our Jan. 10 letter to which you state that you will provide responsive records. While this letter will narrow ICP's request, due to the impending expiration of the comment and review periods on the proposal by HSBC Holdings plc to acquire Household, this is also an appeal.

  ICP sent virtually identical public records / freedom of information requests to a number of other Attorney General's Offices; ICP has already begun to receive responsive documents, including copies of complaints, correspondence with Household, etc., under fee waivers as a non-profit public interest organization. The multi-state settlement of charges of predatory real estate lending (through Household's HFC and Beneficial branches) is a matter of public concern; we reiterate our request for a fee waiver and for timely (and incremental) production of the requested records. To expedite this, ICP's request for consumer complaints is narrowed herein: for Household, back to January 1, 1999 (the time frame of your Office's Restitution Agreement with Household); for CitiFinancial and American General, back to January 1, 2000, as you suggest.

  It is in the public interest to disclose the specifics of any and all complaints against Household (and, for comparison's sake, certain of its peers) in Iowa, and to disclose the specifics and background of Household's finalized Settlement in Iowa. For your information, the Federal Trade Commission has granted ICP's fee waiver request with regard to documents related to the FTC's recent predatory lending settlement with Citigroup -- we would be troubled if obtaining records related to Household's settlement with the states (including Iowa) proved to be significantly more difficult and expensive.

  Portions of our substantive appeal are made with reference to a Dec. 13, 2002, conference call with Ms. Kathleen Keest of your Office and with a staff member of the Office of the Washington State Attorney General .Regarding communications with HSBC, during the Dec. 13 conference call the question arose of whether the states, including your Office, would seek to expand the scope of the injunctive relief in light of Household's proposal to be acquired by HSBC (and in light of the analysis in the third item into which you've divided our request). Ms. Keest of your Office chided ICP for assuming that the states (including your Office) had not made inquiries with Household or HSBC to this effect. We are requesting any and all records in this regard; it is in the public interest to release them, regardless of the (questionable) terms of the Consent Judgements with Household, which appear to us to inappropriately privatize the public records / freedom of information laws... ICP is extremely concerned that Household International not be given any veto-rights -- or even notice -- of ICP's requests, above, that do not involve records submitted to your Office by Household. For example, your Office's communications with other non-Household parties are public records, regarding which no private corporation is entitled to advance notice of requests or release. It would be a perversion of consumer protection if, by "settling on the cheap" (see above, esp. your Item 3 and <www.wa.gov/ago/householdfinance/faq.htm>, Household became even more insulated for public scrutiny that other lenders. Accordingly, we ask you to notify Household, if at all, of only those portions of our now-clarified request which involve documents submitted to your Office by Household, and that are explicitly covered by the notice provisions of your Office's Consent Judgment with Household.

  But in Iowa and in other states, Household still gets notice of any request concerning in any way their predatory lending negotiations, whether or not the requested documents were submitted by Household.  Government in the sunshine?

Return to Predatory Bender's Citi States Map, @ Inner City Press

Kansas

State Mortgage bank Regulator:
Kansas Office of State Bank Commissioner

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has a branch in the state of Kansas. On December 1, 2003, Inner City Press submitted this comment to the Kansas State Banking Department:

Dear Commissioner Norris, Ms. Allen, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its branch office(s) in Kansas. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also, including in the spirit of Ms. Allen's Sept. 22, 2003, letter to ICP (still unresolved), a formal request for a hearing, and for an investigation into CitiFinancial's practices in Kansas.

    That CitiFinancial's target, WaMu Finance, is under your jurisdiction, is reflected by <www.osbckansas.org/DOCML/DOCMLBrokerLenderSearch/approved11-21-03.pdf>, which lists

2001-4142 Washington Mutual Finance, Inc. Lake Forest CA 1/1/04 2001-4142 Washington Mutual Finance, Inc. Pensacola FL 1/1/04 1994-3079; Washington Mutual Finance, Inc. of Kansas Shawnee KS 1/1/04 2001-4147; Washington Mutual Finance, LLC Pensacola FL 1/1/04 2001-4147 Washington Mutual Finance, LLC Bartlesville OK 1/1/04

[Note that WamuFinance.com lists Washington Mutual Finance, Kansas City, 6461 Quivira Rd., Shawnee, KS 66216]

  Click here for the continuation of ICP's Comment.   Here's the state of the state, on matters predatory:

  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its three offices in Kansas (two in Wichita and one in Overland Park) into branches of a federal savings bank, Chase FSB, to escape state laws...ICP presented (Household) predatory lending exhibits to the Kansas Attorney General's office:

Dear Assistant Attorney General McCabria, Consumer Protection Division:

  Thank you for your Jan. 23 response to the Kansas Open Records Act (hereinbelow, "FOIA") request I submitted earlier this month on behalf of Inner City Press/Community on the Move and the Fair Finance Watch ("ICP"). While ICP disagrees with certain of the implicit denials of access contained in your letter, and hereinbelow appeals therefrom, we appreciated your prompt provision of the Consent Judgment, and the Petition for Approval thereof. Beyond appealing from the withholding of other responsive documents, another purpose of this letter is to submit to your Office documents reflecting Household's practices even since it entered into the Consent Judgments

  We wish to bring to your attention Household's position that it does not have to comply even with the Injunctive Relief in the Consent Judgments until Dec. 31, 2003. In the public interest, we would appreciate being informed if that is your Office's reading of the Consent Judgement, specifically Paragraph 29 thereof. As you will see from the attached exhibits, it is our contention that Household is not in compliance with the spirit, and even the letter, of the Consent Judgments.

  Annexed hereto as ICP Exhibit 1 is a form, faxed on Jan. 8, 2003 from "HFC Lending" in Tampa, Florida to "Household" in Orlando, Florida which is Household's "Side Loan Matrix." It directs Household account executives to make "Side Loans" at interest rates between 18% and 21.90%. As recounted by Household CFO David Schoenholz in an Oct. 11, 2002 conference call announcing the agreement in principle, "I also want to talk about the impact of best practices in the agreement on the sales volume. The agreement only relates to our real estate volume. There's really nothing explicitly in it that should reduce volume. We previously decided to discontinue selling secured side loans at the time of closing."

  Annexed hereto as ICP Exhibit 2 is a Dec. 20, 2002 (that is, post-Settlement) version of Household's Real Estate Checklist, which among other things contains a box to fill out about the "Side Loan." This form clearly relates to the Settlement: the middle column concerns the "Borrowers' Benefits Test," but, significantly, requires less demonstrable benefits-to-the-borrower for refinancing one of Household's own loans.

  And yet the Settlement was not expanded, then or since...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Kentucky

State Mortgage bank Regulator:
Kentucky Department of Financial Institutions

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has 22 branches in the state of Kentucky. On December 1, 2003, Inner City Press submitted this comment to the Kentucky Department of Financial Institutions:

Dear Commissioner Robinson, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its 22 branch offices in Kentucky. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in Kentucky.

That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by dfi.ky.gov/whoweregulate/Small%20Industrial%20Loan%20Recap.pdf which lists the following offices:

SLC Henderson HENDERSON Washington Mutual Finance Group, LLC 1900 U. S. Highway 41N 502/826-9513 1039; SLC Murray CALLOWAY Washington Mutual Finance Group, LLC 704 North 12th Street 502/753-7474 1593; SLC Princeton CALDWELL Washington Mutual Finance Group, LLC 430 U. S. Highway 62 502/365-6600 1597; SLC Madisonville HOPKINS Washington Mutual Finance Group, LLC 190 Madison Square Drive 502/821-7050 1590; SLC Paducah MCCRACKEN Washington Mutual Finance Group, LLC 760 Broadway 502/443-4585 1046; SLC Cadiz TRIGG Washington Mutual Finance Group, LLC 37 Commerce Street 502/522-4938 1592; SLC Central City MUHLENBURG Washington Mutual Finance Group, LLC 1010 East Everly Brothers Blvd. 502/754-5600 1606; SLC Frankfort FRANKLIN Washington Mutual Finance Group, LLC 1267 Highway 127, South 502/875-5730 1036; SLC Hopkinsville CHRISTIAN Washington Mutual Finance Group, LLC 1223 Skyline Drive 502/886-0187 1604; SLC Bardstown NELSON Washington Mutual Finance Group, LLC 205 Kentucky Home Square 502/348-5945 1033; SLC Florence BOONE Washington Mutual Finance Group, LLC 8460 U.S. 42, Suite D 859/342-9099 1134; SLC Louisville JEFFERSON Washington Mutual Finance Group, LLC 1832 South Hurstbourne Parkway 502/458-1945 1043; SLC Bowling Green WARREN Washington Mutual Finance Group, LLC 390 31 W. Bypass, Suite 3 502/782-0093 1591; SLC Somerset PULASKI Washington Mutual Finance Group, LLC Pisgah Valley Square, 3865 S. Highway 27 606/678-3003 1599; SLC Lebanon MARION Washington Mutual Finance Group, LLC 130 Lebanon Trade Center 502/692-1704 1598; SLC Danville BOYLE Washington Mutual Finance Group, LLC Danville Square Shopping Center 606/236-3006 1596; SLC Owensboro DAVIESS Washington Mutual Finance Group, LLC 3211 Frederica Street, Suite 1 502/685-4981 1602; SLC Shelbyville SHELBY [WMFG], LLC 219 Boone Station Road 502/633-9955 1595; SLC Lexington FAYETTE [WMFG], LLC 112 Mt. Tabor Road, Suite 11 859/268-9880 1041; SLC London LAUREL [WMFG], LLC 223 London Shopping Center 606/877-1111 1594; SLC Ashland BOYD Washington Mutual Finance Group, LLC 1613 Greenup Avenue 606/324-3151 1032; SLC Maysville MASON Washington Mutual Finance Group, LLC 1567 U. S. Hwy 68 606/759-5305 1600

Click here for the continuation of ICP's Comment Click here for the continuation of ICP's Comment. predatory:

  HB 287, enacted as Acts Ch. 64 of 2003, concerns predatory lending -- the rating agencies S&P and Fitch don't like the law, refused to rate mortgage backed securities involving Kentucky properties. Also, Kentucky's AG's Office circled the wagons to protect Household International -- so ICP appealed:

Dear Attorney General Chandler, and Assistant Attorney General Harold J. Turner:

   On behalf of the Inner City Press/Community on the Move and its members, and of the Fair Finance Watch (collectively, "ICP"), this is an appeal from Assistant Attorney General Turner's Feb. 10, 2003, letter (the "Denial") partially denying access to records responsive to ICP's Jan. 10, 2003, request for records related to your Office's recent Settlement with Household International, Inc. ("Household"), and denying ICP's request for a fee waiver. This is a formal appeal under both KRS 61.880(2) and (4)... Other states' Attorney General's Offices have provided us with certain inter- and intra-agency communications, and with certain of their communications with Household (which they've deemed not covered by the identical confidentiality provisions of their Consent Judgments, see below, and with memos from the investigation of Household, including one the provides this description of Household's practices:

"The use of a large range of discount points on the GFE is misleading to consumers. HFC's claims that borrowers had a 'choice' of rates and discount points has proven to be false.. A significant number of consumers from across the country have complained that they were promised an approximate 7% rate when the rate was far greater (11% to 14%... HFC's practice is to hard sell insurance products. These practices break down into four categories: i) aggressive sales tactics, ii) inclusion of insurance without customer knowledge, iii) making borrowers believe insurance is a requirement, and iv) forgery of signatures on acceptance documents...

HFC has charged excessive and unconscionable fees including unlawful increases to charges by third party providers (e.g. title report fees)... HFC has routinely made loans to borrowers in which there is no tangible benefit. A consistent practices appears to be the requirement of a high rate second mortgage behind a high rate first mortgage that leaves the borrower in a far worse position than before they transacted business with HFC... The characteristics of HFC's home equity line of credit are those of a closed end, rather than open end. The result is the avoidance of required RESPA and TILA disclosures... Numerous occurrences of failure to make GFE and TIL disclosure have been noted... Loan-to-values in excess of 100% are intended to lock borrowers into loans with principal amounts so high compared with the value of the borrowers' homes that the borrowers are unable to refinance with another lender. Because these loans are under collateralized, where these loans go into foreclosure there will almost certainly be a deficiency... Household has engaged in the practice of mailing 'live' checks to potential borrowers... These live check loans are marketing tools and persons who case the 'live' checks are placed on a 'hot list' for 'target practice' and are aggressively marketed to consolidate the live-check loan with the consumer's other credit obligations in a home equity loan with a slightly smaller interest rate but a much larger principal balance secured by the borrowers' residences."

   Suffice it to say that not all of these practices were addressed or reformed by the Settlements or by your Office's Consent Judgment with Household.

   Nor have these practices since been addressed...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Louisiana

State Mortgage bank Regulator:
Louisiana Office of Financial Institutions

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has 36 branches in the state of Lousiana. On December 1, 2003, Inner City Press submitted this comment to the Louisiana Office of Financial Institutions:

Dear Commissioner Travis, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its 36 branch offices in Louisiana. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, including La. Rev. Stat. Ann. § 44:31, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in Louisiana.

    That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by your agency's website, and by WaMuFinance.com, which lists:

408 Charity St., Abbeville, LA 70510; 1310 Peterman Dr., Alexandria, LA 71301; 704 E. Madison St., Bastrop, LA 71220; 5760 Siegen Ln., Ste. B, Baton Rouge, LA 70809; 313 Walnut St., Bunkie, LA 71322; 8400 W. Judge Perez Dr. , Chalmette, LA 70043; 16148 W. Main St., Ste. A, Cut Off, LA 70345; 172 Del Norte Ave., Ste. B, Denham Springs, LA 70726; 427-A N. Pine St., DeRidder, LA 70634; 141 N. Bobcat Dr., Eunice, LA 70535; 1502-6 Main St., Franklin, LA 70538; 1602 S. Burnside Dr., Ste. D, Gonzales, LA 70737; 2790 W. Church St., Ste. 1, Hammond, LA 70401; 3635 Lapalco Blvd., Ste. 200, Harvey, LA 70058; 209 Bayou Gardens Blvd. Ste. I, Houma, LA 70364; 121 W. Nezpique; Jennings, LA 70546; 2505 Williams Blvd., Ste. C, Kenner, LA 70062; 1512 Ambassador Caffery Blvd., Lafayette, LA 70506; 2506 Ryan St., Lake Charles, LA 70601; 1700 E. Prien Lake Rd., Ste. 4, Lake Charles, LA 70601; 1512 W. Airline Hwy., LaPlace, LA 70068; 267 E. Tunica Dr., Marksville, LA 71351; 115 E. Union St., Minden, LA 71055; 2023 Hudson Lane, Monroe, LA 71201; 508 Roderick St., Morgan City, LA 70380; 221 Hwy. 1, S., Natchitoches, LA 71457; 616 S. Lewis St., Ste. B, New Iberia, LA 70560; 144 E. Sixth Ave., Oakdale, LA 71463; 939 N. Trenton St., Ruston, LA 71270; 8201 Jewella Ave., Ste. 113, Shreveport, LA 71108; 1480 Gause Blvd., Ste. C, Slidell, LA 70458; 110 Old Market St., St. Martinville, LA 70582; 309 N. Canal Blvd., Thibodaux, LA 70301; 1642 Carter St., Ste. 3, Vidalia, LA 71373; 6617 Main St., Winnsboro, LA 71295

Click here for the continuation of ICP's Comment.   Here's the state of the state, on matters predatory:

  Here's a social initiative in New Orleans to combat predatory lending. Much exhortation: House Resolution 103 asks the Office of Financial Institutions to promulgate rules and regulation to increase public awareness of predatory lending practices.  These can be found, for example, at offices of CitiFinancial, Household, Wells and American General... Meanwhile House Bill 817, which would require expanded disclosures on high cost loans, remains bottled up in the Committee on Commerce, or dead, depending who you ask... On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its eleven offices in Louisiana into branches of a federal savings bank, Chase FSB, to escape state laws...Here's just three of the CitiFinancials in Louisiana:

8309 W Judge Perez Dr, Chalmette, LA 70043 - 504-276-6330
3501 N. Causeway Boulevard, Metairie, LA 70002 - 504-837-8980
601 Terry Parkway, Gretna, LA 70056 - 504-362-3923

Return to Predatory Bender's Citi States Map, @ Inner City Press

Maine

State Mortgage bank Regulator:
Maine Department of Professional & Financial Regulation - Office of Consumer Credit Regulation
Maine Department of Professional & Financial Regulation

  When you pass a weak law (like Maine's LD 494 -- "An Act To Enhance Consumer Protections in Relation to Certain Mortgages" -- later S&P pats you on the head, saying it will continue to rate "structure finance transactions" in your state...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Maryland

State Mortgage bank Regulator:
Maryland Division of Financial Regulation

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has seven branches in the state of Maryland. On December 1, 2003, Inner City Press submitted this comment to the Maryland Division of Financial Regulation:

Dear Commissioner Turnbaugh, Ms. Watson, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its seven branch offices in Maryland. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in your state. We note that earlier this year, Mary Louise Preis (now at CitiFinancial, see infra and ICP's pending MPIA request) thanked ICP for having "provided a substantial amount of information concerning Household and HSBC, which will be very useful as we consider whether to approve... This agency has requested additional information from HFC, and will be requesting additional information as we continue to analyze the request... we also invite you to provide any additional information you believe would be useful." At a minimum, the same must be done here. We note that your office has yet to respond to ICP's MPIA request for Ms. Preis' communications with CitiFinancial

    That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by your agency's website, at www.dllr.state.md.us/cgi-bin/fin_reg_el/rel2/PQ_Application.cgi, and by WaMuFinance.com, which lists:

7905-C Harford Rd., Baltimore, MD 21234; 4171 Patterson Ave., Baltimore, MD 21215; 29 Baltimore St., Cumberland, MD 21502; 101 Marlboro Ave., Ste. 61, Easton, MD 21601; 7479 Baltimore-Annapolis Blvd., Glen Burnie, MD 21061; 3537 Brenbrook Dr., Randallstown, MD 21133; 1015 S. Salisbury Blvd., Salisbury, MD 21801

Click here for the continuation of ICP's Comment. Here's the state of the state, on matters predatory:

  Senate Bill 574 and House Bill 864 died and were withdrawn. Subsequently, the same Maryland Commissioner who ruled on (and approved) HSBC's applications to acquire Household, Mary Louise Preis, left less than a year later, going to work for CitiFinancial...  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 11 offices in Maryland into branches of a federal savings bank, Chase FSB, to escape state laws... ICP's Maryland campaigns have included T. Rowe Price Thrift Application Challenge (“N.Y. Consumer Group Opposed T. Rowe Price Plan for Thrift,” Baltimore (and Washington) Business Journals)... In the Baltimore MSA, Citibank (Citibank FSB and CitiMortgage together) denied loan applications from African Americans 3.80 times more frequently than applications from whites, higher than the aggregate's disparity (3.27).  Here's just three of the CitiFinancials in Maryland - these are in Baltimore, CitiFi's HQ:

6630 Security Boulevard, Baltimore, MD 21207 - 410-944-5090
6714 Ritchie Highway, Glen Burnie, MD 21061 - 410-761-5120
7676 Belair Road, Baltimore, MD 21236 - 410-882-9640    

Return to Predatory Bender's Citi States Map, @ Inner City Press

Massachusetts

State Mortgage bank Regulator:
Massachusetts Division of Banks

  Here's a good proposal: a bill "to establish community reinvestment obligations for mortgage lenders," SB 4.   Also, the anti-predatory lending regulations at 209 CMR 40.00 et seq. of 2000.   On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its eight offices in Massachusetts into branches of a federal savings bank, Chase FSB, to escape state laws... The Division of Banks holds hearings -- ICP attended one in September 2003 -- but rarely follows-up.  Shawmut, BayBanks, Bank of Boston -- where did they go?  See, e.g., “Fleet, BankBoston Plan to Lend $14.6 Billion For Low-Income, Small-Business Loans,” by John Hechinger, Wall Street Journal, June 28, 1999, Pg. A6. Here's just three of the CitiFinancials in Massachusetts:

1598 Hancock Street, Quincy, MA 2169 - 617-479-6850
Rte 114 300 Andover Street, Peabody, MA 1960 - 978-538-9215
500 Providence Highway, Norwood, MA 2062 - 781-769-3436

Return to Predatory Bender's Citi States Map, @ Inner City Press

Michigan

State Mortgage bank Regulator:
Michigan Financial Institutions Bureau

  Concerning the drafting, industry lobbying against, and redrafting of Detroit's Anti-Predatory Lending Ordinance, click here for a summary, here for full text, both in pdf format.  The Mayor vetoed it two days after Christmas, 2002.   On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 11 offices in Michigan into branches of a federal savings bank, Chase FSB, to escape state laws. In the Detroit MSA in 2002 CMMC denied the refinance applications of African Americans 2.58 times more frequently than whites; in the Benton Harbor MSA, CMMC denied the refinance applications of African Americans 2.36 times more frequently than whites... ICP's work in the Motor City goes back to at least 1995 -- see, e.g., "Group Says NBD's Loan Record Should Void Merger," by Joel J. Smith, Detroit News, October 3, 1995 -- and gave rise to and ICP Detroit Watch Report.

Return to Predatory Bender's Citi States Map, @ Inner City Press

Minnesota

State Mortgage bank Regulator:
Minnesota Department of Commerce

  Here's an attempt to combat the marketing of predatory lenders in the Twin Cities area.   The proposed Minnesota Home Loan Protection Act of 2003 was referred to the Committee on Commerce and Utilities, where it essentially died (offically, it was "laid over").  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its six offices in Minnesota into branches of a federal savings bank, Chase FSB, to escape state laws... Minneapolis, historically, was the headquarters of Norwest, which bought finance companies, including Puerto Rico-based Island Finance.  Under Norwest, Island Finance opened a storefront in the South Bronx, charging everyone who walked in 25% interest, without even checking people's credit histories.  Pricing by risk?

Return to Predatory Bender's Citi States Map, @ Inner City Press

Mississippi

State Mortgage bank Regulator:
Mississippi Department of Banking and Consumer Finance

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has 18 branches in the state of Mississippi:

214 E. Commerce, Aberdeen, MS 39730; 189 Hwy. 51, S., Batesville, MS 38606; 111 Commerce Ave., Cleveland, MS 38732; 1794 Hwy. 72, E.,Corinth, MS 38834; 1006 Top St., Ste. A, Flowood, MS 39232; 733 Hwy. 82, E., Greenville, MS 38701; 508 W. Park Ave., Greenwood, MS 38930; 1247-A Pass Rd., Gulfport, MS 39501; 4 Willow Pointe, Ste. 60, Hattiesburg, MS 39402; 803-A N. 16th Ave., Laurel, MS 39440; 1515 14th, Ste. B, Meridian, MS 39301; 6229 Hwy. 305, Ste. B, Olive Branch, MS 38654; 1601 W. Jackson Ave., Oxford, MS 38655; 436 Beacon St., Philadelphia, MS 39350; 210-C Hwy. 12, W., Starkville, MS 39759; 2604 W. Main, Ste. A, Tupelo, MS 38801; 909 Central St., Water Valley, MS 38965; 210 Hwy. 45, S., West Point, MS 39773

    On December 1, 2003, Inner City Press submitted this comment to the Mississippi Department of Banking and Consumer Finance:

Dear Commissioner Allison, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its 18 -- or 39 -- branch offices in Mississippi. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in Mississippi.

That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by your agency's website, and by WaMuFinance.com. The latter lists 18 WaMu Finance offices in Mississippi, but your Office's November 9, 2001, letter to the Office of Thrift Supervision (which we wish to address at the requested hearing) states that WaMu Finance "operates at 39 licensed locations in Mississippi under the auspices of Section 75-67-101, et seq. and 75-57-201, et seq. Mississippi Code of 1972, Annotated" -- and then mentions seven more locations. It is not clear to ICP how many of these locations CitiFinancial is proposing to acquire; please inform us in this regard.

Click here for the continuation of ICP's Comment.  Here's the state of the state, on matters predatory:

  Stomping ground -- and we mean that literally -- of the old Deposit Guaranty Bank, later bought by AmSouth. ICP raised issues (see, e.g., “Groups Say Loan Denial Rates High,” The Tennessean (Nashville, TN), July 27, 1999), and soon AmSouth settled with the Department of Justice, charges of discriminatory lending.  See, e.g., “Bank settles 'unfair lending' claims,” The Tennessean, September 30, 1999. But AmSouth has improved little since then...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Missouri

State Mortgage bank Regulator:
Missouri Division of Finance

  Watchdogging is constant in the Show-Me State. NationsBank-Boatmen's ("NationsBank-Boatmen's Merger," Associated Press, December 17, 1996), Shelter Mutual Insurance (see, “Shelter Insurance Is Accused of Housing Bias: Company Denies N.Y. Group’s Charges,” Jim Gallagher, St. Louis Post-Dispatch, October 7, 1998, Pg. C1), Citigroup - Associates: ICP's fought 'em tooth and nail, filing suit in Jefferson City, walking the downtown of St. Louis by The River, across to the other side, weedy East St. Louis... Here's just three of the CitiFinancials around St. Louis:

5450 South Lindbergh Blvd, St Louis, MO 63123 - 314-842-8626
511 Belt Line Road, Collinsville, IL 62234 - 618-344-5644
9815 Watson Road, St Louis, MO 63126 - 314-966-6020    

On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its eight offices in Missouri into branches of a federal savings bank, Chase FSB, to escape state laws...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Montana

State Mortgage bank Regulator:
Montana Division of Banking & Financial Institutions

  Here's SB 402, the Montana "Mortgage Broker and Loan Originator Licensing Act," signed by Gov. Judy Martz in May 2003, in pdf format.  

Return to Predatory Bender's Citi States Map, @ Inner City Press

Nebraska

State Mortgage bank Regulator:
Nebraska Department of Banking & Finance

   Here's LB 218, signed by the Governor March 20, 2003. It prohibits predatory practices in the mortgage loan industry and increases the authority of the Nebraska Department of Banking and Finance to take action against persons engaged in predatory lending practices.    

Return to Predatory Bender's Citi States Map, @ Inner City Press

Nevada

State Mortgage bank Regulator:
Nevada Department of Business & Industry

  Gold, sun, casinos and retirees -- this was the venue for a fight against Wells Fargo (“Wells Fargo Merger Target of Las Vegas, N.Y. Critics,” by Richard N. Velotta, Las Vegas Sun, August 15, 2000), and soon after, against Citigroup - Associates: "Activist Seeks Nevada Hearing,"  Las Vegas Sun, October 24, 2000. The anti-predatory lending AB 284 was signed by the Governor on June 10, 2003, as Chapter 465, and became effective on October 1, 2003. On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its two offices in Nevada (Reno, and 500 N. Rainbow Blvd. in Las Vegas) into branches of a federal savings bank, Chase FSB, to escape state laws... In the Las Vegas MSA in 2002 for conventional home purchase loans, Citibank -- Citibank FSB and CitiMortgage together -- denied loan applications from African Americans 3.57 times more frequently than applications from whites. Citibank denied Latinos 1.98 times more frequently than whites. This is worse than other lenders in this MSA: the denial rate disparities for the industry as a whole in 2002 were 1.99 for African Americans, and 1.87 for Latinos...

Return to Predatory Bender's Citi States Map, @ Inner City Press

New Hampshire

State Mortgage bank Regulator:
New Hampshire Bank Commissioner's Office

  Here ICP fought KeyBank, while it bought Champion Mortgage.  We tip our cap to the Granite State CRA Coalition... On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its two offices in New Hampshire (Portsmouth, and 1750 Elm St. in Manchester) into branches of a federal savings bank, Chase FSB, to escape state laws...

Return to Predatory Bender's Citi States Map, @ Inner City Press

New Jersey

State Mortgage bank Regulator:
New Jersey Department of Banking & Insurance

An ever-shifting, late-passed law, AB 75, slated to go into effect on November 27, 2003, was subject to much rating agency sniping; there's also the loss of all big banks headquartered in the state, and almost non-functioning FOIA regime. Still we love Trenton, Camden, Jersey City and Newark too -- having seen the First Fidelity Merger Aftermath.  In 2002 in the Newark MSA,  for conventional home purchase loans, Citibank (Citibank FSB and CitiMortgage together) denied loan applications from African Americans a whopping 30.8 times more frequently than applications from whites. Citibank denied Latinos 15.2 times more frequently than whites. This is much, much worse than other lenders in this MSA: the denial rate disparities for the industry as a whole in 2002 were 3.43 for African Americans, and 2.33 for Latinos. Citibank's higher-than-aggregate denial rate disparities are certainly not explained by any greater-than-normal outreach with normal-priced credit to African Americans or Latinos. For these three groups, the aggregate made 10.0% of its loans to African Americans, and 10.3% to Latinos. For Citibank, the figures were 4.8% of loans to African Americans, and 4.8% to Latinos...  

Return to Predatory Bender's Citi States Map, @ Inner City Press

New Mexico

State Mortgage bank Regulator:
New Mexico Financial Institutions Division

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has eight branches in the state of New Mexico. On December 1, 2003, Inner City Press submitted this comment to the New Mexico Financial Institutions Division:

Dear Director Verant, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its eight branch offices targeting New Mexico. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in New Mexico.

    That CitiFinancial's target, WaMu Finance, has offices targeting consumers in New Mexico, which are under your jurisdiction, is reflected by your agency's website, at www.rld.state.nm.us/fid/Licensee%20Search/licensee_search_facilities.asp, and by WaMuFinance.com, which lists

1008 10th St., Alamogordo, NM 88310;
1020 Lomas Blvd., N.W., Ste. 1, Albuquerque, NM 87102;
460-E N. Riverside Dr., Espanola, NM 87532;
123 W. Broadway, Farmington, NM 87401;
2001 E. Lohman, Ste. 111, Las Cruces, NM 88001;
520 6th St., Las Vegas, NM 87701;
1010 S. Main, Ste. 3, Roswell, NM 88201; and
2860 Cerrillos Rd., Ste. B-1, Santa Fe, NM 87507.

Click here for the continuation of ICP's Comment.  Here's the state of the state, on matters predatory:

Ah, Nuevo Mexico, venue of fights against NationsBank - Boatmen's (see, "NationsBank-Boatmen's Merger," Associated Press, December 17, 1996), and NationsBank buying Montgomery. Thereafter forgotten by NationsBank-turned Bank of America... On January 8, 2003, the Santa Fe city council passed Resolution 2003-4, calling for a state anti-predatory lending law; on April 11, 2003, SB 449, the "Home Loan Protection Act,"  was signed into law, becoming effective on the first day of 2004. Here's just five of the CitiFinancials in New Mexico:

11500 Menaul NE, Albuquerque, NM 87112 - 505-299-8789
6300 San Mateo Bv NE H-2, Albuquerque, NM 87109 - 505-821-1911    
10131 Coors Road NW, Albuquerque, NM 87114 - 505-897-5075    
3821 Menaul Boulevard NE, Albuquerque, NM 87110 - 505-888-9733
4056 Cerrillos Road, Santa Fe, NM 87507 - 505-471-2204

Return to Predatory Bender's Citi States Map, @ Inner City Press

New York

State Mortgage bank Regulator:
New York Banking Department

  There's too much to say, in this space -- state laws (SB 11856 / Chapter 626 of 2002: for loans of $300,00 or less--

If the APR is 8 points higher on the first trust deed than yield on appropriate treasury securities which have an equivalent term, or

if the APR is 9 points higher on a second trust deed that the yield on the treasury securities which have an equivalent term, or

The total points and fees are more than 5%.predatory lending--

  the NYC ordinance (67A of 2002, Local Law No. 36); and the NYBD's Part 41. Headquarters to sleazy Citigroup and Chase, five boroughs and eight million stories. And those are just in New York City -- there's also Buffalo (see, e.g., “Acquisition of Republic Could Face Court Challenge,” Business First Buffalo), Rochester, Syracuse, Albany (for example, see "Complaint Alleges Violations" [of NY Elections Law by Household], by Elizabeth Benjamin, Albany Times Union, February 3, 2003). 

   In 2002 in the New York City Metropolitan Statistical Area (MSA), for conventional home purchase loans, Citibank (Citibank, N.A. and CitiMortgage together) denied loan applications from African Americans 4.67 times more frequently than applications from whites. Citibank denied Latinos 3.17 times more frequently than whites. This is much worse than other lenders in this MSA: the denial rate disparities for the industry as a whole in 2002 were 1.89 for African Americans, and 1.68 for Latinos.

    Citibank's higher-than-aggregate denial rate disparities are not explained by any greater-than-normal outreach with normal-priced credit to African Americans or Latinos. In 2002 in this MSA, Citibank made 3607 conventional home purchase loans to whites, only 390 to African Americans, and 458 to Latinos. For the record, the aggregate industry in this MSA in 2002 made 6567 such loans to African Americans, 6365 to Latinos, and 34,336 to whites. For these three groups, the aggregate made 13.87% of its loans to African Americans, and 13.47% to Latinos. For Citibank, the figures were much lower: 8.7% of loans to African Americans, and 10.3% to Latinos.  For more, click here for ICP's Weekly Bronx Report...

Return to Predatory Bender's Citi States Map, @ Inner City Press

North Carolina

State Mortgage bank Regulator:
North Carolina Commissioner of Banks

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has 37 branches in the state of North Carolina. On December 1, 2003, Inner City Press submitted this comment to the North Carolina Banking Commission:

Dear Commissioner Smith, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its 37 branch offices in North Carolina. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, including G.S. § 132-1(a), for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. (You'll see below and in the attached that the NC AG's Office has provided us with some complaints; this was done under a fee waiver). This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in North Carolina.

    That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by your website, www.banking.state.nc.us/cflist.htm, and by WaMuFinance.com, which lists the following offices:

905 E. Memorial Dr., Ahoskie, NC 27910; 1337-B E. Dixie Dr., Asheboro, NC 27203; 1300-A Patton Ave., Asheville, NC 28806; 308 Huffman Mill Rd., Burlington, NC 27215; 816-B E. Arrowood Rd., Charlotte, NC 28217; 6054 E. Independence Blvd., Charlotte, NC 28212; 3808-J Guess Rd., Durham, NC 27705; 109 E. Stadium Dr., Eden, NC 27288; 1555 Hwy. 70, W., Garner, NC 27529; 716-D E. Ash St., Goldsboro, NC 27530; 508 Summit Ave., Greensboro, NC 27405; 4623-F High Point Rd., Greensboro, NC 27407; #21 Carolina East Center, Greenville, NC 27834; 170 Four Seasons Mall, Hendersonville, NC 28792; 1227 2nd St., N.E., Hickory, NC 28601; 601-C Eastchester Dr., High Point, NC 27262; 405-B Western Blvd., Jacksonville, NC 28546; 461 N. Cannon Blvd., Kannapolis, NC 28083; 2405 N. Heritage St., Ste. F, Kinston, NC 28501; 112-K Wilkesboro Blvd., Lenoir, NC 28645; 17 S. Main St., Lexington, NC 27292; 1402 Skyway Dr., Monroe, NC 28110; #2 Pisgah Hwy., Pisgah Forest, NC 28768; 215 US Hwy. 64, W., Plymouth, NC 27962; 228 S. Main St., Raeford, NC 28376; 5710 Capital Blvd., Ste. A, Raleigh, NC 27616; 1408 1/2 Freeway Dr., Reidsville, NC 27320; 3000 Sunset Ave., Rocky Mount, NC 27804; 530 E. Innes St., Salisbury, NC 28144; 1421 S. Pollock St., Selma, NC 27576; 413 S. Lafayette St., Shelby, NC 28150; 705 Randolph St., Ste. C, Thomasville, NC 27360; 275 N. Haywood St., Waynesville, NC 28786; 35 S. Kerr Ave., Wilmington, NC 28403; 2693-C Forest Hills Rd.Wilson, NC 27893; 615 Peters Creek Parkway, Winston-Salem, NC 27103; 2650 Peters Creek Parkway, SW, Winston-Salem, NC 27127

Click here for the continuation of ICP's Comment. Here's the state of the state, on matters predatory:

  More predatory lending action than you can shake a stick at -- a model statute (click here to view, in pdf format); competing studies; home to Wachovia and B of A, and the smaller RBC Centura and BB&T. We like CRA-NC and the NC Fair Housing Center... See also. as a blast from the past, "NationsBank Merger Spurs Probe Requests," Triangle Business Journal.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 11 offices in North Carolina into branches of a federal savings bank, Chase FSB, to escape state laws. In the Raleigh-Durham MSA in 2002, for conventional home purchase loans, CMMC's denial rate disparity between African Americans and whites was 4.72; between Latinos and whites it was 7.09... In 2002 in the Raleigh-Durham NC MSA, CitiMortgage denied the refinance loan applications from African Americans 4.88 times more frequently than applications from whites, higher than the aggregate's disparity (3.29). And in 2002 in the Charlotte NC MSA, CitiMortgage denied the refinance loan applications from African Americans 5.56 times more frequently than applications from whites, higher than the aggregate's disparity (2.36)...

Return to Predatory Bender's Citi States Map, @ Inner City Press

North Dakota

State Mortgage bank Regulator:
North Dakota Department of Banking & Financial Institutions

Home to U.S. Bancorp's sleazy credit card and home equity lending operation, and bad on FOIA to boot:

Dear Ms. Brocker, and Attorney General Stenehjem:

   On behalf of the Inner City Press/Community on the Move and its members, and of the Fair Finance Watch (collectively, "ICP"), this regards Ms. Brocker's Jan. 15, 2003, constructive denial (the "Denial") of ICP's request, under North Dakota's open records laws and otherwise, for records related to your Office's recent Settlement with Household International, Inc. ("Household"), etc..

   The context of ICP's request, in brief, is that Household has been charged in all fifty states with predatory lending, has entered a settlement that many consumers' organizations including FFW contend is too limited, and has now proposed to be acquired by the London-based Hongkong Shanghai Banking Corporation ("HSBC"). It is in the public interest to disclose the specifics of all complaints against Household (and, for comparison's sake, certain of its peers) in North Dakota, and to disclose the specifics of the Settlement in North Dakota. We note again that on Dec. 19, 2002, Household issued a press release stating that "[a]ll 50 states and the District of Columbia have agreed to participate in the program." For your information, numerous Attorney General's Offices in other state have provided ICP, without cost, with copies of complaints and other records in response to nearly identical Jan. 10, 2003, requests from ICP.

  The Denial provided not a single document. Rather, the Denial claims that all responsive records would be exempt, and threatens to require an advance payment of costs... The Denial states that "there were no Household branch offices in North Dakota." That does not mean that Household International does not do business in North Dakota, in a variety of ways -- including but not limited to through brokers, with tax Refund Anticipation Loans (at interest rates over 100%) through H&R Block and others, through credit cards including subprime / secured credit cards (under the brand name "Orchard Bank") and/or credit insurance in connection with these (collectively, the "Other Household Practices").

   Household and HSBC are now claiming that the Settlement addresses all of Household's allegedly predatory practices except RALs; so we are request documents reflecting your Office's consideration of, and action on, the Other Household Practices.

  But no such documents were every provided...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Ohio

State Mortgage bank Regulator:
Ohio Department of Commerce

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has a branch in the state of Ohio. On December 1, 2003, Inner City Press submitted this comment to the Ohio Division of Financial Institutions:

Dear Superintendent O'Donnell, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its branch office(s) in Ohio. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, including under Ohio Rev. Code § 149.43, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in your state.

    That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by WaMuFinance.com, which lists

Washington Mutual Finance, Columbus
210 W. Johnstown Rd.
Gahanna, OH 43230

   Most other states also list other WaMu Finance office that lend into their states.

Click here for the continuation of ICP's Comment. Here's the state of the state, on matters predatory:

  A history of fair housing beyond compare: Cleveland (Ordinances 372-02, 737-02, 45-03), Dayton (29990-01) and Toledo (click here for August 2003 Toledo anti-predatory lending ordinance, No. 271-03). Ohio HB 386 purports to preempt all municipalities' anti-predatory lending legislation....  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its nine offices in Ohio into branches of a federal savings bank, Chase FSB, to escape state laws...ICP's fought Charter One, Bank One, Fifth Third (see, "Group Seeks to Stop Fifth Third Merger," by John Nolan, Associated Press, Cincinnati Post, January 23, 2001) and PNC. In 2003,. ICP filed suit in Franklin County against HSBC-Household...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Oklahoma

State Mortgage bank Regulator:
Oklahoma Department of Consumer Credit

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has 18 branches in the state of Oklahoma. On December 1, 2003, Inner City Press submitted this comment to the Oklahoma Commission on Consumer Credit:

Dear Administrator Hardin, others:

  On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its 18 branch offices in Oklahoma. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in Oklahoma.

That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by WaMuFinance.com, which lists the following offices:

109 E. Main St., Ada, OK 74820; 615 N. Commerce St., Ste. C, Ardmore, OK 73401; 580 S.E. Washington Blvd., Bartlesville, OK 74006; 1422 W. Kenosha, Broken Arrow, OK 74012; 718 S. 4th St., Chickasha, OK 73018; 728 W. Main St., Duncan, OK 73533; 116 N. 12th St., Durant, OK 74701; 2312 W. Owen K. Garriott, Enid, OK 73703; 1415 S.E. Washington St., Idabel, OK 74745; 1405 S. Douglas Blvd., Ste. A, Midwest City, OK 73130; 1324 S. York St., Muskogee, OK 74403; 8427 S. Western Ave., Oklahoma City, OK 73139; 6726 N.W. Expressway St., Oklahoma City, OK 73132; 20 N. Vann St., Pryor, OK 74361; 1510 N. Kickapoo St., Ste. A-2, Shawnee, OK 74804; 10662 E. 31st St., Tulsa, OK 74146; 4311 S. Sheridan, Tulsa, OK 74145; 109 E. Vandament Ave., Yukon, OK 73099

Click here for the continuation of ICP's Comment.  Here's the state of the state, on matters predatory:

  HB 1574, the Oklahoma Home Ownership and Equity Protection Act, , was approved May 29, 2003.  Here's a 2002 report on predatory lending in Oklahoma. On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its four offices in Oklahoma into branches of a federal savings bank, Chase FSB, to escape state laws...  In 1999,  ICP opposed Wal-Mart, when they tried to enter banking, in Oklahoma. See, e.g.,  "Wal-Mart’s Banking Plans Opposed,” Tulsa (OK) World, July 24, 1999.  More recently (2002)

Dear Administrator Hardin, Commission on Consumer Credit

  On behalf of the Inner City Press/Community on the Move and its members, and of the Fair Finance Watch (collectively, "ICP"), this letter and the exhibits hereto supplement ICP's Dec. 23, 2002, comment, which the Oklahoma State Banking Department ("OSBD") forwarded to you Jan. 3, 2003 (see attached), opposing, and still requesting a copy of records related to, the applications to your agency by HSBC Holdings plc (along with its affiliates, "HSBC") to acquire the scandal-plagued subprime lender Household International (along with its affiliates, including those doing business in Oklahoma (collectively, "Household").

   On Dec. 23, 2002, ICP submitted an initial comment opposing HSBC's applications, to the OSBD (since HSBC's Dec. 20, 2002, preliminary proxy statement filed with the SEC stated that HSBC would be applying for banking approval in Oklahoma). Having heard nothing back (unlike from other states' regulators), on Jan. 3, 2003, ICP telephoned the OSBD, which told me that the appropriate agency was the Oklahoma Commission on Consumer Credit ("OCCC"). ICP telephoned the OCCC on Jan. 3 and left a message, which has not been returned. Subsequently ICP received a copy of the letter from the OSBD's Legal Counsel O. Dudley Gilbert, dated Jan. 3, forwarding ICP's comments to you.

   Despite the fact that ICP has heard nothing back from your Commission, ICP has received an update from an analyst, stating that as of Jan. 15, 2003, "[t]he Oklahoma Department of Consumer Credit has not received the requested affidavits from HSBC officials as of today. The ODCC still anticipates receiving the documents "any day now," but will probably not be able to complete the background checks and approve the transaction before the end of January as originally anticipated. Approval will most likely occur in early-February, 2003, assuming no criminal records are discovered among the HSBC officers under investigation."

  If they weren't criminals then (pre-Household), they are now...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Oregon

State Mortgage bank Regulator:
Oregon Department of Consumer & Business Services

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has seven branches in the state of Oregon.  On December 1, 2003, Inner City Press submitted this comment to the Oregon Division of Finance & Corporate Securities:

Dear Administrator Lanter, Ms. Locnikar, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its seven branch offices in Oregon. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also, including in the spirits of Ms. Locnikar's Sept. 19, 2003, response to ICP, a formal request for a hearing, and for an investigation into CitiFinancial's practices in Oregon.

    That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by WaMuFinance.com, which lists the following offices:

3889 S.W. Hall Blvd., Beaverton, OR 97005; 61535 S. Hwy. 97, Ste. 18, Bend, OR 97702; 210 S. 4th St., Coos Bay, OR 97420; 3333 W. 11th Ave., Ste. E, Eugene, OR 97402; 535 Stevens St., Ste. B, Medford, OR 97504; 12417 N.E. Glisan, Portland, OR 97230; 2411 Lancaster Dr., N.E., Salem, OR 97305

Click here for the continuation of ICP's Comment.Here's the state of the state, on matters predatory:

  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 12 offices in Oregon into branches of a federal savings bank, Chase FSB, to escape state laws...Here, HB 3088 got buried, and the state AG wants $2000 for documents about Household:

Dear Attorney General Hardy Myers, Assistant AG Drew Lianopoulos::

  On behalf of the Inner City Press/Community on the Move and its members, and of the Fair Finance Watch (collectively, "ICP"), this regards and appeals from Assistant Attorney General Lianopoulos' Feb. 4, 2003, letter constructively denying access to records responsive to ICP's Jan. 10, 2003, request, under the Oregon Public Records Act, ORS 192.420, for records related to your Office's recent Settlement with Household International, Inc. ("Household"), etc.. After a 25-day delay, we are told that your Office proposes to charge $97 a hour for "Assistant Attorney General review" for documents regarding Household which other states' Offices of the Attorney General have provided to ICP faster, and for free. ICP's Jan. 10, 2003, letter explicitly included a request for a waiver of fees (which numerous other states' Office of the Attorney General have granted). Despite ORS 192.440(4), the constructive Denial does not even mention ICP's request in this regard. This is an appeal, including under ORS 192.440(5).

   The proposed charge over $2,000 (mostly for AAG review) strikes us as abusive and designed to discourage public review and oversight of your Office's settlement with Household, which for some reason was limited only to Household's real estate loans, and even for those, only to branch-originated loans. ICP is troubled by both this ludicrous proposed charge, and by the initial delay in response (and proposed further delay of 45 days in providing documents). ICP intuits that these may be attributable to the highly-questionable agreement to privatize public records that is contained in some states' December 2002 settlement with Household. Along with the already-delayed records we requested on Jan. 10, 2003 (the request is narrowed below), we ask to be provided with copies of any and all communications between your Office and Household regarding requests for Settlement-related information, and with an explanation of how Oregon's public records law is not violated by the concluding sections of your Office's settlement agreement with Household.

   The context of ICP's request, in brief, is that Household has been charged in all fifty states, including Oregon, with predatory lending, has entered a settlement that many consumers' organizations including ICP contend is too limited, and has now proposed to be acquired by the London-based Hongkong Shanghai Banking Corporation ("HSBC"). It is in the public interest to disclose the specifics of any and all complaints against Household (and, for comparison's sake, certain of its peers) in Oregon, and to disclose the specifics of the Settlement in Oregon. We note this context inter alia in light of Gray v. Salem-Keizer School District, 139 Or.App. 556, 912 P.2d 938 (1996), holding that the purpose and context of the request should be taken into consideration in determining how the records' release or confidentiality may affect the public interest.

   As stated in our Jan. 10, 2003, request, we need these records in connection with state and federal regulatory proceedings on HSBC's proposal to acquire Household. The Consent Decrees are being used by HSBC as a basis on which its applications to acquire Household should be approved, without any public hearings, and your Office has already delayed 25 days and counting in providing any documents about the settlement. This is why the already 25-day delay is galling. This letter should be considered an appeal; it should be considered by the ultimate decision-maker at your Office on public record requests, and that you forward this appeal, and your response, to the Secretary of State, as the Public Records Administrator, under ORS 192.015. We are particularly troubled by the abusive proposed charge given the Office of Attorney General's role in considering appeals of other agencies' Public Record Act denials.

Return to Predatory Bender's Citi States Map, @ Inner City Press

Pennsylvania

State Mortgage bank Regulator:
Pennsylvania Department of Banking

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has 10 branches in the state of Pennsylvania. On December 1, 2003, Inner City Press submitted this comment to the Pennsylvania Department of Banking:

Dear Secretary Schenck, Mr. Moretz, Ms.Hernandez-Velez, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its 10 branch offices in Pennsylvania. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, 65 P.S. §§66.1, et seq., for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. We make this request as New York residents, under the privileges and immunities clause of the U.S. Constitution, see, "Lawsuit Challenges Delaware Records Law: Nonresidents Denied Use of Freedom of Information Act," Wilmington News-Journal, Nov. 27, 2003, < www.delawareonline.com/newsjournal/local/2003/11/27lawsuitchalleng.html>.This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in your state.

That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by WaMuFinance.com, which lists:

1739 Liberty St., Allentown, PA 18104; 9-A N. Progress Ave., Harrisburg, PA 17109; 319 W. County Line Rd., Ste. 1, Hatboro, PA 19040; 241 W. Roseville Rd., Ste. 4, Lancaster, PA 17601; 1217 Market St., Lemoyne, PA 17043; 6080 Steubenville Pike, McKees Rocks, PA 15136; 2030 Main St., Norristown, PA 19403; 1738 Greensburg Ave., North Versailles, PA 15137; 901 E. Main St., Palmyra, PA 17078; 7512 Frankford Ave., Philadelphia, PA 19136

Click here for the continuation of ICP's Comment.  Here's the state of the state, on matters predatory:

  The Philadelphia ordinance was preempted by HB 1703.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its seven offices in Pennsylvania into branches of a federal savings bank, Chase FSB, to escape state laws... In 2002 in the Philadelphia MSA, CitiMortgage denied the conventional home purchase loan applications from African Americans 4.55 times more frequently than applications from whites, higher than the aggregate's disparity (3.11)...  Meanwhile, AG Mike Fisher, and the departments of banking and insurance, claim that their Right-to-Know Act is only for Pennsylvania citizens -- making PA one of the few states to do this, like Delaware (more on this anon).  Here was one of our PA requests, mid-2003:

Dear Deputy Secretary Hernandez-Velez, Right-to-Know Law officer:

On behalf of the Inner City Press/Community on the Move, and in my personal / individual capacity (collectively referred to hereinbelow as "ICP"), this is a request under 65 P.S. §§66.1-66.9 (the "Right-to-Know Law") for records in your agency's possession or control regarding American Business Financial Services, Inc. and its affiliates ("ABFI"), and, separately and for comparison's sake, regarding Household International and its affiliates ("Household;" ABFI and Household are collectively referred to hereinbelow as the "Companies"). We are requesting copies of all non-exempt communications between the Department and the Companies, from May 1, 2000, to the date of your response. We are also requesting copies of all records reflecting or relating to consumer complaints against the Companies.

  To assist you in collecting the responsive records, we note that your agency's Web site, via <www.banking.state.pa.us/Banking/Banking/InstListResults.asp>, lists the following ABFI subsidiaries as licensees:

American Business Mortgage Services, Inc. First Mortgage Banker P 1021, Bala Cynwyd PA 19004
American Business Mortgage Services, Inc. Secondary Mortgage Lender P 0181, Bala Cynwyd PA 19004
HomeAmerican Credit, Inc. First Mortgage Banker P 1136, Bala Cynwyd PA 19004

HomeAmerican Credit, Inc. Secondary Mortgage Lender P 1853, Bala Cynwyd PA 19004

HomeAmerican Consumer Discount Company Consumer Discount Company P 2982, Bala Cynwyd PA 19004-9837

On May 15, 2003, ABFI issued a press release on the Business Wire service stating among other things that

"American Business Financial Services, Inc. (NASDAQ:ABFI) today announced that its consumer mortgage subsidiary, Home American Credit, Inc., doing business as Upland Mortgage, plans to significantly expand its lending program in nine markets, beginning in May 2003. The expansion, expected to phase in over the next several months, will include: Arkansas, Colorado, Idaho, Montana, New Mexico, North Dakota, Oklahoma, South Dakota, and Wyoming. Upland Mortgage is presently licensed or qualified to originate home equity loans in 44 states. According to ABFI Chairman and Chief Executive Officer, Anthony J. Santilli, 'This expansion is demonstrative of much more than our ability to expand our business geographically. It is really a testament to the value we bring to those American consumers in every part of the country who are often ignored by more traditional lenders.'"

  Also for your information, a June 13, 2003, SEC filing on form 8K, ABFI disclosed that the U.S. Justice Department on May 14, 2003, requested via subpoena from ABFI all "loan files with respect to mortgage loan transactions in which the Company entered into a forbearance agreement with a borrower rather than pursue foreclosure or other contract remedies."

  The list of Household International (now HSBC) affiliates licensed in Pennsylvania is more extensive:
Household Realty Corporation Secondary Mortgage Lender P 0105, Harrisburg PA

Household Finance Consumer Discount Company P 1653, Harrisburg PA
Household Retail Services, Inc. Sales Finance Company P 1135, Wood Dale IL

HSBC Bank USA Sales Finance Company P 2136
HSBC Mortgage Corporation (USA), P 0079, Upper Darby PA
HSBC Mortgage Corporation (USA) 2ndary Mortgage Lender P 1980, Upper Darby PA

HSBC Bank USA Sales Finance Company P 2136
HSBC Mortgage Corporation (USA) Partially Exempt B 0079.001, Depew NY
HSBC Mortgage Corporation (USA) Partially Exempt B 0079.002, Fairfax VA

Beneficial Consumer Discount Company 2ndary Mortgage Lender P 210, Harrisburg PA
Beneficial Consumer Discount Company P 1942, Harrisburg PA
Beneficial Mortgage Services First Mortgage Broker P 2872, Narberth PA
Beneficial Mortgage Services Secondary Mortgage Broker P 0941, Narberth PA
Beneficial Savings Bank Sales Finance Company P 0294, Philadelphia PA 19106

  What a roster of rogues... Here's a few more, with street address: five CitiFinancials each, around Philadelphia, Pittsburgh, then Harrisburg:

1900 Grant Avenue, Philadelphia, PA 19115 - 215-856-9405
2110 Marlton Pike E. Rte 70, Cherry Hill, NJ 8003 - 856-424-2227
1404 US Hwy 130 North, Cinnaminson, NJ 8077 - 856-786-7399
1009 Pontiac Road, Drexel Hill, PA 190264816 - 610-789-6009
Route 130 & Browning Road, Brooklawn, NJ 8030 - 856-742-5130

3613 Library Road, Pittsburgh, PA 15234 - 412-881-6915
1063 Washington Avenue, Carnegie, PA 15106 - 412-429-2036
4136 Library Road, Castle Shannon, PA 15234 - 412-344-2780
300 Curry Hollow Road, Pleasant Hills, PA 15236 - 412-655-3870
7380 McKnight Road, Pittsburgh, PA 15237 - 412-367-9292

3843 Union Deposit Road, Harrisburg, PA 17109 - 717-564-8899
3401 Hartzdale Drive #126, Camp Hill, PA 17011 - 717-737-0431
6520 Carlisle Pike, Mechanicsburg, PA 17050 - 717-795-8102
1 Valley Street, Carlisle, PA 17013 - 717-249-9566
6049 Allentown Boulevard, Harrisburg, PA 17112 - 717-541-8633

Predatory lending in Pennsylvnia - for residents only...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Rhode Island

State Mortgage bank Regulator:
Rhode Island Banking Division

   They lost the headquarters of Fleet, the Providence television show, and now everything else. On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its office in Rhode Island (300 Centerville Road in Warwick) into a branch of a federal savings bank, Chase FSB, to escape state laws... From here, a bureaucrat wrote that Household had done nothing wrong:

Dear Attorney General Lynch:

  On behalf of the Inner City Press/Community on the Move and its members, and of the Fair Finance Watch (collectively, "ICP"), this is an appeal, pursuant to. R.I. Gen. Laws § 38-2-8(b), from Special Assistant Attorney General Field's Feb. 14, 2003, letter (the "Denial") partially denying access to records responsive to ICP's Jan. 10, 2003, request for records related to your Office's recent Settlement with Household International, Inc. ("Household"), etc..

The Denial divides ICP's request into seven categories of records, and specifies some records that are being withheld. However, we contend that that are additional responsive records which are being withheld. Annexed hereto are certain documents, to be considered in connection with this appeal, which have been provided to ICP by the Offices of Attorney General of other states, including some with open records laws far narrower than the Rhode Island Access to Public Records Act ("APRA"). Also, as a Rhode Island-specific example, consider this e-mail

From: [ ] @riag.state.ri.us

Subject: RE: Predatory Lending Follow-up

Date: Tue, 10 Dec 2002 15:49:59 -0500

...the AG's office is not doing anything about this matter. I don't mean to be glib; we do not regulate banks in the AG's office, nor may we, since other state and federal agencies do. It may be unhappy to contemplate, but complaints received in DBR about HHF's actions do not violate any of DBR's banking laws, and our consumer protection laws are not helpful here either. So you may wonder why we are included in the settlement at all....RIers are getting relief primarily because of the resources in other states and their stronger laws as they pertain to banking and consumer affairs.

Received: by ATTG3 with Internet Mail Service (5.5.2656.59) id <Y1CWXAHM>; Tue, 10 Dec 2002 15:50:00 -0500 Message-ID: <71C3777FAD7CD611B0ED0008C733BF905B6F1E@ATTG3>

   That is simply an example, providing a basis for why ICP contends that responsive records are being withheld, even beyond those enumerated in the Denial. In connection with this appeal, a broader search of agency documents should take place (including in light of the other documents annexed hereto). As to the enumerated withheld documents, we specifically contest the withholding of the "letter of final action" (Denial at 2), the Dec. 6, 2002, e-mail (id. at 1), and, most absurdly, the "press release by Household." That document, like others, is clearly already publicly available, eviscerating any basis to withhold it. We also contest, and appeal from, the withholding of all records responsive to the first and seventh of the categories into which the Denial divided our request.

  We reiterate our request for expedition, and question whether the confidentiality provisions of your Consent Judgment with Household should be voided as contrary to public policy and applicable open government laws -- including but not limited to APRA -- in that, as applied, they result in Household being shielded, even more than other subprime lenders, from public scrutiny. For example, Household should have no right to be notified of, or to object to, disclosure of the type of inter- and intra-agency communications annexing hereto, and that have been released to ICP by other states' Offices of the Attorney General.

  For your information, as recently as Feb. 14, 2003, HSBC has represented to regulators that "[w]ith the exception of refund-anticipation loans... all of the products and practices to which ICP refers were considered in connection with or were the subject of the Settlement" (emphasis added; this quote is from HSBC's 2/14/03 submission to the Delaware Insurance Department). As should be clear, HSBC is arguing that since your Office, and the multi-state group, did not act on, for example, Household's non-branch real estate loans, and other non-real estate loans, this means that these Household's practices have been "considered" and vetted, and implicitly given a seal of approval, by your Office and the multi-state group.

Return to Predatory Bender's Citi States Map, @ Inner City Press

South Carolina

State Mortgage bank Regulator:
South Carolina Department of Consumer Affairs

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has 31 branches in the state of South Carolina. On December 1, 2003, Inner City Press submitted this comment to the South Carolina State Board of Financial Institutions:

Dear Director C. Dean Bratton, Commissioner Jacobs, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its 31 branch offices in South Carolina. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in South Carolina.

That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by WaMuFinance.com, which lists

1408 Whiskey Rd., Aiken, SC 29803; 3420 N. Main St., Anderson, SC 29621; 1705 N. Main St., Anderson, SC 29621; 38 McDonough St., Barnwell, SC 29812; 2509 Broad St., Camden, SC 29020; 1663 Savannah Hwy., Ste. 1, Charleston, SC 29407; 1696 Old Towne Rd., Charleston, SC 29407; 23195 Hwy. 76, E., Ste. A, Clinton, SC 29325; 7364-A Two Notch Rd., Columbia, SC 29223; 3315 Broad River Rd., Ste. 100, Columbia, SC 29210; 1601-A W. Palmetto St., Florence, SC 29501; 601 Haywood Rd., Greenville, SC 29607; 690B 72 Bypass, N.W., Greenwood, SC 29649; 1317-B W. Poinsett St., Greer, SC 29650; 112 W. Carolina Ave., Hartsville, SC 29550; 516 E. Main St., Kingstree, SC 29556; 1113-A Hwy. 9 Bypass, Lancaster, SC 29720; 744 W. Main St., Lexington, SC 29072; 1013 Old Hwy. 52, Ste. K, Moncks Corner, SC 29461; 2026 Bear Village Court, Newberry, SC 29108; 2070 Northbrook Blvd., North Charleston, SC 29406; 1354 Grove Park Dr., Orangeburg, SC 29115; 2371 Cherry Rd., Rock Hill, SC 29732; 100 Hwy. 123, E., Seneca, SC 29678; 1000 N. Pine St., Ste. 9, Spartanburg, SC 29303; 8031 Warren H. Abernathy Hwy., Spartanburg, SC 29301; 21-B W. Wesmark Blvd., Sumter, SC 29150; 410 N. Duncan Byp., Ste. A, Union, SC 29379; 1606 Airport Blvd., West Columbia, SC 29169; 1505 Charleston Hwy., West Columbia, SC 29169; 529 Cross Anchor Hwy., Woodruff, SC 29388

Click here for the continuation of ICP's Comment.  Here's the state of the state, on matters predatory:

  Here's SB 438 / Act 42 - "High-Cost And Consumer Home Loans Act" (click here, in pdf) -- and, in html, a (lenders') lawyer's article about the law.  It becomes effective January 1, 2004.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its three offices in South Carolina (Greenville, Piedmont and Columbia) into branches of a federal savings bank, Chase FSB, to escape state laws...

Return to Predatory Bender's Citi States Map, @ Inner City Press

South Dakota

State Mortgage bank Regulator:
South Dakota Department of Commerce & Regulation

  In fighting Citi-Associates, the SD regulator held a hearing; at the 11th hour, Citigroup tried to prevent ICP for participating:

Dear Mr. Duncan, Dept. of Commerce and Regulation

  On the evening of October 9, 2000, Columbus Day, at 11 p.m., I was informed by a staff member of Inner City Press/Community on the Move ("ICP") that counsel to Citigroup, Inc. had just faxed a letter to ICP's office, purporting to oppose ICP's party status for the October 10, 2000 hearing in the above-captioned matter.

   As you know, ICP's request for party status was granted, by letter dated October 2, 2000. In our phone conversation on October 5, you agreed to allow ICP to participate as a full party, by telephone, at the hearing on October 10 at 10 a.m. CST. There should be no need for ICP to respond to Citigroup's counsel's eleventh hour opposition. However, having reviewed Citigroup's counsel's letter, and its one-sided (and misleading) presentation of case law, at 2, ICP is submitting this response.

  Citigroup's counsel devotes the longest paragraph of the letter to a one-sided presentation of federal appeals court litigation under the Community Reinvestment Act ("CRA") -- which is not the statute at issue here. In any event, note that New York State courts have held that ICP has standing, to seek judicial review of decisions by the New York State banking regulator. See, e.g., Inner City Press / Community on the Move v. New York State Banking Bd., 170 Misc. 2d 684, 657 N.Y.S.2d 275, 1996 N.Y. Misc. LEXIS 397, which held inter alia that

Petitioner Inner City Press meet the test [for standing]... Banking Law Section 142... sets forth certain criteria that the Banking Board must consider in determining whether or not to approve a merger application, including... 'primarily, the public interest and the needs and convenience thereof."... The court finds that petitioners have legally cognizable interests that are encompassed by such statutes... Petitioners also are the appropriate organization to represent the interests of low to moderate income predominantly minority neighborhoods... For all of these reasons, petitioners have standing to maintain this action.

  I look forward to participating in the hearing...

   And did.

Return to Predatory Bender's Citi States Map, @ Inner City Press

Tennessee

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has 60 branches in the state of Tennessee. On December 1, 2003, Inner City Press submitted this comment to the Tennessee Department of Financial Institutions :

Dear Commissioner Lavender, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its 60 branch offices in Tennessee (WaMu Finance's biggest state). This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in Tennessee.

    That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by your website, www.state.tn.us/financialinst/Lic_TILT.html#W, and by WaMuFinance.com, which lists:

276 Gill St., Alcoa, TN 37701; 1357 W. Market St., Bolivar, TN 38008; 1135 Volunteer Parkway, Ste. 2, Bristol, TN 37620; 2010 W. State St., Bristol, TN 37620; 1395 Volunteer Parkway, Bristol, TN 37620; 3823 Ringgold Road, Chattanooga, TN 3741; 108 Northgate Commercial Ctr., Chattanooga, TN 37415; 5791 Brainerd Rd., Chattanooga, TN 37411; 111 N. Riverside Dr., Clarksville, TN 37040; 2441 Keith St., N.W., Cleveland, TN 37311; 1129 Trotwood Ave., Ste. 28, Columbia, TN 38401; 813-B S. Garden, Columbia, TN 38401; 420 S. Lowe, Ste. 23, Cookeville, TN 38501; 125 Cumberland Plaza, Crossville, TN 38555; 209-H Henslee Dr., Dickson, TN 37055; 1075 Vendall Rd., Dyersburg, TN 38024; 1970-C W. Elk Ave., Elizabethton, TN 37643; 335 W. Main St., Gallatin, TN 37066; 1106 S. Roane, Harriman, TN 37748 - 37748; 4412-A Lebanon Rd., Hermitage, TN 37076; 5502-F Hixson Pike, Hixson, TN 37343; 2911 E. End Dr., Humboldt, TN 38343; 1903 N. Highland Ave., Jackson, TN 38305; 1321 Sunset Dr., Johnson City, TN 37604; 3120 E. Oakland Ave., Johnson City, TN 37601; 1137 N. Eastman Rd., Kingsport, TN 37664; 1409-H East Stone Dr., Kingsport, TN 37660; 714 S. Gay St., Knoxville, TN 37902; 8079 Kingston Pike, Ste. L, Knoxville, TN 37919; 4922 Broadway, N.E., Knoxville, TN 37918; 1059 Scottsville Rd., Lafayette, TN 37083; 123 Myers Lane, Ste. 103, LaFollette, TN 37766; 1416 W. Main St., Lebanon, TN 37087; 404 Hwy. 321, N., Unit 10, Lenoir City, TN 37771; 134 Cude Lane, Madison, TN 37115; 911 Madison Square, Madison, TN 37115; 151 Warren St., Madisonville, TN 37354; 182 University Plaza, Martin, TN 38237; 6500 Winchester Rd., Ste. 2, Memphis, TN 38115; 4093 Summer Ave., Memphis, TN 38122; 3624-5 Austin Peay Hwy., Memphis, TN 38128; 4095 American Way, Ste. 8, Memphis, TN 38118; 5945 Knight Arnold Rd., Memphis, TN 38115; 6084 S. First St., Milan, TN 38358; 1329 W. Andrew Johnson Hwy., Morristown, TN 37814; 135 W. Northfield Blvd., Murfreesboro, TN 37129; 3782 Nolensville Rd., Nashville, TN 37211; 127 Hwy. 25, E., Newport, TN 37821; 158 Fairbanks Rd., Oak Ridge, TN 37830; 1021 Mineral Wells Ave., Paris, TN 38242; 117 W. Madison St., Pulaski, TN 38478; 118 Walmart Dr., Ripley, TN 38063; 2107 Wayne Rd., Savannah, TN 38372; 145 S. Y Square, Selmer, TN 38375; 311 Court Ave., Sevierville, TN 37862; 183 Mose Dr., Sparta, TN 38583; 2023 Memorial Blvd., Ste. C, Springfield, TN 37172; 1802 N. Jackson St., Tullahoma, TN 37388; 1441 S. First St., Union City, TN 38261; 704 Dinah Shore Blvd., Winchester, TN 37398

Click here for the continuation of ICP's Comment.  Here's the state of the state, on matters predatory:

  Hard to get documents, not the height of compliance. On October 30, 2003, the proposed  "Tennessee Home Loan Protection Act" was introduced - click here (in pdf format). Previously, HB 21, the "Tennessee Predatory Lending Prevention Act," died in the Utilities and Banking Subcommittee... On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its three offices in Tennessee (Hermitage, Brentwood and Nashville)   into branches of a federal savings bank, Chase FSB, to escape state laws...And here's just five of the CitiFinancials in and around Knoxville, TN:

6733 Clinton Highway, Knoxville, TN 37912 - 865-947-5655
2605-D Adair Drive, Knoxville, TN 37918 - 865-688-4996
8805 Kingston Pike, Knoxville West, TN 37923 - 865-693-0482
1078 Hunter's Crossing Dr, Alcoa, TN 37701 - 865-983-5913
150 North Seven Oaks Dr, Knoxville, TN 37922 - 865-539-4891

Return to Predatory Bender's Citi States Map, @ Inner City Press

Texas

State Mortgage bank Regulator:
Texas Savings and Loan Department
Texas Office of Consumer Credit Commissioner

  Ground Zero of independent predators, especially in Irving. 

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has 45 branches in the state of Texas. On December 1, 2003, Inner City Press submitted this comment to the Texas Office of Consumer Credit Commissioner:

Dear Commissioner Pettijohn, Ms. Wolfenbarger, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its 45 branch offices in Texas. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in Texas.

    That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by WaMuFinance.com, which lists

811 E. Main, Ste. A, Alice, TX 78332; 4207 W. 21st St., Amarillo, TX 79106; 8868 Research Blvd., Ste. 705, Austin, TX 78758; 614 S. Gregg St., Big Spring, TX 79720; 943 N. Expressway Ste. 17 & 18, Brownsville, TX 78520; 555 W. Commerce, Brownwood, TX 76801; 4001 E. 29th St.,Ste. 107, Bryan, TX 77802; 6012 S. Padre Island Dr., Corpus Christi, TX 78412; 3223 W. Camp Wisdom Rd., Dallas, TX 75237; 2502-A W. Freddy Gonzalez, Edinburg, TX 78539; 1360 Lee Trevino, Ste. 206, El Paso, TX 79936; 7500 N. Mesa, Ste. 318, El Paso, TX 79912; 10005 Alameda, Ste. S, El Paso, TX 79927; 5959 Gateway W. Blvd., El Paso, TX 79925; 9109 Dyer St., Ste. R, El Paso, TX 79924; 1212 E. Harrison St., Ste. 175, Harlingen, TX 78550; 10777 N.W. Freeway, Ste. 110, Houston, TX 77092; 12517 Interstate 45 N., Houston, TX 77060; 901 Normal Park Dr., Ste. 106, Huntsville, TX 77320; 943 Melbourne Rd., Hurst, TX 76053; 429 This Way St., Lake Jackson, TX 77566; 707 E. Calton Rd., Ste. 203, Laredo, TX 78041; 501 Spur 63, Longview, TX 75601; 4620 50th St., Ste. 2, Lubbock, TX 79414; 303 E. Denman Ave., Ste. G, Lufkin, TX 75901; 417 S. Broadway, McAllen, TX 78501; 3501 Gus Thomasson Blvd., Mesquite, TX 75150; 2700 E. Griffin Parkway Ste. E, Mission, TX 78572; 508 N. Washington Ave., Mt. Pleasant, TX 75455; 2805 North St., Ste. C, Nacogdoches, TX 75965; 4555 E. University Ave., Odessa, TX 79762; 1004 E. Palestine Ave., Palestine, TX 75801; 3304 Lamar Ave., Paris, TX 75460; 3622 Fairmont Pkwy., Ste. C, Pasadena, TX 77504; 4241 S.W. Blvd., San Angelo, TX 76904; 139 S.W. Military Dr., San Antonio, TX 78221; 7071 San Pedro, San Antonio, TX 78216; 213 N. Travis St., Sherman, TX 75090; 4211 Texas Blvd., Texarkana, TX 75503; 3307 Palmer Hwy., Texas City, TX 77590; 535 wsw Loop 323, Tyler, TX 75701; 1923 E. Red River, Victoria, TX 77901; 3707 Franklin Av., Waco, TX 76710; 509 W. Hwy 83, Weslaco, TX 78596; 3102 Kemp Blvd., Wichita Falls, TX 76308

Click here for the continuation of ICP's Comment.

Return to Predatory Bender's Citi States Map, @ Inner City Press

Utah

State Mortgage bank Regulator:
Utah Department of Financial Institutions
Utah Real Estate Division

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has three branches in the state of Utah. On December 1, 2003, Inner City Press submitted this comment to the Utah Department of Financial Institutions:

Dear Commissioner Leary, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its three branch offices in Utah. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, including under the Government Record Access and Management Act (GRAMA), for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in Utah.

    That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by WaMuFinance.com, which lists the following offices:

Washington Mutual Finance, Logan
926 N. Main St., Logan, UT 84321

Washington Mutual Finance, Ogden
4173 Riverdale Rd., Riverdale, UT 84405

Washington Mutual Finance, Salt Lake City
4900 S. Redwood Rd., Ste. C, Salt Lake City, UT 84123

Click here for the continuation of ICP's Comment. Here's the state of the state, on matters predatory:

   On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its two offices in Utah (South Ogden, and 2180 S. 1300 East in Salt Lake City) into branches of a federal savings bank, Chase FSB, to escape state laws...Home of the predatory servicer Fairbanks Capital (controlled by the PMI Group - which ICP raised, see, e.g., "Financial Guaranty Insurance Co. Sale to PMI Group Sparks Protest," by Bonnie McGeer, Asset Securitization Report, September 15, 2003); bad experience with defeatist from the Utah AG's Office:

  On Jan. 10, 2003, ICP requested such records from the Utah Office of the Attorney General (the "AG's Office"). Under cover letter dated Jan. 14, 2003 (the "First Denial"), Mr. Wayne Klein of the AG's Office sent ICP certain very limited records; on Jan. 27-28, 2003, ICP faxed a letter and exhibits in response: in essence, an appeal.

  Mr. Klein's Feb. 5, 2003, letter (the "Second Denial") inter alia sought to impose fees on even the initial response, and denied access to numerous records which we believe should be released, both because they are not exempt from disclosure, and in the public interest. We are concerned that some of the withholdings are made in light of the Confidentiality provisions of the AG's Office's settlement with Household; in connection with this appeal, we ask the State Records Committee to consider whether paragraph 39 of the Consent Judgment is consistent with Utah law (including but not limited to Utah Code Ann. § 63-2-201(2), which provides that "[a]ll records are public unless otherwise expressly provided by statute"), with principles of open government, or whether it should be voided or modified as contrary to public policy...

  To put this appeal in context, we note a letter by Mr. Klein, to a complainant whose name has apparently been redacted, stating inter alia that "Utah does not have laws making these practices illegal and there is no agency that oversees companies like [Household]. The Division of Consumer Protection has no authority over home loans. The Division of Real Estate has limited powers to require a license of mortgage companies, but does not regulate their practices. The Department of Financial Institutions has little authority over first mortgage loans. In sum, the legislature has not found a need to impose regulatory oversight over this industry." But see, the Salt Lake Tribune of February 10, 2003, at B3, reporting that House Bill 189, "to impose consumer-friendly restrictions on so-called 'predatory lenders' got the go-ahead Friday from House members." While the AG's Office may still technically claim that "the legislature has not found a need to impose regulatory oversight" on high-rate, allegedly predatory mortgage lenders, the knee-jerk rejection of a good-faith appeal, such as the Third Denial (and the Second Denial's attempt to begin imposing fees because Inner City Press continued to seek records regarding the AG's Office's settlement with Household), is inconsistent with law (see above), with open government and with the public interest.
For the reasons set forth in the letter and exhibits we faxed to Mr. Klein, the AG's Office's lead lawyer in the Household Settlement, on Jan. 27-28, ICP is concerned that the Household Settlement is too narrow (being limited to branch-originated real estate loans); we are additionally concerned that Household may already be violating the spirit and/or letter of the Settlement, and that HSBC might move even further in this regard.

  And they have...And HB 249  died on the vine...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Vermont

State Mortgage bank Regulator:
Vermont Department of Banking, Insurance, Securities and Health Care Administration

  Here's an Anti-Predatory Lending bill that was introduced in the Vermont Senate, BX 230 (click here, in pdf format). SB 83 was referred to the Senate Finance Committe back on February 11, 2003...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Virginia

State Mortgage bank Regulator:
Virginia Bureau of Financial Institutions

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has 20 branches in the state of Virginia. On December 1, 2003, Inner City Press submitted this comment to the Virginia Bureau of Financial Institutions:

Dear Commissioner Face, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its 20 branch offices in Virginia. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, including Va. Code Ann. § 2.2-3704(A), for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. We make this request as media that broadcasts into Virginia; also / but see, "Lawsuit Challenges Delaware Records Law: Nonresidents Denied Use of Freedom of Information Act," by Mary Allen, Wilmington News-Journal, November 27, 2003, <www.delawareonline.com/newsjournal/local/2003/11/27lawsuitchalleng.html>. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in Virginia.

    That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by WaMuFinance.com, which lists the following offices:

259 Zan Rd., Charlottesville, VA 22901; 3408 Virginia Ave., Collinsville, VA 24078; 798 Southpark Blvd., Ste. 30, Colonial Heights, VA 23834; 601 Meadowbrook Shopping Ctr., Culpeper, VA 22701; 204 Westover Dr., Danville, VA 24541; 110 Exchange St., Ste. A, Danville, VA 24541; 7115 Leesburg Pike, Ste. 102, Falls Church, VA 22043; 1506 S. Main St., Unit 10, Farmville, VA 23901; 1100-142 Armory Dr., Franklin, VA 23851; 2189 Cunningham Dr., Hampton, VA 23666; 2225 Lakeside Dr., Unit C-1, Lynchburg, VA 24501; 7460 Lee Hwy., Radford, VA 24141; 3129 Mechanicsville Turnpike, Richmond, VA 23223; 7112-A Hull St. Rd., Richmond, VA 23235; 7801 W. Broad St., Ste. 9, Richmond, VA 23294; 1301 Towne Square Blvd., Roanoke, VA 24012; 4019 Halifax Rd., Ste. B, South Boston, VA 24592; 5386 Kemps River Dr., Ste. 108, Virginia Beach, VA 23464; 2522 Jefferson Hwy., Ste. 102, Waynesboro, VA 22980; 2210 Wilson Blvd., Winchester, VA 22601; 800 E. Main St., Wytheville, VA 24382

Click here for the continuation of ICP's Comment.  Here's the state of the state, on matters predatory:

  Among other things,  Pat Robertson's base (click here for ICP's Report on Pat's ill-conceived proposed partnership with Bank of Scotland). Senate Bill 1103, based on recommendations by the Virginia Housing Study Commissioner, was signed by the Governor on March 16, 2003.  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its 12 offices in Virginia into branches of a federal savings bank, Chase FSB, to escape state laws...

Return to Predatory Bender's Citi States Map, @ Inner City Press

Washington

State Mortgage bank Regulator:
Washington Department of Financial Institutions

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has a branch in the state of Washington. On December 1, 2003, Inner City Press submitted this comment to theWashington Department of Financial Institutions

Dear Director Howell, Mr. Vincent, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its branch office(s) in Washington State. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a request, following up on Mr. Vincent's September 25, 2003, letter to ICP for Ms. Howell, for a hearing, and for an investigation into CitiFinancial's practices in Washington.

    That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by www.dfi.wa.gov/cs/licensee_list_031117.pdf, which lists

Washington Mutual Finance Inc / Aristar Mortgage Company
23861 El Toro Rd, 5th FL Lake Forest CA 92630 (949) 580-6601 (949) 580-6672
Carmela Baldeon 18357 Consumer Loan - Main Office 3/1/2004

Washington Mutual Aristar Mortgage
3405 McLemore Dr Pensacola FL 32514 (800) 838-4956 (800) 838-4957 18357-18358
Consumer Loan - Branch 3/1/2004

WaMuFinance.com also lists:

Washington Mutual Finance, Vancouver
6713 N.E. 63rd St., Ste. 103, Vancouver, WA 98661

Click here for the continuation of ICP's Comment.  Here's the state of the state, on matters predatory:

  On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its ten offices in Washington State into branches of a federal savings bank, Chase FSB, to escape state laws. ICP wrote in, and the Department of Financial Institutions' legal counsel, Joe Vincent, then explained his understanding that CMMC is a subsidiary of Chase Manhattan Bank USA N.A. (actually, it isn't) -- and then stated, "I wish to express on behalf of our Director, Helen Howell, appreciation for your concerns... It is not, however, within the purview of the DFI to speculate on or officially comment on the application of CMMC to become a federal savings bank, a matter solely within the jurisdiction of the OTS and FDIC."  Ms. Howell similar prevaricated with regard to Wells Fargo...

Supposedly the Washington AG's Office led the fight against Household -- they structured a settlement on the cheap and defended it in boiler plate letters distributed to other states:

Dear Mr. Huey, Assistant Attorney General:

...While we have yet to receive a single documents from your Office in response to our Jan. 10, 2003, request, we have been provided with some responsive documents by other agencies to which we directed similar requests on Jan. 10, 2003. These include, for example, a memorandum entitled "State of Washington Meeting with HFC, May 23, 2002" (see infra); a letter you wrote to Kathleen Curtin of Household on June 28, 2002; a seemingly related memorandum to Ms. Curtin, dated June 21, 2002, "Re: Request for general information for July 9 meeting;" and an undated document entitled "Summary of Relief Sought by Washington AGO CP Division Against Household International, Inc.."

   We remain surprised that your Office has not, to date, provided us with any documents responsive to our Jan. 10 request. Your letter refers to file cabinets full of complaints against Household -- but as soon as I was contacted by Ms. O'Hearne, I limited ICP's request, as to complaint, to computer print-out summaries of such complaints. That was on Jan. 22, but still not documents have been provided. On Feb. 14, after I attempted to reach you by telephone, I received an e-mail from Daniel Owen of your Office, stating "I received a copy of your letter dated January 22, 2003. You mentioned Missouri granted your fee waver, what other states also granted your waver?" Forty-four days after the submission of our records request, I listed other states, and then re-emphasized the Jan. 22 narrowing of ICP's request:

we don't want the 30,000 pages provided in your Office's initial estimate. We then waived our request for the actual complaints, and asked only for a computer generated list. We were told that the complaints made up most of the 30,000 page estimate. But I've just been told that the estimate may now be 30,000 to 50,000 pages, and that payment in advance would be required.

I'm sensing some incongruity with other states' AG's Offices responses, ironic in light of your Office's lead role in the settlement with Household and in light of AAG Huey's Dec. 13, 2002, letter to ICP, stating that "You raise important questions, which I believe are best addressed in the context of the state and federal regulatory proceedings related to the approval" of HSBC's applications to acquire Household. We were and are seeking these documents among other things to participate in those proceeding; in those proceeding, HSBC has said that the Settlement addresses or considered all of the Household issues we've raised, except tax Refund Anticipation Loans.

Our Jan. 10 records requests was intended to obtain documents to respond to this HSBC / Household (mis-) representation of the settlement, but to date have received not a single document from your Office. Outside of the public records process, we would like (and have requested) for your Office and/or the multi-state group or the executive committee thereof to make clear what the settlement considered and addressed and what it doesn't.

We are concerned that the Confidentiality provisions of the Consent Judgment(s) may be playing a role in your Office's delayed provision of responsive documents; we would ask that you consider whether those confidentiality provisions (1) are consists with RCW 42.17.270, et seq., and (2) don't provide Household with an even greater shield from accountability and public disclosure that other controversial subprime lenders. Many states' FOI responses have cc-ed Household; some states have provided their communications with Household regarding our request(s); I've now noticed a state cc-ing Mr. Huey on its FOI response to ICP.

The further irony: we have obtained (at no cost), for example, AAG Huey's June 28, 2002, letter to Household's Kathleen Curtin, and a memo about a state of Washington meeting with HFC on May 23, 2002. These are the type of documents we've been requesting from your Office since Jan. 10; we sure hope to receive them soon.

  The reference above to another state's Attorney General's Office cc-ing you on an interim FOI response is to Ohio, which also has yet to provide us with any of the responsive documents. You've cc-ed your Feb. 18 letter to Household's John Blenke; I'm left wondering if that's your reading of the Consent Judgment, that "notice" must be provided to Household of any communication regarding the company, its practices or its proposed new owner. If so, this certainly is a "right" that other subprime lenders don't enjoy. We are concerned that these and other confidentiality provisions of the Consent Judgments will make it even more difficult to protect consumers from the Household practices to which several of the documents we've obtained refer, but which are not the subject matter of the Consent Judgments.

...Accordingly, we would ask that your Office, and/or the executive committee of the multi-state group, respond to the above-quoted HSBC statements regarding "the products and practices.[which] were considered in connection with or were the subject of the Settlement," prior to the expiration of the review periods in any more of the regulatory proceeding on HSBC's applications to acquire Household. We also ask that the documents we've been requesting since Jan. 10, 2002 -- and which since Jan. 22 have not included the underlying file cabinets full of complaints to which you refer -- be provided as quickly as possible.

  Ten months later, we still don't have the documents... Here's just three of the CitiFinancials in Washington State, these are around Seattle:

10708 5th Avenue NE, Seattle, WA 98125 - 206-365-9675
330 Southwest 43rd Street, Renton, WA 98055 - 425-251-8207
10408 Silverdale Way NW, Silverdale, WA 98383 - 360-308-0903   

Return to Predatory Bender's Citi States Map, @ Inner City Press

West Virginia

State Mortgage bank Regulator:
West Virginia Division of Banking - and W. Virginia Code

  CitiFinancial's new acquisition target in its Predatory Bender, Washington Mutual Finance, has four branches in the state of West Virginia. On December 1, 2003, Inner City Press submitted this comment to theWest Virginia Division of Banking:

Dear Commissioner Stark, others:

On behalf of Inner City Press / Community on the Move and its members and affiliates, and the Fair Finance Watch (ICP), this concerns the subprime lender CitiFinancial and its proposal, announced November 24, 2003, to acquire Washington Mutual Finance and its (at least) four branch offices in West Virginia. This comment and the exhibits hereto should be considered first in opposition to CitiFinancial's WaMu Finance proposal. Relatedly, this letter is a request, under your freedom of information statute, including W. Va. Code § 29B-1-2, for copies of any application or notice submitted by Citi, and all consumer complaints against Citi and/or Washington Mutual Finance for the past three years. This is also a formal request for a hearing, and for an investigation into CitiFinancial's practices in West Virginia

    That CitiFinancial's target, WaMu Finance, has offices in your state, under your jurisdiction, is reflected by www.wvdob.org/consumers/Regulated_consumer_lenders.asp which lists the following offices:

201 W. Main Street, Clarksburg, WV 26301
1857 Route 21 South, Ripley, WV 25271
2200 Grand Central Avenue, Vienna, WV 26105
#31 By-Pass Plaza Shopping Center, Beckley, WV 25801

Click here for the continuation of ICP's Comment. .(Click here, c/o W. Virginia Legal Services).

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Wisconsin

State Mortgage bank Regulator:
Wisconsin Department of Financial Institutions

   Another ICP venue - see, e.g., "Minorities Might Pay Cost of Firstar Merger, Group Says," by Paul Gores, Milwaukee Journal Sentinel, December 5, 2000,  Pg. 3D; "Fed Requests More Information on Banks' Minority Lending Practices," by Paul Schwab, The Business Journal of Milwaukee, December 15, 2000. On the preemption front, currently state-regulated (and subprime-lending) Chase Manhattan Mortgage Corporation is trying to convert its three offices in Wisconsin (two in Brookfield, and 4050 W. Spencer St. in Appleton) into branches of a federal savings bank, Chase FSB, to escape state laws...

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Wyoming

State Mortgage bank Regulator:
Wyoming Division of Banking

ICP challenged Chase Manhattan and U.S. Trust of Wyoming, for breaking the law. Here's a long decision.

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American Samoa - coming soon

State Mortgage bank Regulator:

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Guam - coming soon

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Puerto Rico

State Mortgage bank Regulator:
Puerto Rico Commissioner of Financial Institutions - file complaints

  La Isla del Encanto -- and of Wells Fargo's high-cost Island Finance...

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U.S. Virgin Islands

Department of Licensing and Consumer Affairs

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