CRA Hearing in Los Angeles, August 17, 2010 -- Part 4

  THE THIRD PANEL THAT WE WILL HEAR FROM TODAY CONSISTS OF CEYL PRINSTER OF COLORADO ENTERPRISE FUND,
  ROBERTO BARRAGAN OF VALLEY ECONOMIC DEVELOPMENT CENTER, CLARENCE WILLIAMS OF CALIFORNIA CAPITAL FINANCIAL DEVELOPMENT CORPORATION,
  ALAN FISHER OF THE CALIFORNIA REINVESTMENT COALITION. PREETI VISSA OF THE GREENLINING INSTITUTE
  AND JOANG LING OF THE COMMUNITY CORPORATION OF SANTA MONICA PRESENTING FOR THE LOW INCOME HOUSING INSTITUTE.
  WITH THOSE BRIEF INTRODUCTION, LET ME ASK MS. PRINSTER TO BEGIN.
  >> THANK YOU VERY MUCH. ON BEHALF OF COLORADO ENTERPRISE FUND,
  I APPRECIATE THE OPPORTUNITY TO ENGAGE IN THE DISCUSSION ON MODERNIZING THE COMMUNITY REINVESTMENT ACT.
  COLORADO ENTERPRISE FUND IS A CDFI THAT HAS BEEN HELPING SMALL BUSINESSES ACROSS THE STATE
  OF COLORADO FOR NEARLY 35 YEARS. WE PROVIDE ACCESS TO AFFORDABLE, FLEXIBLE LOAN CAPITAL
  AND OFFERED A ADVISORY SERVICES TO BUILD THE MANAGEMENT CAPACITY OF BUSINESS OWNERS AND ENTREPRENEURS.
  OUR GOAL IS TO PROVIDE ECONOMIC OPPORTUNITY TO LOW AND MODERATE?INCOME INDIVIDUALS
  BY CATALOGING BUSINESS FORMATION AND GROWTH AS THE ECONOMIC ENGINE FOR HEALTHY COMMUNITIES IN OUR STATE.
  THE C.R.A. OVERALL HAS FOSTERED COMMUNITY AND ECONOMIC DEVELOPMENT WELL, SUPPORTING COUNTLESS ORGANIZATIONS,
  STRATEGIES AND INITIATIVES IN ADDITION TO LENDING.
  IT HAS HELPED CREATE ECONOMIC OPPORTUNITY BY CONNECTING UNDERSERVED MARKETS WITH FINANCIAL CAPITAL AND SERVICES.
  I WILL BE DISCUSSING C.R.A. AS IT RELATES TO THE NEEDS OF SMALL BUSINESS.
  SINCE THIS IS THE AREA IN WHICH I WORK AND WHICH I BELIEVE NEEDS INCREASED FOCUS.
  THE CURRENT ECONOMIC CRISIS WHICH STARTED AS AN IMPLOSION IN THE HOME MORTGAGE MARKET
  HAS NOW BECOME A CALAMITY FOR SMALL BUSINESS, WHICH ARE THE MAINSTAY OF JOBS
  AND ECONOMIC VITALITY IN THIS COUNTRY. AND I BELIEVE C.R.A. CAN DO MORE TO HELP ADDRESS THIS CALAMITY.
  IN ADDITION, THESE CONVERSATIONS ABOUT C.R.A. SHOULD DOVETAIL WITH THE FINDINGS
  OF A SERIES OF OVER 40 MEETINGS HELD ACROSS THE COUNTRY THIS YEAR BY THE FEDERAL RESERVE
  ON ADDRESSING THE FINANCING NEEDS OF SMALL BUSINESS, WHICH IDENTIFIED ISSUES THAT HAVE IMPACTED THE SUPPLY OF
  CREDIT TO SMALL BUSINESS. WHEN THE BAR FOR SAFETY AND SOUNDNESS OF LENDING TO SMALL BUSINESS IS RAISED SO
  HIGH AS TO MAKE IT IMPOSSIBLE TO GET A LOAN, ECONOMIC DEVELOPMENT IS HALTED.
  BOTH SIDES OF THE HOUSE NEED TO BE TALKING TO EACH OTHER SO THAT DIFFERENT GOVERNMENT STAKE HOLDERS
  NOT SENDING CONFLICTING MESSAGES, AS HAS BEEN EXPERIENCED IN THE CURRENT ENVIRONMENT.
  THE FEDERAL RESERVE SMALL BUSINESS MEETINGS IDENTIFIED CREDIT GAPS THAT UPDATED C.R.A. POLICIES
  COULD HELP ADDRESS, SUCH AS THE NEED FOR LINES OF CREDIT AND WORKING CAPITAL, REFINANCING MATURING LOANS,
  SMALL DOLLAR LOANS UNDER $200,000, PATIENT CAPITAL FOR BUSINESS NEEDS THAT TAKE TIME TO GENERATE REVENUE FOR DEBT
  SERVICE AND LOANS TO DISTRESSED INDUSTRIES LIKE CONSTRUCTION, RETAIL AND SERVICE BUSINESSES.
  ALSO STARTUP CAPITAL IS ALMOST IMPOSSIBLE TO OBTAIN BUT IN HIGH DEMAND
  AS UNEMPLOYED WORKERS WANT THE LAUNCH NEW BUSINESSES. ONE POSSIBILITY FOR ADDRESSING SOME OF THESE CREDIT GAPS
  IS TO GIVE C.R.A. CREDIT FOR SBA 7A LOANS IN ANY AMOUNT IN THE SAME WAY LOANS
  OVER A MILLION ALREADY ARE ELIGIBLE FOR C.R.A. TRACKING DATA ON ALL 7A LENDING AND INCORPORATING IT
  INTO C.R.A.S WOULD INCREASE BUSINESS START?UP ACQUISITIONS AND CERTAIN DEBT RESTRUCTURES.
  THE F.B.A. GUARANTEE PROVIDES SAFETY FOR THE BANK WHILE HELPING THE BUSINESS OBTAIN LOAN CAPITAL.
  NEVERTHELESS, THERE WILL STILL BE GAPS. BUSINESSES DENIED CREDIT OR PERCEIVED THEY WILL BE DENIED WILL TURN TO
  ALTERNATIVE SOURCES OF CAPITAL NOT OPTIMAL FOR SUSTAINED ECONOMIC DEVELOPMENT,
  SUCH AS USING CREDIT CARDS AND RETIREMENT ACCOUNTS, ADJUSTING TURNS ON RECEIVABLES AND PAYABLES
  AND USING EXPENSIVE FACTORING. C.D.F.I.S PRESENT THE OPTION OF PATIENT RESPONSIBLE AND FLEXIBLE BUSINESS CAPITAL,
  SUCCESSFULLY EXCUTING LOANS PERCEIVED AS HIGH RISK AND PROVIDING ACCESS TO CAPITAL IN TIMES OF ECONOMIC TURBULENCE.
  COLORADO ENTERPRISE FUND HAS NUMEROUS SUCCESSFUL BANK PARTNERSHIPS WITH NATIONAL,
  REGIONAL AND SMALL COMMUNITY BANKS THAT HAVE PROVIDED US WITH THE INVESTMENT CAPITAL FOR LOANS TO SMALL BUSINESSES
  FOR MANY YEARS. OUR BANK PARTNERS SEE THESE INVESTMENTS AS AN EFFICIENT MEANS OF REACHING MARKETS OR
  POPULATIONS THAT ARE DIFFICULT FOR THEM TO SERVE DUE TO VARIOUS ECONOMIC AND REGULATORY CONSTRAINTS,
  ESPECIALLY IN LIMITED SCOPE MARKETS WHERE THEY HAVE A SMALLER PRESENCE.
  WHILE BANKS HAVE BEEN A CRITICAL PARTNER OF C.D.F.I.S, A MODERN C.R.A. WOULD ENCOURAGE INSTITUTIONS TO
  EXPAND INVESTMENTS IN C.D.F.I.S BY GIVING PARTNERSHIPS MORE WEIGHT THROUGH DATA COLLECTION AND FACTORING
  C.D.F.I.RELATIONSHIPS MORE HEAVILY INTO PERFORMANCE EVALUATIONS.
  A NEW CRA SHOULD ALSO PROMOTE INNOVATIVE APPROACHES TO PARTNERSHIPS BY GIVING BANKS C.R.A. CREDIT
  FOR NEW FINANCING STRATEGYINGS WHILE STILL CONTINUING THEIR LONG?TERM INVESTMENTS IN C.D.F.I.S.
  AN EXAMPLE OF AN EFFECTIVE NEW STRATEGY THAT COULD BE ADAPTED IN THIS CONTEXT
  IS THE COLORADO CREDIT RESERVE, WHICH IS A CAPITAL ACCESS PROGRAM THAT HAS PROVIDED A RESOURCE TO FUND
  LOAN LOSSES AND HAS HELPED US LEVERAGE THESE DOLLARS BY FACTOR OF OVER 15 TO ONE
  FOR THE BENEFIT OF SMALL BUSINESSES. THIS IMPACT COULD BE REPLICATED AS A C.R.A.
  STRATEGY FOR BANKS TO EMPLOY MORE BROADLY IN SUPPORT OF C.D.F.I.S. THE NEED FOR TECHNICAL ASSISTANCE
  AND BUSINESS ADVISORY SERVICE IS AN AREA THAT COULD USE MORE EMPHASIS IN REVITALIZED C.R.A.
  HOME OWNERSHIP COUNSELING IS AN ACCEPTED AND WIDELY SUPPORTED SERVICE IDENTIFIED IN C.R.A. RECOMMENDATIONS.
  TECHNICAL ASSISTANCE TO BUSINESSES WILL HELP THEM PREPARE FOR BANK FINANCING AND LONG-TERM VIABILITY,
  THUS PROMOTING SUSTAINED ECONOMIC DEVELOPMENT. C.R.A. COULD DEVELOP MECHANISMS TO SUPPORT C.D.F.I.S
  AND OTHER COMMUNITY RESOURCES WHO PROVIDE BUSINESS T.A. THANK YOU FOR HOLDING THESE MEETINGS AND FOR ALLOWING ME
  TO COMMENT FROM MY PERSPECTIVE AS A C.D.F.I. SUPPORTING SMALL BUSINESS. I BELIEVE THAT THERE'S GREAT POTENTIAL
  FOR ENHANCING THE C.R.A. REGULATIONS TO PROVIDE SUSTAINED ECONOMIC DEVELOPMENT,
  AND I LOOK FORWARD TO THE DISCUSSION. THANK YOU.
  >> THANK YOU. MR. BARRAGAN. >> MY NAME IS ROBERTO MOHAMMED EL BARADEI.
  I'M PRESIDENT AND C.E.O. OF THE VALLEY ECONOMIC DEVELOPMENT CENTER.
  I APPRECIATE THIS OPPORTUNITY TO PROVIDE COMMENT ON STRENGTHENING AND MODERNIZING COMMUNITY INVESTMENT ACT.
  V.D.C. IS THE LARGEST SMALL BUSINESS DEVELOPMENT ORGANIZATION IN METROPOLITAN LOS ANGELES SERVING OVER 6,000 BUSINESSES ANNUALLY
  WITH DIRECT LENDING, TECHNICAL ASSISTANCE, TRAINING AND WORKSHOPS.
  V.D.C. IS A CERTIFIED COMMUNITY DEVELOPMENT FINANCE INSTITUTION WITH AN EXISTING $15 MILLION SMALL MICROBUSINESS LOAN PORTFOLIO
  AND RECENTLY SECURITY CAPITAL FROM THE CITY OF LOS ANGELES AND GOLDMAN SACHS TO SUPPORT ANOTHER $21 MILLION
  OF SMALL BUSINESS LENDING. V.D.C. IS A SMALL BUSINESS ADMINISTRATION MICROLENDER FOR OVER 12 YEARS
  AND OPERATES THE LARGEST ECONOMIC DEVELOPMENT REVOLVING LOAN FUND IN CALIFORNIA.
  WE'RE ALSO THE SPONSOR OF A CREDIT UNION WITH $2.4 MILLION IN ASSETS THAT RANKS
  IN THE TOP 75 OF SBA LENDERS HERE IN LOS ANGELES AND LASTLY WE'RE AN AFFILIATE
  THAT DOES S.B.A. 504 LENDING. OVER THE LAST 24 MONTHS, V.D.C. HAS BEEN AT THE EPICENTER
  OF THE WORST SMALL BUSINESS CREDIT CRISIS SINCE THE GREAT DEPRESSION. SBA LENDING HAS DROPPED 50%
  OVER THAT TIME AND LARGE NATIONAL COMMERCIAL BANKS THAT LED SMALL BUSINESS LENDING FOR LOANS BELOW
  $100,000 AND WHO SUFFERED MILLIONS IN LOSSES DUE TO STATE INCOME LOANS
  HAVE WALKED AWAY FROM THE MARKET LEAVING HUGE GAPS IN CREDIT AVAILABILITY.
  SMALL BUSINESS WATCHED AS HOME EQUITY LINES, CREDIT LINES AND LINES OF CREDIT THEY DEPENDED UPON WERE TERMINATED.
  HERE IN LOS ANGELES, REGIONAL BUSINESS BANKS, THOSE RESPONSIBLE FOR SUPPORTING SMALL AND MEDIUM BUSINESSES
  ARE FACING MILLIONS IN LOSSES DUE TO COMMERCIAL REAL ESTATE FAILURES.
  AFTER TWO YEARS OF RECESSION, START?UP CAPITAL IS NON?EXISTENT AND EXISTING SMALL BUSINESS LENDING
  BY NATIONAL BANKS IS LIMITED TO BUSINESS CREDIT CARDS AND LOANS ABOVE $200,000.
  WITH 60% OF CALIFORNIA BANKS UNDER SOME TYPE OF REGULATORY CONTROL, MANY BANKS CANNOT MAKE SMALL BUSINESS LOANS
  OR HAVE TO LIMIT THEM TO RELATIVELY RISK?FREE REAL ESTATE FINANCING AND 50% LOAN TO VALUE.
  JUST AS WE HAVE SEEN LONG?TERM UNEMPLOYED STOP LOOKING FOR JOBS,
  WE'VE ALSO NOW SEE SMALL BUSINESS STOP LOOKING FOR CAPITAL.
  AS EXISTING BUSINESSES COME OUT OF THE RECESSION IT SEEMS TO BECOME PART OF THE SPUTTERING RECOVERY,
  THEY'VE GIVEN UP LOOKING FOR CAPITAL, TIRED OF DENIALS, AND WHILE THEY HAVE REAL EXPANSION OPPORTUNITIES,
  RATHER THAN BORROW TO SUPPORT GROWTH, THEY GROW ORGANICALLY FROM PROFITS. SO RATHER THAN JOB CREATION,
  WE HAVE JOB CREATIONS IN THE ONES AND TWOS INSTEAD OF THE TENS AND HUNDREDS.
  LENDING IS DEPENDENT ON THOSE SAME BANKS OR SEEK TO HAVE BANKS BORROW FROM THEM
  AT LOW RATES, SEEMINGLY UNCONSCIOUS OF THE FACT THAT CAPITAL IS AT RISK IF LOANS ARE MADE.
  TO STRENGTHEN AND MODERNIZE C.R.A. TO THE BENEFIT OF SMALL BUSINESS, I WOULD ASK,
  ELIMINATE REGULATION B AND THE BANK'S ABILITY TO MEET C.R.A. SMALL BUSINESS LENDING BENCHMARKS THROUGH RESOLVING DEBT.
  LOANS BELOW $100,000 AND BUSINESSES WITH REVENUE BELOW $1 MILLION ARE NO LONGER ADEQUATE INDICATORS
  OF SMALL BUSINESS LENDING OR LENDING TO MINORITIES. DOCTORS, DENTIST, AND OTHER PROFESSIONALS WITH NET
  INCOMES MUCH GREATER THAN MOST SMALL BUSINESSS HAVE BENEFITED FROM THIS LOOPHOLE,
  NOT SMALL BUSINESS, WHICH WILL BE THE SOURCE OF JOBS TO COME.
  TRANSPARENCY SHOULD BE THE MINIMUM REQUIREMENT, NOT THE EXCEPTION. WE MUST ACCEPT THAT BANK BASED SOLUTIONS
  TO OUR SMALL BUSINESS CREDIT CRUNCH IGNORES THEIR OWN PLIGHT AND ENCOURAGES RHETORIC RATHER THAN ACTION.
  ACCORDINGLY, FEDERAL AS WELL AS BANK SUPPORT TO DIRECT LENDING MECHANISMS
  MUST RECEIVE CONTINUOUS AND HIGHER SUPPORT. IN ADDITION, THE REGULATORY AGENCY SHOULD WORK WITH THE C.D.F.I. FUND
  TO TARGET SUPPORT, NOT JUST TO NATIONAL INTERMEDIARIES BUT TO THE COMMUNITIES SUFFERING THE BRUNTD OF THIS
  CREDIT CRISIS SUCH AS CALIFORNIA, ARIZONA AND NEVADA. OVER THE LAST FIVE YEARS,
  95% OF C.D.F.I. HAS BEEN AWARD EAST OF THE MISSISSIPPI, BLIND TO THE GROWTH OF COMMUNITIES
  AND THE DOWNTREND THEY HAVE EXPERIENCED. BANKS SHOULD BE CHALLENGED TO MAKE REAL AND TRANSPARENT INVESTMENTS IN
  DISTRESSED COMMUNITIES AS OPPOSED TO CAPITULATEING TO C.R.A. EXTORTIONISTS AND FOR?PROFIT WOLF FUNDS
  MASQUERADING AS C.R.A. SHEEP SKIN. C.R.A. INVESTMENT, NON?PROFITS FOR REAL ESTATE ININVESTMENT CORPS TO GARNER
  INVESTMENTS THEY CAN'T RAISE OTHERWISE. THESE FOR?PROFITS SHOULD NOT WITH ALLOWABLE COMMUNITY INVESTMENTS.
  SHORT?TERM A RECENT PEPPERDINE STUDY HIGHLIGHTS MUCH OF WHAT I'VE SPOKEN TO TODAY,
  THE CURRENT ABILITY OF SMALL BUSINESS TO GROW AND HIRE AND OUR CURRENT INABILITY TO DO SO WITHOUT CAPITAL.
  WE'VE WAITED FOR RECOVERY TO COME. BY ALL INDICATIONS WE HAVE ANOTHER 12 TO 18 MONTHS
  BEFORE WE SEE SOME NEW NORMAL. WITH 14% UNEMPLOYMENT HERE IN L.A., WE CANNOT WAIT THAT LONG.
  WE NEED CAPITAL NOW. WE NEED SMALL BUSINESS GROWTH NOW AND WE NEED NEW JOBS NOW.
  THANK YOU FOR THE OPPORTUNITY TO PROVIDE TESTIMONY ON THE FUTURE AND IMPORTANCE OF THE C.R.A.
  >> THANK YOU. MR. WILLIAMS?
  >> GOOD AFTERNOON. MY NAME IS CLARENCE WILLIAMS,
  AND I AM PRESIDENT AND C.E.O. OF CALIFORNIA TAP CAPITAL FINANCIAL DEVELOPMENT CORPORATION.
  CALIFORNIA CAPITAL IS A NON?PROFIT C.D.F.I. ORGANIZATION LOCATED IN SACRAMENTO, CALIFORNIA.
  WE HAVE PROVIDED FINANCING, BUSINESS DEVELOPMENT TRAINING, FINANCIAL LITERACY, EDUCATION AND TECHNICAL ASSISTANCE
  FOR SMALL AND MICROENTERPRISE BUSINESSES SINCE 1983. WITH A 27?YEAR HISTORY OF AIDING UNDERSERVED COMMUNITIES,
  WE ENJOY AN EXEMPLARY REPUTATION THROUGHOUT NORTHERN CALIFORNIA AND THE CENTRAL VALLEY.
  HISTORICALLY THE COMMUNITY REINVESTMENT ACT HAS ATTEMPTED TO ADDRESS DISCRIMINATION IN LOANS MADE
  TO INDIVIDUALS AND BUSINESSES FROM LOW AND MODERATE?INCOME COMMUNITIES.
  TODAY I AM HERE TO ADVOCATE FOR THE IMMEDIATE PROMULGATION OF REGULATIONS,
  ADOPTING THE PROVISIONS OF THE DODD-FRANK BILL OF 2010 THAT REQUIRES LENDERS TO REPORT RACE
  AND GENDER, BORROWERS OF SMALL BUSINESS LOANS. THE CENSUS TRACK LOCATION OF THE BUSINESS, ACTION TAKE
  WITHIN RESPECT TO THE APPLICATION, APPROVED OR REJECTED, AND THE REVENUE OF THE BUSINESS.
  WITH FAST?GROWING MINORITY POPULATION THAT WILL APPROACH 50% OF THE NATION'S POPULATION BY 2050
  AND A HIGHLY COMPETITIVE GLOBAL MARKET, AMERICA'S COMPETITIVENESS WILL INCREASINGLY DEPEND ON THE INNOVATION
  AND STRENGTH OF MINORITY BUSINESS ENTERPRISES. IT IS IN THE BEST INTERESTS OF THE HEALTH OF OUR ECONOMY
  THAT REGULATORS REQUIRE FINANCIAL INSTITUTIONS TO COLLECT DATA THAT WILL TELL THE STORY OF LENDING ACTIVITY
  TO SMALL, MINORITY AND WOMEN?OWNED BUSINESSES. THIS WILL SERVE AS A CATALYST TO MITIGATE DISPARATE LENDING OUTCOMES
  TO THOSE BUSINESSES. AS AN EXAMPLE, WE KNOW THAT ENTREPRENEURS WHO USE CREDIT CARDS TO START
  AND ACQUIRE THEIR BUSINESSES MAY BE EXPOSED TO HIGHER OPERATING COSTS BECAUSE CREDIT CARDS TEND TO CHARGE
  ON AVERAGE HIGHER INTEREST RATES COMPARED TO OTHER SOURCES OF CAPITAL. FIRMS START IT BY USE CREDIT CARDS
  FOR CAPITAL ARE USUALLY AT A COST DISADVANTAGE COMPARED TO FIRMS STARTED WITH OTHER SOURCES OF CAPITAL.
  ACCORDINGLY, A NATIONAL STUDY COMPLETED IN 2007 BY THE INSIDE CENTER FOUND THAT ENTREPRENEURS OF COLOR
  ARE MORE LIKELY TO TURN TO CREDIT CARD DEBT AS A WAY TO START UP A BUSINESS,
  AN EXPENSIVE AND RISKY START?UP PROCEDURE. THEIR DATA SHOWS THAT 19% OF WHITE MALES
  RECEIVE BUSINESS LOANS FROM BANKS AS OPPOSED TO ONLY 9% HISPANIC AND AFRICAN AMERICAN BUSINESS OWNERS.
  FURTHERMORE, REGULATORY AGENCIES NEED TO COLLECT THE FOLLOWING DATA: LOANS LESS THAN $250,000
  AND BETWEEN $251,000 AND $500,000 TO BUSINESSES WITH REVENUES, $1 MILLION OR LESS ANNUALLY,
  LOANS THAT COMPARE OVERALL SMALL BUSINESS LENDING TO THE PROPORTION OF SMALL WOMEN?OWNED
  AND MINORITY?OWNED BUSINESSES IN LOW?INCOME NEIGHBORHOODS AS WELL AS THE OVERALL AMOUNT OF LENDING.
  THE ANNUAL PENCENTAGE RATE OF LOANS, IDENTIFICATION OF TERM LOANS, LINES OF CREDIT AS WELL AS INTEREST RATES.
  IT IS ALSO IMPORTANT TO EMPHASIZE THE ACCESS TO BUSINESS ADVISORY SERVICES, INCLUDING TECHNICAL ASSISTANCE
  AND FINANCIAL LITERACY EDUCATION FOR LOW AND MODERATE INCOME INDIVIDUALS AND BUSINESS OWNERS IS SEVERELY LACKING.
  SMALLER MICROENTERPRISE BUSINESSES HAVE AN ENHANCED OPPORTUNITY OF REALIZING SUCCESS AND SUSTAINABILITY
  IF THERE'S GREATER ACCESS TO THESE SERVICES. FINALLY, ATTENTION AND RESOURCES SHOULD BE
  DIRECTED TO THE NEEDS OF THE HIGH GROWTH IMMIGRANT REFUGEE AND LIMITED NON?ENGLISH PROEFFICIENT BUSINESS MARKET.
  THESE RECOMMENDATIONS THAT I HAVE SET FORTH TODAY ARE AN ATTEMPT TO CORRECT FOR PAST AND PRESENT DISCRIMINATION
  AND TO PREVENT SUCH FROM REOCCURRING IN THE FUTURE. THANK YOU FOR YOUR TIME AND CONSIDERATION.
  >> THANK YOU. MR. FISHER? >> THANK YOU. IT IS POSSIBLE TO BORROW SOME OF HIS TIME?
  >> NO. >> WE CAN NEGOTIATE THAT. >> GOOD AFTERNOON.
  THANK YOU FOR INVITING ME. I'M ALAN FISHER, EXECUTIVE DIRECTOR OF THE CALIFORNIA REINVESTMENT COALITION.
  C.R.C. IS A STATEWIDE MEMBERSHIP ORGANIZATION OF MORE THAN 280 NON?PROFITS, PUBLIC AGENCIES WORKING AROUND C.R.A.
  AND BANKING AND FINANCE ISSUES FOR MORE THAN A COUPLE DECADES. C.R.A. HAS REALLY OPENED
  THE DOOR FOR COMMUNITY ORGANIZATIONS. I THINK THAT'S ONE OF THE THINGS THAT
  REALLY NEEDS TO BE PUT OUT THERE.I MEAN, I HAVE FRIENDS, NOT CLOSE FRIENDS, BUT FRIENDS
  WHO WORK FOR BIG FUNDS, AND THEY CAN'T MEET WITH THE C.E.O. WE MEET WITH THE C.E.O.
  AND THAT'S SOMETHING THAT ONLY COULD HAVE HAPPENED WITH C.R.A. BUT AT THE SAME TIME,
  I REALLY WANT TO SPEAK TO THE FOUR OF YOU AND YOUR AGENCIES BECAUSE YOU LET US DOWN
  IN THE LAST FIVE OR TEN YEARS. YOU COULD HAVE STOPPED SOME OF THIS,
  WE ASKED YOU TO LOOK AT SUBSIDIARIES AND AFFILIATES. WE ASKED YOU LOOK AT SMALL BUSINESS,
  ALL OF THESE THINGS. WE REALLY NEED YOU TO BE REGULATORS,
  TO NOT LET THIS HAPPEN TO OUR COUNTRY AGAIN. SO I HOPE THAT YOU'LL HEAR THAT.
  I THINK THAT ONE OF THE THINGS THAT WE HOPE IS THAT YOU'LL REALLY LISTEN
  TO THE COMMUNITY MORE THAN YOU HAVE BEFORE. WE MAY BE BIASED IN THIS,
  BUT IT SEEMS LIKE THE BANKS SPOKE LOUDER THAN WE DID AT ANY OF THE AGENCIES.
  I THINK ONE PIECE OF THIS IS COMMUNITY CONTEXT JUST TO GIVE YOU AN EXAMPLE.
  WE MET ONCE IN WASHINGTON, D.C., WITH THE OCC, MAYBE 12 OR 15 LEADERS FROM CALIFORNIA,
  AND I JUST... WE WERE TALKING ABOUT COMMUNITY CONTACTS, AND I JUST HAPPENED TO ASK, UNREHEARSED,
  NO ONE IN THAT ROOM HAD, HAD A COMMUNITY CONTACT FROM ONE OF YOUR AGENCIES
  ASK ABOUT THE BANKS. AND THESE ARE LEADERS IN THE COMMUNITY. SO I REALLY HOPE THAT CAN CHANGE.
  I HOPE YOU'LL LISTEN TO THE COMMUNITY MORE. I HOPE WE CAN AVOID HAVING ANOTHER CRISIS LIKE THIS.
  THE... I'M GOING TO TRY NOT TO REPEAT THINGS THAT OTHERS HAVE SAID.
  MY COLLEAGUES ABOUT SMALL BUSINESS. BUT I THINK THERE ARE A COUPLE QUICK THINGS ON GEOGRAPHIC COVERAGE.
  ONE IS IF THERE IS A WEST BANK THAT HAS ONE BRANCH OR A FEW AND THAT LENDS ACROSS THE COUNTRY,
  THEY NEED TO BE RESPONSIBLE IN THE AREA WHERE THEY DO SIGNIFICANT LENDING.
  MY FAVORITE EXAMPLE OF THIS WAS COUNTRYWIDE BANK THAT IN MY NEIGHBORHOOD SAID COUNTRYWIDE BANK
  AND MORTGAGE AND YET THEY HAD NO RESPONSIBILITY FOR DEPOSITS THEY COLLECTED, NO RESPONSIBILITY IN SAN FRANCISCO,
  WHICH IS PROBABLY NOT AN UNDERSERVED COMMUNITY IN GREAT PART, BUT THE OTHER THING IS THAT NON?METROPOLITAN
  AND RURAL AREAS ARE TOO OFTEN OVERLOOKED. I MEAN, WHAT BANKS ARE TELLING COMMUNITY GROUPS
  IS THAT THESE AREAS ARE NOT IN THEIR "C.R.A. LENDING AREAS." AND I THINK YOU
  BEAR RESPONSIBILITY FOR THAT, AS WELL. NOT ALL OF IT, BUT YOU NEED TO NOT DO SAMPLING.
  YOU NEED TO LOOK AT RURAL AREAS. WHAT'S HAPPENING IS AREAS THAT ALREADY HAVE VERY LITTLE
  ARE BEING EVEN FURTHER LEFT ALONE. TO ME IF A BANK MAYBE IS TOO LARGE TO FULLY EVALUATE,
  MAYBE IT PRESENTS SYSTEMATIC RISK AND SHOULDN'T EXIST AT THAT SIZE. SO C.R.A. PERFORMANCE TESTS,
  C.R.A.'S GOAL IS EQUAL ACCESS. I THINK BANKS SHOULD BE EVALUATED. I DON'T KNOW HOW CLOSELY
  THEY APPROACH EQUALITY IN THEIR LENDING INVESTMENTS AND SERVICES. ARE THEY PROVIDING PRODUCTS THAT SERVE LOW?INCOME PEOPLE
  AND PEOPLE OF COLOR? TOO OFTEN WHAT WE SEE, AND MY STAFF TELLS ME THIS IS A DATED REFERENCE,
  BUT ARE ONE?SIZE?FITS?ALL THAT WOULD BE GREAT FOR OZZIE AND HARRIETTE.
  LOOKING AT THIS AUDIENCE, MAYBE PEOPLE DO KNOW OZZIE AND HARRIETTE, AND NOT FOR PEOPLE WITH LESS INCOME,
  NOT FOR PEOPLE WITH DIFFERENT CULTURES. SECONDLY, DOES A PROPORTION OF LENDING SERVICE INVESTMENTS
  MATCH THE PROPORTION OF THE POPULATION? I MEAN, I WOULD SAY IT NEVER DOES,
  BUT ARE THEY APPROACHING THAT? IS IT GETTING THERE? ARE THE BRANCHES MATCHING THE POPULATION
  BECAUSE MANAGERS OF BRANCHES GET JUDGED ON WHETHER THEY SERVE THEIR AREA.
  IF THERE IS NO BRANCH, THERE'S NOBODY WORRYING ABOUT THAT NEIGHBORHOOD.
  AND IT'S CLEAR FROM EVERY STUDY THAT COLOR PREJUDICE IS ALIVE AND WELL, AND C.R.A. EXAMINATIONS
  NEED TO HAVE A GREATER EVALUATION OF DISPARATE IMPACT. WE AGREE WITH A RECENT REPORT
  FROM THE CALIFORNIA SMALL BUSINESS TASKFORCE CONVENED BY THIS BANK IN ITS RECOMMENDATION
  THAT REQUIRING ANY ACQUIRER OF REGULATION...REGULATED FINANCIAL INSTITUTIONS TO AGREE TO HONOR ANY EXISTING
  PUBLICLY ANNOUNCED COMMUNITY REINVESTMENT AGREEMENT OR PLAN. WE THINK IT'S A GREAT DISSERVICE TO COMMUNITIES
  THAT ONE BANK AFTER ANOTHER HAS MERGED WITH NO PUBLIC COMMENT. WE NOW HAVE FOUR BANKS
  IN THE STATE OF CALIFORNIA THAT HAVE 60% OF THE DEPOSITS IN THE STATE OF CALIFORNIA.
  THAT MEANS THAT IT'S VERY DIFFICULT TO CONTROL THOSE BANKS. I WANT TO SUPPORT WHAT MY COLLEAGUES HERE SAID
  ABOUT DODD?FRANK. WE WISH YOU WOULD IMPLEMENT THOSE FEATURES IMMEDIATELY AND ABOUT ENTITY, BUSINESSES
  WITH LESS THAN $1 MILLION, THEY OUGHT TO BE LOOKED AT. WE HOPE THAT YOU WILL MAYBE
  USE THE COMMUNITY IN TERMS OF COMMUNITY DEVELOPMENT. WE SOMETIMES THINK THAT THE EXAMINERS REALLY DON'T UNDERSTAND THAT.
  MY FAVORITE EXAMPLE FROM A FEW YEARS BACK WAS AN EVALUATION WHERE THEY SAID
  THAT IT WAS OKAY. THE BRANCHES WERE CLOSED IN LOW?INCOME AREAS BECAUSE E.BANKING WAS BEING OFFERED
  SO JUST TO CLOSE, I THINK THERE NEEDS TO BE PUBLIC HEARINGS ON ANY MERGER, BUT ALSO I HOPE
  THAT IF THERE ARE SOME FOLKS WHO MAYBE DIDN'T MAKE IT IN FIVE DAYS AHEAD OF TIME
  IN THEIR REQUEST FOR PUBLIC COMMENT THAT THEY COULD BE ADDED.
  THE LAST TIME THIS HAPPENED IN THE '90S THERE WERE TWO DAYS AND IT WASN'T SO RUSHED.
  SO I APPRECIATE THIS. WE'RE LOOKING FORWARD TO CONTINUING DIALOG. THANK YOU.
  >> MS. VISSA. >> THE GREENLINING INSTITUTE THANKS THE FEDERAL AGENCIES FOR A TIMELY REVIEW OF C.R.A. AND FOR THE OPPORTUNITY TO
  CONTRIBUTE TO DISCUSSION OF SUCH AN IMPORTANT ISSUE. AS I SPEAK, WE'RE WITNESSING AN
  UNPRECEDENTED LOSS OF WEALTH IN COMMUNITIES OF COLOR ACROSS THE NATION.
  A LEADING REASON IS THE GROWING LOSS OF HOME EQUITY. WIDESPREAD FORECLOSURES
  HAVE DRAINED AN ESTIMATED 350 BILLION DOLLARS FROM COMMUNITIES OF COLOR.
  FOR EVERY 100 AFRICAN AMERICAN HOMEOWNERS, 11 HAVE EITHER LOST THEIR HOMES OR ARE AT RISK OF FORECLOSURE.
  FOR LATINO FAMILIES, THE FIGURES ARE WORST. IT COMES TO 17 OF EVERY 100 HOMEOWNERS.
  WHILE FORECLOSURES ARE A KEY PART OF THE PICTURE, THEY'RE NOT THE WHOLE PICTURE.
  BEYOND LOSING THEIR HOME, PEOPLE IN OUR COMMUNITYS HAVE BEEN THE LAST HIRED AND FIRST FIRED
  AND HAVE LOST A DISPROPORTIONATE NUMBER OF SMALL BUSINESSES.
  THIS HAS LED TO A GROWING RACIAL WEALTH GAP. FOR EVERY DOLLAR OF WEALTH OWNED
  BY A WHITE FAMILY, AN AFRICAN AMERICAN OR LATINO FAMILY OWNS JUST 16 CENTS.
  WE DON'T HAVE THE DATA FOR THE ASIAN AMERICAN COMMUNITY. THE MODERNIZATION
  AND ENHANCEMENT OF C.R.A. HAS THE POTENTIAL TO ADDRESS THESE INEQUALITY, YET AS IT'S WRITTEN TODAY,
  IT LACKS THE POWER TO TRULY DO SO. DESPITE THE STRENGTH OF C.R.A., WE KNOW IT CAN'T BE EFFECTIVE
  UNLESS IT IS EMBRACED AND PROMOTED BY REGULATORS AND FINANCIAL INSTITUTIONS.
  WE'RE THEREFORE PLEASED THAT FEDERAL REGULATORS HAVE PROACTIVELY SOUGHT INPUT TODAY THROUGH THESE HEARINGS.
  GIVEN THE MAGNITUDE OF THE CRISIS FACING COMMUNITY, GREENLINING RECOMMENDS THE FOLLOWING
  FOR IMMEDIATE IMPLEMENTATION: NUMBER ONE, IMMEDIATELY PLACE DIVERSITY FRONT AND CENTER IN THE APPLICATION OF C.R.A.
  FIRST AND FOREMOST, WE MUST EMBRACE THE FACT THAT DIVERSITY MATTERS. C.R.A. RATINGS MUST TAKE INTO ACCOUNT THE EXTENT
  TO WHICH A FINANCIAL INSTITUTION COMMITS TO DIVERSITY IN THE WORKPLACE AND AMONG EXECUTIVE MANAGEMENT.
  THE 2009 GREENLINING ANNUAL BOARD DIVERSITY REPORT SHOWS THAT IN CALIFORNIA PEOPLE OF COLOR REPRESENT 60% OF THE POPULATION,
  YET CORPORATE BOARD STRUCTURES ARE NOWHERE NEAR THAT LEVEL OF DIVERSITY.
  THIS IS DESPITE RESEARCH THAT SHOWS DIVERSE BOARDS PRODUCE HIGHER PERFORMANCE IN METRICS
  SUCH AS RETURN ON EQUITY, RETURN ON SALES AND RETURN ON INVESTED CAPITAL.
  UNLESS AND UNTIL BOARDS AND EXECUTIVE MANAGEMENT TEAMS REFLECT THE DIVERSITY OF CUSTOMERS THEY SERVE,
  WE CANNOT HAVE A SAFE AND SOUND BANKING SYSTEM. NUMBER TWO, IMMEDIATELY ADD SUPPLIER DIVERSITY
  TO THE C.R.A. EVALUATION PROCESS. THE RAPID HEMORRHAGING OF JOBS IN OUR COMMUNITIES CAN AT LEAST
  PARTIALLY BE ADDRESSED THROUGH BETTER ATTENTION TO THE NEEDS OF MINORITY?OWNED BUSINESSES.
  SMALL BUSINESSES ARE AMONG THE TOP JOB CREATORS IN LOW INCOME COMMUNITIES AND COMMUNITIES OF COLOR,
  BUT MANY SMALL OR MINORITY?OWNED BUSINESSES FACE DIFFICULTY ENACTING CONTRACTS TO GROW.
  AN INCREDIBLY SUCCESSFUL MODEL IN CALIFORNIA, GO156, HAS PLACED CALIFORNIA LIGHT YEARS AHEAD OF OTHER STATES
  IN MINORITY BUSINESS CONTRACTING. GO156 HAS MOVED THE SUPPLIER OF UTILITIES AS HIGH AS 30%
  WHILE THEY HOVER AROUND 5% IN OTHER STATES THROUGH SIMPLE GOAL SETTING AND TRANSPARENCY AND WITHOUT ANY QUOTAS.
  THIS MODEL SHOULD BE REPLICATED BY THE FINANCIAL REGULATORS. UNDER AN ENHANCED C.R.A.,
  BANKS SHOULD BE REQUIRED TO SUBMIT ANNUAL REPORTS AND TO PARTICIPATE IN AN ANNUAL HEARING
  TO DISCUSS THE REPORTS. NUMBER THREE, CREATE POSITIVE INCENTIVES FOR INNOVATION. THE CURRENT C.R.A. SYSTEM
  HAS NEVER FIGURED OUT HOW TO REWARD UNIQUE LEADERSHIP EFFORTS AS MENTIONED IN THE PREVIOUS PANEL.
  WE THEREFORE SEE SATISFACTORY RATINGS FOR OCCASIONALLY EXTRAORDINARY LEADERSHIP.
  OR OUTSTANDING RATINGS FOR MEDIOCRE EFFORTS. BANKS SHOULD BE ABLE TO RECEIVE C.R.A. CREDIT
  BY MEETING THE NEEDS OF COMMUNITIES THROUGH RESPONSIBLE INNOVATION. THE RETURN OF CONVENTIONAL LENDING PRODUCTS
  SHOULD NOT PRECLUDE CREATIVE, INNOVATIVE AND SAFE PRODUCTS THAT HAVE LESS CONVENTIONAL TERMS
  AND RESPONDS TO NEW TRENDS IN BUILDING COMMUNITY ECONOMIC STRENGTH. SUCH INNOVATION SHOULD BE HIGHLIGHTED AS BEST PRACTICES
  AND REWARDED WITH CREDIT UNDER A REVISED C.R.A. FOURTH AND FINALLY, MAKE C.R.A. MATTER AGAIN.
  THE WORLD HAS CHANGED SINCE 1977 AND ITS FAILURE TO KEEP UP HAS DIMINISHED ITS EFFECTIVENESS.
  WE CAN MAKE C.R.A. MATTER AGAIN. THE FINANCIAL SECTOR OF THAT ERA WOULD BE UNRECOGNIZABLE TODAY.
  AND MANY FINANCIAL SERVICES CRITICAL TO WEALTH CREATION ARE NOW PROVIDED BY INSTITUTIONS NOT COVERED BY C.R.A.
  A MODERNIZED C.R.A. MUST BE EXPANDED TO COVER THESE OTHER INDUSTRIES, INCLUDING INVESTMENT BANKS, INSURANCE,
  HEDGE FUNDS, PRIVATE EQUITY FIRMS AND, OF COURSE, ANY TROUBLED INSTITUTION THAT BENEFITS FROM FEDERAL INTERVENTION.
  FORMER CHAIRMAN GREENSPAN HIMSELF RECENTLY ACKNOWLEDGED THAT FEDERAL REGULATORS WERE NOT PROACTIVE ENOUGH IN PROTECTING CONSUMERS
  FROM FRAUDULENT PRACTICES BY THESE INDUSTRIES. GIVEN THIS PERSPECTIVE, WE URGE THE REGULATORS TO TAKE INITIATIVES
  TO EXPAND THE PURVIEW OF C.R.A. TO THESE INSTITUTIONS. ONCE AGAIN I THANK YOU
  FOR THE OPPORTUNITY TO SHARE GREENLININGS VIEWS AND I'M VERY GLAD I DIDN'T HEAR THAT DING.
  >> WELL, YOU SPOKE FAST ENOUGH. MS. LING.
  >> GOOD AFTERNOON. MY NAME IS JOAN LING, EXECUTIVE DIRECTOR, COMMUNITY CORPORATION OF SANTA MONICA
  I'M PRESENTING THIS TESTIMONY ON BEHALF OF SHARON LI OF THE LOW?INCOME HOUSING INSTITUTE
  IN SEATTLE, WASHINGTON. LIHI IS A NON PROFIT HOUSING ORGANIZATION. IT HAS DEVELOPED OVER
  3800 UNITS OF AFFORDABLE HOUSING IN SIX COUNTIES IN THE PUGET SOUND REGION FOR SUPPORTED HOUSING
  FOR HOMELESS TO CONDOMINIUMS FOR MODERATE INCOME FAMILIES, AS WELL AS IT ADVOCATES ON HOUSING POLICY,
  HOUSING PRESERVATION AND HOMELESS ISSUES. FOR OVER 15 YEARS IT COORDINATED THE ACTIVITIES OF
  THE WASHINGTON REINVESTMENT ALLIANCE TO ENSURE THAT C.R.A. COMMITMENTS ARE HONORED IN WASHINGTON STATE.
  MODERNIZING AND IMPROVING C.R.A. IS SORELY NEEDED. THE FEDERAL AGENCIES MUST REVAMP THE EVALUATION TOOLS
  TO CLEARLY QUANTIFY THE C.R.A. BENEFITS TO LOW AND MODERATE INCOME COMMUNITIES AND PEOPLE OF COLOR.
  THE SYSTEM IS FLAWED IF 99% OF THE BANKS PASS THEIR C.R.A. EXAM YET LOW AND MODERATE?INCOME CONSUMERS
  AND COMMUNITIES OF COLOR ARE NOT BEING ADEQUATELY SERVED. THIS IS EVIDENCE BY THE SUB?PRIME
  LOAN FORECLOSURE CRISIS, THE PROLIFERATION OF PAYDAY LOANS, AND THE LACK OF COMMUNITY DEVELOPMENT IN HOUSING.
  I WOULD LIKE TO ADDRESS FOUR ISSUES RELATED TO SMALL BUSINESS AND CONSUMER LENDING.
  IN THE STATE OF WASHINGTON IN 2008, THERE WERE 250,000 SMALL BUSINESS LOANS MADE WITH A DOLLAR AMOUNT
  OF 6.6 BILLION DOLLARS. THE BANKS NEED TO COLLECT INFORMATION SEPARATING OUT DOLLAR VOLUME
  AND NUMBER OF LOANS MADE TO MINORITIES AND WOMEN OWNED SMALL BUSINESSES AS WELL AS
  IDENTIFYING THOSE LOANS MADE IN DISTRESSED AREAS. NUMBER TWO BANKS SHOULD OFFER A RANGE
  OF CONSUMER LOAN PRODUCTS THAT SERVE LOW INCOME AND MODERATE INCOME BORROWERS.
  THE FEDERAL AGENCIES SHOULD ESTABLISH BENCH MARKS TO ASSESS THE QUANTITY, QUALITY, AND AFFORDABILITY
  OF THESE PRODUCTS AND INSURE THAT LOW COST BANKING ACCOUNTS, FINANCIAL EDUCATION AND SERVICES
  TO THE UN BANKED ARE OFFERED IN THE ASSESSMENT AREAS. NUMBER THREE TODAY PAY DAY
  LOAN OFFICES ARE PREVALENT IN THE LOW INCOME NEIGHBORHOODS AND THEY OUT PERFORM MAINSTREAM BANKS
  IN SERVING LOW INCOME FAMILIES AND INDIVIDUALS. THE FEDERAL AGENCIES MUST REQUIRE BANKS TO RECOMMIT
  AND EXPAND THEIR OPERATIONS INCLUDING LOCATING BRANCHES, ATMS, HOME MORTGAGE AND BUSINESS CENTERS IN LOW INCOME
  AND MINORITY COMMUNITIES. NUMBER FOUR IN THE STATE OF WASHINGTON AN INCREASING NUMBER OF LATINO FAMILIES
  WITH CHILDREN ARE LIVING IN MOBILE HOMES. THESE FAMILIES ARE IN NEED OF AN AFFORDABLE LOAN PRODUCT
  TO PURCHASE THEIR HOMES OTHERWISE BEING SUBJECT TO HIGH INTEREST RATES IN THE DOUBLE DIGITS.
  IN THE AREA OF DATA COLLECTION REPORTING DISCLOSURE AND PERFORMANCE EVALUATIONS WE HAVE THREE POINTS
  THAT WE WOULD LIKE TO MAKE. FIRST THE HMDA INFORMATION MUST PROVIDE INFORMATION ON THE QUANTITIES
  OF THE LOANS WITH REASONABLE TERMS TO MINORITY AND LOW INCOME HOUSEHOLDS.
  LIHI RECENTLY COMPLETED 48 TOWN HOMES FOR FIRST TIME BUYERS WITH MODEST MEANS IN THE SEATTLE AREA.
  SOME IMMIGRANT FAMILIES MANY WITH EXTENSIVE SAVINGS AND NO DEBT WERE PUT THROUGH THE WRINGER
  IN QUALIFYING FOR HOME LOANS BECAUSE THEY HAD NO CREDIT CARDS, NO CAR LOANS,
  PAID THEIR BILLS ON TIME AND THEREFORE HAD NO CREDIT RATING. THEY WERE INITIALLY REJECTED FOR LOANS.
  IT IS NOT ACCEPTABLE FOR MINORITY HOUSEHOLDS WITH ALTERNATE CREDIT TO BE TREATED THIS WAY.
  NUMBER TWO FINANCING OF AFFORDABLE MULTI FAMILY HOUSING SHOULD BE GIVEN AS MUCH
  IF NOT MORE WEIGHT THAN SINGLE FAMILY LOANS BECAUSE THE BULK OF LOW INCOME PEOPLE
  ARE SERVED BY RENTAL HOUSING. NON PROFIT DEVELOPERS IN THE PACIFIC NORTHWEST ARE IN PARTICULAR NEED
  FOR FIXED RATE LONG TERM DEBT. IN ADDITION WE ASK THAT LAND ACQUISITION LOANS,
  WORKING CAPITAL, AND EQ2 INVESTMENTS FOR AFFORDABLE HOUSING BE A REQUIREMENT IN ORDER TO ACHIEVE C.R.A. SATISFACTORY RATING.
  IN THE PROCESS OF ASSESSING A BANKS PERFORMANCE UNDER C.R.A. THE ASSESSMENT SHOULD BE OPEN
  TO COMMUNITY INPUT INCLUDING AN APPEAL PROCESS FOR THE COMMUNITY TO GO THROUGH AND THAT SUCH APPEALS
  SHOULD ALLOW FOR CONDITIONS TO BE REQUIRED OF THE BANK TO IMPROVE THEIR PERFORMANCE IN KEY AREAS
  OVER A LIMITED TIME FRAME. THANK YOU VERY MUCH FOR HEARING ME.
  >> THANK YOU. WE AGAIN HAVE LARGE PANEL, AND WE'RE GOING TO GO WITH AN
  EIGHT?MINUTE ROUND OF QUESTIONS. WE'LL START WITH MS. BRAUNSTEIN.
  >> THANK YOU. MY FIRST QUESTION, I WANTED TO ADDRESS FIRST OF ALL ALAN
  AND THEN IF ANYBODY ELSE WANTS TO COMMENT, FEEL FREE. IT'S KIND OF A TWO?PARTER.
  ALAN, IN YOUR TESTIMONY, YOUR WRITTEN TESTIMONY AND YOU MENTIONED IT BRIEFLY IN YOUR STATEMENT,
  YOU TALKED ABOUT THE ASSESSMENT AREA DEFINITION. AND YOU PUT FORWARD AN IDEA THAT'S BEEN
  PUT FORWARD IN OTHER C.R.A. HEARINGS WE'VE HAD PREVIOUSLY WHERE BANKS SHOULD BE RESPONSIBLE FOR AREAS
  WHERE THEY DO, AND I THINK YOU USED THE TERM "SIGNIFICANT" AMOUNT OF BUSINESS.
  I WAS WONDERING, THE FIRST PART IS COULD YOU PUT SOME KIND OF DEFINITION ON
  WHAT DO YOU MEAN BY SIGNIFICANT, HOW SHOULD WE DEFINE THAT IF WE WENT IN THAT DIRECTION.
  AND THEN THE SECOND PART IS DO YOU HAVE ANY CONCERN AT ALL OR ANYBODY UP THERE
  THAT IF WE WENT IN THAT DIRECTION THAT IT WOULD CAUSE BANKS TO PULL BACK
  FROM SOME AREAS WHERE THEY'RE CURRENTLY DOING BUSINESS BECAUSE THEY'RE GOING TO, YOU KNOW,
  IF THEY GET CLOSE TO THAT THRESHHOLD WHERE ALL OF A SUDDEN THEY'RE RESPONSIBLE FOR THE AREA,
  THEY MAY PULL BACK FROM THAT AREA ALTOGETHER BECAUSE THEY DON'T WANT THAT RESPONSIBILITY.
  IS THAT... ARE YOU CONCERNED ABOUT UNINTENDED CONSEQUENCES IN MOVING IN THAT DIRECTION FOR ASSESSMENT AREAS,
  AND WHAT DO YOU CONSIDER SIGNIFICANT? IT'S TWO PARTS. >> I MEAN, I THINK IT'S A VERY COMPLICATED QUESTION,
  AND I PUT SIGNIFICANT BECAUSE I DON'T KNOW THE ANSWER TO THAT.
  IT SEEMS LIKE WE NEED TO LOOK AT SOME EXAMPLES AND REALLY SEE, BUT IT SEEMS TO ME
  IT'S CLEAR ABOUT THE ONE BRANCH BANK OR THE INTERNET BANK. IT'S CLEAR TO ME...
  I WAS THINKING THE UNINTENDED CONSEQUENCES WAS DIFFERENT. MAYBE FOR A LARGE RETAIL BANK THERE WOULD BE UNINTENDED
  CONSEQUENCES BECAUSE THEY GAVE LESS WHERE THEIR BRANCH AREAS WERE AND GAVE MORE OUTSIDE.
  I THINK ALL OF THOSE THINGS ARE GOOD QUESTIONS THAT REALLY NEED TO BE EXAMINED
  AND BY LOOKING AT PRACTICAL EXAMPLES AND SEEING. I THINK IT IS CLEAR THAT BRANCHES
  ARE NOT THE PLACE THAT BANKING TAKES PLACE IN THE WAY IT DID IN '77.
  AND I THINK THE OTHER THING, WE'D REALLY LIKE TO BE PART OF A DISCUSSION
  THAT LOOKED AT EXAMPLINGS AND TRIED TO BE BETTER AT ASSESSING THAT.
  I'M SORRY FOR NOT A GOOD ANSWER. >> WELL, YOU KNOW, IT IS DIFFICULT QUESTIONS.
  I GUESS WE'RE ALL SMARTER. JUST KIDDING. >> WELL, I THINK THAT GOES WITHOUT SAYING.
  BUT I THINK WE NEED TO INVESTIGATE IT AND WE HAVEN'T AND REALLY WORK AT IT
  AND NOT THROW OUT SOME NUMBER BECAUSE I THINK THEY... THE END OF IT THAT DEALS WITH RETAIL BANKS
  LIKE YOU'RE SAYING, IT COULD HAVE UNINTENDED CONSEQUENCES IN A NUMBER OF WAYS.
  >> IF I MIGHT, JUST AS YEARS AGO BRANCHES AND DEPOSITS, WHEN YOU GARNERED THEM
  FOR WERE AN INDICATOR OF INVESTMENT IN THE COMMUNITY, AS ALAN HAS SAID,
  THAT'S COMPLETELY CHANGED WITH TECHNOLOGY. NOW IT'S MORE OF A QUESTION OF BUSINESS SERVICES
  AND LENDING BEING DONE IN A COMMUNITY. AND I THINK THAT ANY STATE WHERE BANK
  IS LENDING MORE THAN $10 MILLION SHOULD BE PART OF THE ASSESSMENT AREA.
  IN ADDITION TO THE SECOND QUESTION, THE FACT IS IF A BANK IS... IF A FINANCIAL
  INSTITUTION IS LENDING WITHIN AN AREA, WITHIN A COMMUNITY BECAUSE IT'S PROFITABLE, THEY'RE OUTSIDE
  OF MAYBE THEIR ASSESSMENT AREA BECAUSE IT IS PROFITABLE. THEY MIGHT BE ABLE TO DO
  A SAME BUILT OF BUSINESS. AS LONG AS IT IS PROFITABLE BUSINESS, BANKS ARE NOT GOING
  TO BACK AWAY FROM IT BECAUSE IT'S PART OF THEIR ASSESSMENT AREA.
  >> AND I THINK ALAN'S ANSWER AT THE END WAS QUITE APPROPRIATE. I DO THINK THIS LENDS
  ITSELF TO MORE DISCUSSION. I THINK INHERENT WITHIN YOUR RESPONSE IS THAT YOU RECOGNIZE
  THAT INSTITUTIONS WILL GAME THE SYSTEM NO MATTER WHERE YOU DRAW THAT LINE.
  AND TO THE EXTENT THAT CALIFORNIA REINVESTMENT COALITION AND OTHER ENTITIES RECOGNIZE GAMING THE SYSTEM
  WHEN ONE HAS ONE OFFICE IN ONE STATE AND ONE ASSESSMENT AREA AND SERVES
  THE REST OF THE COUNTRY TO, A CERTAIN EXTENT A CERTAIN AMOUNT OF GAMING
  IS GOING IN TERMS OF THE BUSINESS PLAN. TO THE EXTENT THAT THE REGULATORS,
  WE BELIEVE, SHOULD ALSO BE ABLE TO RECOGNIZE THIS. AND I THINK PEOPLE SITTING AROUND THE TABLE
  AND HONESTLY PURSUING THIS WOULD BE ABLE TO COME UP WITH SOME WAY TO BE ABLE
  TO ADDRESS I THINK THE CONCERNS THAT WE HAVE ABOUT BANKS BEING ABLE TO ESCAPE
  ANY TYPE OF ACCOUNTABILITY BY GAMING THE SYSTEM IN SUCH A BLATANT MANNER HAS BEEN DESCRIBED.
  >> I HEARD A COUPLE OF PEOPLE ON THIS PANEL, AND WE HEARD A NUMBER
  OF PERSONS ON PREVIOUS PANELS TALK ABOUT SOMETHING CALLED AN INNOVATIVE PRODUCT. I HAVE A VERY
  LIMITED PERIOD OF TIME. I'M GOING TO ASK EACH ONE OF DO YOU GIVE ME AN EXAMPLE IN
  YOUR OPINION OF AN INNOVATIVE PRODUCT AND THEN THE FOLLOW?UP QUESTION, AFTER YOU'VE ALL GONE THROUGH,
  IS GIVE US SOME SUGGESTIONS AS TO HOW WE AS REGULATORS CAN GREATER INCENTIVIZE,
  REGULATE THE OFFER THOSE KINDS OF PRODUCTS. I'LL START WITH YOU, MR. BARRAGAN.
  >> I THINK YOU CAN CHOOSE EQUITY INVESTMENTS. IT WAS AN INNOVATIVE PRODUCT. IT HAS
  BECOME LESS SO AS FEWER INSTITUTIONS ARE DOING THEM IN A WAY THAT PROVIDES FOR LESS STRAIN
  AND OBLIGATION ON THE NON?PROFIT ORGANIZATION. I'LL GIVE YOU AN EXAMPLE. U.S. BANK LAST YEAR
  IN THE MIDST OF THE CREDIT CRUNCH MADE $2 MILLION AVAILABLE TO US TO DO
  MICROLENDING THROUGHOUT SOUTHERN CALIFORNIA. >> TO SMALL BUSINESS? >> SMALL BUSINESS AND MICROBUSINESSES.
  AT THAT TIME BACK IN OCTOBER OF LAST YEAR, YOU REMEMBER, IT WAS... YOU COULD NOT FIND
  THOSE DOLLARS, PARTICULARLY TARGETED AS SMALL BUSINESSES. THE FACT IS IT WAS A VERY SHORT PROCESS.
  IT WAS A SUPPORTIVE INTEREST RATES AND RESPONSIBILITY AND ALLOWED US... TODAY WE HAVE LENT
  THE ENTIRE $2 MILLION OUT THE SMALL BUSINESSES THROUGHOUT THE TERRITORY. OVER TIME EQUITY?LIKE INVESTMENT
  HAS TAKEN ON DIFFERENT DEFINITIONS, BUT AT THE END OF THE DAY,
  WHAT IT SHOULD BE IS A LONG?TERM BELOW MARKET INTEREST RATE NON?RECOURSE LOAN
  TO A NON?PROFIT C.D.F.I. TO MAKE LOANS WHERE FINANCIAL INSTITUTION FOR WHATEVER REASON CANNOT MAKE THEM.
  >> MR. WILLIAMS? >> I THINK MY DEFINITION OF INNOVATIVE PRODUCT IS SOMETHING THAT IS VERY EFFECTIVE.
  I THINK ALL TOO OFTEN WE'RE LOOKING FOR BELLS AND WHISTLES.
  TO ME AS I BEGIN THE LOOK AT THE DATA AND THE NEEDS AND LOW INCOME COMMUNITIES
  IN ORDER TO ACCESS FINANCING, ACCESS CREDIT FROM FINANCIAL INSTITUTIONS, I FIND THAT ONE OF THE MAJOR IMPEDIMENTS
  GOING FORWARD ARE LOW CREDIT SCORES AND TERRIBLE CREDIT BEHAVIOR. IT WOULD SEEM TO ME
  THEN THAT THE ABILITY TO IMPLEMENT EFFECTIVE FINANCIAL EDUCATION, I WAS GLAD TO HEAR BANK OF AMERICA
  SAY THAT SENDING OUT LOAN OFFICERS OR SENDING OUT BANK PERSONNEL JUST TO SHOW UP
  TO VARIOUS CLASSES TO TALK ABOUT FINANCIAL EDUCATION IS NOT NECESSARILY AS EFFECTIVE AS IT IS
  WHEN THEY USE FINANCIAL INTERMEDIARIES IN THE COMMUNITY. TO THE EXTENT THAT WE WANT THE MAKE CAPITAL
  AVAILABLE IN LOW?INCOME COMMUNITIES, COMMUNITIES OF COLOR, UNLESS WE DEAL WITH THE ISSUES OF CREDIT BEHAVIOR
  AND CREDIT SCORES, WE'RE NOT GOING TO OVERCOME THOSE BARRIERS. THEREFORE SOMETHING AS SIMPLE
  AND EXECUTED WELL SUCH AS UNANIMOUS, EDUCATION COULD BE EXTREMELY INNOVATIVE WITHOUT NECESSARILY HAVING
  ALL THE BELLS AND WHISTLES THAT WE USUALLY COME TO DESCRIBE, COME TO SEE AS BEING INNOVATIVE.
  >> MR. FISHER? >> YES, THANK YOU. SO I THINK OF AN INNOVATIVE PRODUCT
  AS SOMETHING THAT BRINGS MORE PEOPLE INTO THE FINANCIAL MAINSTREAM. ONE EXAMPLE OF THAT,
  ONE CALIFORNIA BANK IN OAKLAND HAS AN ESSENTIAL BANK ACCOUNT. IT'S A CHECK LESS CHECKING ACCOUNT.
  YOU GET FREE MONEY ORDERS AND YOU HAVE A CARD THAT CAN BE USED
  AT POINT OF SALE AND A.T.M., SO IT'S VERY DIFFICULT TO OVERDRAFT. AND IT REPLACES
  AND COMPETES WITH THE CHECK CASHER. SO I THINK THAT IS A GOOD EXAMPLE.
  INCENTIVIZING, I'M A LITTLE UNCOMFORTABLE IN SOME WAYS WITH. THERE OUGHT TO BE SOME RECOGNITION,
  BUT MANY OF THE THINGS I THINK OF ARE THINGS THAT, YOU KNOW, SHOULD BE A MATTER OF COURSE AND NOT SEEN AS A HUGE CHANGE. >> I'M SUGGESTING INCENTIVIZING IN TERMS OF INCENTIVIZING INSTITUTIONS
  TO PERHAPS SPEND THE KIND OF TIME YOU HAVE IN COMING UP WITH THESE PRODUCT,
  IDENTIFYING THE COMMUNITY, IDENTIFYING THE PRODUCT, THE SERVICE, WHATEVER IT IS THEY WANT TO PROVIDE
  AND TO THEN CARRY IT OUT. THAT'S WHERE THE INCENTIVE COMES FROM. >> OKAY. >> ALL RIGHT. YES?
  >> I'VE GOT TWO POINTS. ONE IS A QUICK EXAMPLE OF MANY OF THE PARTNERS
  IN THE ROOM TODAY FROM THE FINANCIAL INSTITUTIONS CAN TELL YOU ABOUT LOAN PRODUCTS
  THEY HAD FOR HOME MORTGAGES PRIOR TO ABOUT TWO OR TREE YEARS AGO THAT WERE
  SPECIFICALLY TAILORED FOR LOW?INCOME FAMILIES WITH REDUCED DOWN PAYMENTS. ?KINDS OF THINGS MR. WILLIAMS
  IS REFERRING TO OR PERHAPS NOT AS FAR? >> PERHAPS EVEN FURTHER.
  I THINK THERE WERE QUITE A FEW THAT NO LONGER EXIST TODAY, BUT THE RECORD SHOWS
  THOSE HOMEOWNERS DID NOT DEFAULT AT HIGHER RATES THAN MOST OTHERS. SO IT WOULD BE A
  RETURN BACK THE REALLY FINDING A WAY TO MAKE SURE THOSE PEOPLE WHO ARE NOT
  ACCESSING PRODUCTS TODAY CAN ACCESS THEM. THE OTHER IS REALLY JUST
  MAKING SURE THAT YOU'RE AHEAD OF THE CURVE TODAY. WE KNOW THAT GREEN INVESTMENTS ARE SORT OF THE
  TOP OF EVERYBODY'S MIND, AND YET WE WANT TO MAKE SURE THAT WE'RE NOT COMING BACK TO
  THE TABLE FIVE YEARS FROM NOW AND SAYING SOMETHING ELSE IS WHAT... WHERE ALL OF THE
  MONEY AND INVESTMENT IS COMING IN. WE NEED TO REWRITE C.R.A. TO ALLOW FOR
  THAT ADAPTATION TO THE BANKS. >> THANK YOU. MS. WILLIAMS. >> I'M NOT SURE IF IT'S
  INNOVATIVE, BUT IT IS ASKING THE BANK TO TAKE A LEADERSHIP ROLE IN ADDRESSING THE BORROWING NEEDS
  OF NON?PROFITS HOUSING DEVELOPERS. I THINK BANKS COULD TAKE THE LEAD IN
  COORDINATING WITH FOUNDATIONS, DOING PROGRAM INVESTMENTS AND LOCAL CITIES
  TO PROVIDE ACQUISITION LOANS, WORKING CAPITALS AND OTHER RISKY LOAN INVESTMENTS UP
  FRONT TO COVER THE COST OF STARTING THESE PROJECTS. BECAUSE ONE OF THE MOST
  CHALLENGING ASPECTS OF TRYING TO GET THIS EARLY MONEY IS THAT THE BANKS ARE
  ONLY WILLING TO PUT IN 60%, MAYBE 70% AND THEN THE REST THE NON?PROFIT HAS TO COBBLE
  TOGETHER FROM OTHER SOURCES TO HAVE A ONE?STOP SHOP WHERE DIFFERENT
  PARTNERS COME IN TO COVER DIFFERENT TRENCHES OF RISKS WOULD BE A SERVICE THAT IS MUCH NEEDED.
  >> MS. PRINSTER? >> I DID MENTION ONE THING IN MY TESTIMONY, BUT BEFORE I GO TO
  THAT, I'D LIKE TO JUST PIGGY BACK ON WHAT ROW PERIDOT WAS ?? ROBERTO WAS SAYING ABOUT EQ2S.
  THE TWO ARE RELATED. ONE OF ISSUES I THINK HAS SEEMED UNFAIR TO ME IS THE
  EXPECTATION THAT, AND IT'S A REASONABLE EXPECTATION THAT THOSE EQ2S THAT THOSE BANKS
  WOULD ALWAYS BE WHOLE, YET THEIR ASSETS BY VIRTUE OF THE RELATIONSHIP, WE'RE BEING
  ASKED TO MAKE LOANS THAT ARE MORE RISKY THAN BANK WOULD MAKE. AND SO THERE NEEDS TO
  BE SOME RECOGNITION THAT AT SOME POINT THERE WOULD BE SOME EITHER SHARING OR
  WRITEDOWN OF THOSE EQ2S THAT WOULD BE ACCEPTABLE AND THAT WOULDN'T PREVENT US FROM...
  WELL, PREVENT THE BANK FROM HAVING ANY KIND OF CRITICISM OR US FROM EVER EVEN HAVING A
  HOPE OF GETTING ANOTHER ONE IN THE FUTURE. SO THE WHOLE ISSUE OF LOAN
  LOSSES IS A CONCERN FOR A NON?PROFIT. YOU MENTIONED COBBLING TOGETHER THE RESOURCES.
  HERE WE ARE ASKING TO... HAVING TO GO OUT AND TRY TO RAISE CONTRIBUTIONS FOR EQUITY TO
  COVER LOAN LOSSES. WHO WANTS TO GIVE MONEY FOR THAT. THE OTHER... THE PROGRAM
  THAT WE HAVE IN COLORADO HAS INCLUDED C.D.F.I.S AS PART OF THIS LOAN RESERVE PROGRAM,
  COLORADO CREDIT RESERVE, AND AS WE LOOK FORWARD AND PROJECT IN THE FUTURE IN HOW
  IT'S GOING TO HELP US TO BE A MORE FINANCIALLY SUSTAINABLE ORGANIZATION FOR THE LONG
  TERM BY HELPING US TO COVER THE LOSSES, IT SEEMS TO BE A GREAT PROGRAM.
  IT'S REALLY DONE A LOT TO LEVERAGE RESOURCES. WE HAVE TO STILL BE RESPONSIBLE
  BECAUSE WE DON'T WANT TO USE UP OUR WHOLE RESERVE ON A FEW LOANS,
  AND IT SEEMS LIKE A GREAT THING THAT PUTTING TOGETHER A VARIETY OF RESOURCES TO BUILD
  UP THESE RESERVE POOLS WOULD HELP C.D.F.I.S A GREATLY. >> JUST A SECOND. >> THANK YOU, JOHN.
  I'D LIKE TO ASK ABOUT THE PANEL'S VIEWS ON C.R.A. PERFORMANCE RATINGS AND INCENTIVES.
  MS. LING, IN YOUR WRITTEN TESTIMONY, YOU RECOMMENDED MORE GRADES AND I THINK YOU
  SPECIFIED AN OUTSTANDING PLUS RATING. I WAS WONDERING IF YOU COULD ELABORATE ON THAT AND
  ANY OTHER IDEAS YOU MAY HAVE IN ADJUSTING OUR RATING SYSTEM AND AS PART OF YOUR
  RESPONSE TO WHAT EXTENT, AND THIS PICKS OFF OF WHAT DIRECTOR BOWMAN WAS TALKING
  ABOUT WHAT ARE THE APPROPRIATE INCENTIVES THAT WE CAN USE THROUGH THE
  RATINGS SYSTEM TO ENCOURAGE LENDING AND OTHER COMMITMENTS BY BANKS?
  >> WELL, I THINK THAT SHARON LI AND THE LOW?INCOME HOUSING INSTITUTE IN WASHINGTON
  WOULD LIKE TO SEE MORE WEIGHT BE GIVEN TO MULTIFAMILY HOUSING LENDING OVER SINGLE
  FAMILY LOANS, SO THAT'S ONE AREA THAT PACIFIC NORTHWEST IS LOOKING TO WAIVE THE
  PERFORMANCE DIFFERENTLY. THAT'S IT. >> THANK YOU. MS. VISSA. >> I THINK PART OF THE CONCERN
  COMES FROM THE FACT AS COMMUNITY ADVOCATES IN THIS COMMUNITY, 99% OF ALL BANKING INSTITUTIONS PASSING THEIR EXAM,
  IT'S HARD FOR US TO DIFFERENTIATE BETWEEN GOOD, BETTER AND BEST, AND I THINK
  THAT'S WHERE THE OUTSTANDING PLUS RATING COMES INTO PLAY. IT DIFFERENTIATES BETWEEN
  THOSE EXTRAORDINARY EFFORTS THAT HAVE BEEN TAKEN AND JUST MEETING THE BAR.
  WE WOULD RECOMMEND THAT THERE ACTUALLY BE A SORT OF LIKE A CURVE IN SCHOOL WHERE
  ONLY THAT TOP FIVE OR TOP 10% CAN RECEIVE AN OUTSTANDING PLUS,
  AND THEN THERE TENDS TO BE MORE OF A COLLABORATION AND/OR COMPETITION AMONG THE FIELD, AS WELL.
  I THINK A LOT OF THE DISCUSSION IN THE EARLIER PANEL ABOUT THE COMMUNITY DEVELOPMENT TEST
  COMES INTO PLAY HERE WHEN WE TALK ABOUT INCENTIVES. REALLY ALLOWING FOR THOSE
  OPPORTUNITIES FOR NEW WAYS TO MEET COMMUNITY NEEDS TO GET TO THAT NEXT LEVEL,
  AND I THINK ONE ASPECT THAT CANNOT BE FORGOTTEN IS WHAT ALAN MENTIONED,
  WHICH IS THE COMMUNITY ITSELF AND THEIR VOICE. TRYING TO FIND A WAY TO HAVE
  THEIR ASSESSMENT BE PART OF THE PROGRAM. >> THANK YOU. MR. FISHER? >> THOSE ARE GREAT QUESTIONS.
  YOU KNOW, WE USED TO HAVE A SECTION OF OUR NEWSLETTER, THE BAD DOG SECTION,
  WHERE ANYONE THAT GOT LESS THAN A SATISFACTORY WAS IN THERE, AND WE FOUND...
  THERE HAS BEEN NO ONE IN CALIFORNIA FOR YEARS. I THINK WE'VE HAD A LOT OF CONVERSATIONS
  WITH SOME OF YOU ABOUT GRADE INFLATION, AND SO I DO THINK THAT MAYBE ONE POSSIBLE
  THING JUST TO ADD, I'VE ALWAYS LIKED THE IDEA OF A CURVE AFTER NOT LIKING IT TOO MUCH.
  TO BRING COMMUNITY DEVELOPMENT UP TO A HIGHER LEVEL, NOT AS SORT OF EXTRA CREDIT,
  BUT AS AN INTIMATE PART OF WHAT HAPPENED, SO I WOULD THINK THAT.
  AND I GO BACK AND FORTH ON THE ISSUE OF INCENTIVES BECAUSE CERTAINLY INCENTIVES HELP,
  BUT THIS IS SUPPOSED TO BE THE BUSINESS. BUT MAYBE THERE ARE AWARDS OR SOMETHING LIKE
  THAT THAT RECOGNIZE WITHOUT BEING MORE THAN THAT, AND I DO THINK THAT BANKS OF A CERTAIN
  SIZE SHOULD BE EXPECTED TO GET AN OUTSTANDING, YOU KNOW, THAT IF THEY DON'T THERE OUGHT
  TO BE SOME NEGATIVE ASPECT TO IT BECAUSE THEY SHOULD BE ABLE TO. >> THANK YOU. >> MR. WILLIAMS.
  >> YEAH, I THINK THIS QUESTION SOMEWHAT OVERLAPS WITH THE DISCUSSION THIS MORNING.
  I THINK AN AREA OF EVALUATING BANKS OUGHT TO BE HOW WELL THEY PLAY TOGETHER
  IN REGARD TO THE C.R.A. ALL TOO OFTEN THE ISSUE OF BANKS UNABLE TO COME TOGETHER
  TO WORK ON COMMUNITY?BASED NEEDS, PLACE?BASED NEEDS AS IDENTIFIED UNDER THE PERFORMANCE CONTEXT
  IS HURTING A LOT OF NON?PROFITS IN THE WORK THAT WE DO.
  ALL TOO OFTEN A BANK IS ONLY INTERESTED IF THEY ARE THERE, THEY HAVE THEIR NAME
  ON THIS PROJECT, THEY GET TO BRAND IT, THEY GET THE CREDIT, THEY'RE THE LEAD.
  WHEREAS WE'RE LIKELY TO GET BETTER RESULTS IF WE COULD FIND THEM WORKING IN A
  COLLABORATIVE MANNER. NOW, THE ONLY WAY THAT'S GOING TO HAPPEN IS YOU'RE
  GOING TO HAVE TO GIVE THEM CREDIT AND YOU'RE GOING TO HAVE TO INCENTIVIZE THEM IN
  WORKING TOGETHER IN AN ENVIRONMENT OTHER THAN JUST MULTIBANK C.D.C.S.
  SO TO THE EXTENT THAT YOU CAN BRING MORE RESOURCES TOGETHER WORKING ON SOME OF
  THESE PROBLEMS WHERE IT'S NOT NECESSARILY LOOKED AT AS BEING COMPETITIVE OR PROPRIETARY,
  I THINK THE COMMUNITIES WILL BE... THEY WILL BENEFIT FAR MORE. >> THANK YOU.
  >> MR. BARRAGAN. ACTUALLY, I HAVE A UNIQUE POSITION HERE. I SERVE ON THE BANK,
  ON A COMMUNITY BANK BOARD OF DIRECTORS ABOUT A $500 MILLION BANK LOCATED IN ENCINO
  THAT WENT TO THE C.R.A. EXAM WITH THE F.D.I.C. I ALSO SERVE AS THE CHAIRMAN
  OF THE C.R.A. COMMITTEE. SO I HAVE A VERY UNIQUE POSITION LOOKING AT HOW YOU EVALUATE US.
  THIS IS A BANK THAT DID RECEIVE AN OUTSTANDING RATING. IT COMMITS 10% OF NET INCOME
  TO CHARITABLE CONTRIBUTIONS. IT PROVIDES SIGNIFICANT SMALL BUSINESS LENDING.
  IT MAKES INVESTMENTS TO LOW?INCOME CREDIT UNIONS AND IN MINORITY?OWNED BANKS.
  IT HAS SIGNIFICANT PARTICIPATION IN GOVERNMENT LENDING PROGRAMS AND IT
  RELIES LITTLE ON MORTGAGE?BACKED SECURITIES AND TAX CREDITS FOR C.R.A. CREDIT.
  THAT I THINK IS AN OUTSTANDING RATING. I DON'T SEE THAT WITH MANY BANKS. >> MS. PRINSTER.
  >> BEING THE LAST IN LINE AGAIN, WHICH IS GREAT, I LIKE THAT, I GUESS WHAT I WAS JUST KIND OF
  TAKING SOME NOTES HERE, AND I CAME UP WITH FOUR ITEMS FROM THE PREVIOUS COMMENTERS TO
  START WITH, SO MAYBE THIS WILL JUST SUMMARIZE THE COMMENTS HERE.
  COMMUNITY DEVELOPMENT TEST I THINK IS A GREAT IDEA. CONVERSATION WITH THE COMMUNITY,
  HAVING THAT DISCUSSION IN AN OPEN AND TRANSPARENT WAY WHEN THERE ARE EXAMS WITH
  COMMUNITY STAKEHOLDERS, COLLABORATION WITH EACH OTHER IS A GREAT PRINCIPLE TO
  TRY TO EVOKE AS PART OF THE PROCESS, AND I LIKE THE IDEA OF CONTRIBUTIONS, JUST THE 10%
  OR WHATEVER PERCENTAGE, SOME KIND OF PERCENTAGE OF PROFITS CONTRIBUTING
  TO THINGS THAT WILL HELP COMMUNITY DEVELOPMENT, SUCH AS THE TECHNICAL ASSISTANCE
  THAT WE'VE BEEN TALKING ABOUT AND OTHER TYPES OF SERVICES THAT C.D.F.I.S, FOR EXAMPLE,
  BUT OTHER COMMUNITY RESOURCES AND NON?PROFITS COULD ALSO CONTRIBUTE TO
  BUILDING UP CAPACITY IN LOW AND MODERATE?INCOME NEIGHBORHOODS AND POPULATIONS.
  >> THANK YOU VERY MUCH. I'D LIKE THE RETURN TO A QUESTION THAT I ASKED THE LAST
  PANEL BECAUSE I THINK IT'S GOING TO GIVE A LITTLE DIFFERENT FLAVOR IN THE
  COMMENTS A NUMBER OF YOU HAVE MADE, AND THAT WAS THAT IN THE LAST DISCUSSION WE HAD
  IN THINKING ABOUT THINGS LIKE SMALL BUSINESS LENDING OR FORECLOSURE PREVENTION
  AND NEIGHBORHOOD STABILIZATION, THERE IS A IT SEEMS TO ME A CERTAIN TENDENCY IN THINKING
  HOW TO DEAL WITH THOSE ISSUES, ESPECIALLY IN THE CURRENT ECONOMIC CLIMATE
  TO KIND OF BROADEN THE BASE, TO THINK ABOUT DOING MORE THINGS IN SMALL BUSINESS
  THAN PERHAPS LOOSEN LINKS TO A NARROW DEFINITION OF LOW AND MODERATE INCOME
  WHEREAS A NUMBER OF YOUR COMMENTS WERE RATHER SPECIFIC FOCUSED NOT JUST ON L.M.I. COMMUNITIES
  BUT ON MINORITY COMMUNITIES AND THAT SORT OF THING. IT SEEMS TO ME THAT THOSE ARE
  KIND OF TENSIONS PULLING IN OPPOSITE DIRECTIONS, BUT I JUST WONDER IF YOU SEE A REAL
  TENSION THERE OR WHETHER THOSE ARE KIND OF RECONCILABLE THOUGHTS.
  >> WE DISCUSSED THE TENSION IN CERTAIN GROUPS. I THINK TO THE EXTENT YOU
  START MOVING THE C.R.A. INTO OUTSIDE OF THE L.M.I. COMMUNITIES, THERE ARE GOING
  TO BE ISSUES. IT WOULD BE SOMEWHAT FACETIOUS. SOME OF THE COMMENTS WERE
  THOSE ISSUES NOW BEING BROUGHT UPON THE MIDDLE AND UPPER?INCOME FOLKS ARE
  ISSUES THAT DIRECTEDLY RELATED TO BEHAVIOR BY THE BANKS THEMSELVES,
  AND THEREFORE NOW TO GO OUT TO SOLVE THOSE AND THEY GET CREDIT FOR THEM,
  YOU SEE IT'S SORT OF A CIRCLE OF LOGIC HERE THAT'S NOT QUITE UNDERSTANDABLE.
  I THINK THAT NOTWITHSTANDING THE FACT THAT THE COMMUNITY REINVESTMENT ACT DOES NOT
  NECESSARILY SPEAK TO RACE, ANYONE WHO STUDIES THE HISTORY OF REDLINING THE
  COMMUNITY REINVESTMENT ACT KNOWS THAT THE SILENCE IN REGARDS TO RACE WAS NOT THE
  FAULT OF THOSE FOLKS WHO WERE ADVOCATING FOR C.R.A. IT WAS THE BANKING COMMUNITY
  THAT WANTED TO KEEP IT OUT. THAT BEING SAID, WE KNOW TO THE EXTENT THAT WE FIND LOW
  INCOME, HIGH UNEMPLOYMENT, ALL THE INDICATORS WE'RE GOING TO FIND PEOPLE OF COLOR.
  THEREFORE UNLESS AND UNTIL AND WHEN WE LOOK AT THE DEMOGRAPHICS IN TERMS OF THE
  GROWTH IN THIS COUNTRY, THE FUTURE OF THE LABOR FORCE, THESE ARE THE ISSUES THAT
  WE'RE FACING. THE FUTURE OF THIS COUNTRY IS GOING TO DEPEND UPON THE
  GROWTH IN HISPANIC, SOUTHEAST ASIAN AND AFRICAN AMERICAN COMMUNITIES.
  WHITE POPULATION IS DECREASING. WE ALL KNOW THIS. WHO IS GOING TO SUPPORT SOCIAL SECURITY?
  WHO ARE GOING TO FILL THOSE JOBS OUT THERE NECESSARY? WE KNOW THAT THEY CAN ONLY
  BE FILLED FROM THOSE POPULATIONS. THOSE POPULATIONS ARE SUFFERING FROM HIGHER DROP?OUT RATES,
  EDUCATION, LACK OF ACCESS TO CAPITAL AND WHAT HAVE YOU. SO IT WOULD SEEM TO ME AS A
  PRIORITY LOOKING AT THE SCARCE RESOURCES THAT WE'RE ADDRESSING THAT WE MUST STAY
  CONCENTRATED AND WE MUST STAY FOCUSED, AND IF THAT FOCUS IS ON LOW AND MODERATE
  ?INCOME COMMUNITIES AT THIS POINT IN TIME AND IF THAT'S THE BACK DOOR THAT I GET INTO
  THOSE POPULATIONS, THEN SO BE IT. BECAUSE I DON'T THINK THAT I'M GOING TO BE ABLE TO GO TO
  CONGRESS AND GET THEM TO OPEN THIS UP ON THE BASIS OF RACE. SO THE WAY I LOOK AT THIS,
  YES, THERE WILL BE SOME TENSION AS WE TRY THE MOVE THE C.R.A. BEYOND
  THE TARGETED LOW AND MODERATE INCOME COMMUNITIES. >> I WOULD TRADE REG B FOR L.M.I.
  IF WE COULD DETERMINE WHAT BUSINESSES AND WHAT COMMUNITIES RECEIVED LOANS
  AND THAT BECAME THE STANDARD. THE FACT IS OUR WORKFORCE IS A VERY DIVERSE WORKFORCE.
  THE BUSINESSES THAT I WORK WITH, I DON'T BRING THEM IN BECAUSE THEY'RE L.M.I.,
  I BRING THEM BECAUSE THEY'RE BUSINESS. I DO FIND OUT AFTERWARDS THAT THE MAJORITY
  OF THE PEOPLE BEING HIRED ARE L.M.I. AT THE END OF THE DAY IT'S ABOUT JOBS.
  >> I THINK WHEN... I'M SORRY. I THINK WHEN IT COMES TO SMALL BUSINESS LENDING, THERE DOES
  NEED TO BE A RECOGNITION THAT SMALL BUSINESSES ARE NOT NECESSARILY PLACE?BASED IN
  TERMS OF THE L.M.I. CHARACTERISTICS. I THINK THAT AS ROBERTO WAS TALKING, I THINK WE ALSO LOOK
  AT WHOEVER IS LACKING ACCESS TO CAPITAL AND WE FIND OUT LATER WHAT THEIR PROFILE
  LOOKS LIKE, AND THERE'S NO QUESTION THAT LOW INCOME AND MODERATE INCOME NEIGHBORHOODS
  AND COMMUNITIES NEED TO HAVE VIABLE SMALL BUSINESSES, BUT WHEN IT RELATES TO L.M.I.
  INDIVIDUALS WHO ARE BUSINESS OWNERS, THEY DON'T NECESSARILY... THE BEST PLACE
  FOR THEIR BUSINESS IS NOT NECESSARILY IN THAT COMMUNITY OR THAT NEIGHBORHOOD.
  SO TO THE EXTENT THAT YOU WANT TO BE ABLE TO BUILD WEALTH AMONG THOSE
  INDIVIDUALS, THEY HAVE TO GO WHERE THE BUSINESS CONCEPT IS GOING TO BE MOST VIABLE.
  ON THE OTHER HAND, IT GOES THE OTHER WAY, MAYBE A MIDDLE INCOME OR EVEN A HIGHER
  INCOME PERSON WHO MIGHT BE STARTING A BUSINESS THAT WOULD BE HIRING INDIVIDUALS
  FROM THOSE POPULATIONS, THEY THEMSELVES WOULD NOT NECESSARILY BE L.M.I.,
  NOR WOULD THERE BUSINESS BE OF A CERTAIN SIZE THAT WOULD QUALIFY FOR C.R.A.
  AND YET THEY WOULD HAVE A LARGE IMPACT ON THE COMMUNITY.
  THAT'S WHY I FEEL LIKE THE SMALL BUSINESS IS REALLY A LITTLE BIT DIFFERENT... NEEDS TO BE
  LOOKED AT DIFFERENTLY IN TERMS OF THE OVERSIGHT AND INCENTIVES TO BE ABLE TO SEE
  HOW IT IMPACTS THE COMMUNITY. >> I'M NOT PREPARED TO REPRESENT THE LOW?INCOME
  HOUSING'S POINT OF VIEW ON THIS MATTERED, BUT PERSONALLY I FEEL THE DISTINCTION BETWEEN
  LOW INCOME AND COMMUNITY OF COLOR IS FALSE ONE, AND I TEND TO AGREE WITH MR. WILLIAMS
  POINT OF VIEW THAT LET'S FOCUS ON LOW AND MODERATE INCOME COMMUNITY AND ADDRESS THE
  SOCIAL EQUITY ISSUES THAT THESE COMMUNITIES ARE SEEKING TO REDRESS.
  >> I AGREE WITH ALL OF MY COLLEAGUES HERE ON THE PANEL THAT THERE MUST BE A FOCUS ON
  THE L.M.I. COMMUNITIES, BUT I THINK WE'LL DO A DISSERVICE IF WE ARE RACE NEUTRAL.
  RESEARCH IS SHOWN THAT PEOPLE WITH FICO SCORES OF 720 AND ABOVE ARE SOLD PREDATORY LOANS.
  IF WE DON'T TAKE THAT INTO ACCOUNT, I THINK WE'LL END UP IN THE SAME PLACE AGAIN.
  >> I WOULD AGREE WITH WHAT MY COLLEAGUES HERE ARE SAYING. I THINK IT HAS TO BE A MIX OF
  BOTH OF THESE THINGS. IT'S CLEAR THAT THERE'S COLOR DISCRIMINATION.
  I MEAN IN ALL THE STUDIES THAT WE'VE DONE, THE RECENT STUDY WE DID LOOKING AT BOTH LOAN
  MODIFICATION AND MORTGAGE LENDING AREAS WHERE PEOPLE OF COLOR LIVED WERE DISADVANTAGED.
  AND IN A STUDY WE DID A FEW YEARS AGO, MIDDLE?INCOME AFRICAN AMERICANS HAD A
  HARDER TIME GETTING A MORTGAGE LOAN THAN LOW?INCOME ANGLO?S. I THINK WE NEED THE LOOK AT
  THOSE TYPES OF THINGS. I THINK WE NEED MORE DATA IN TERMS OF BREAKING OUT,
  PARTICULARLY ASIAN AMERICANS, A.P.I., BUT I THINK THIS HAS TO BE LOOKED AT OTHERWISE WE DON'T GET THE WHOLE PICTURE.
  >> THANK YOU. DO OTHERS HAVE FOLLOW?UP QUESTIONS? WE HAVE A LITTLE MORE TIME.
  >> I'LL ASK ONE. THIS IS... WE HAD SOME DISCUSSION ABOUT THIS EARLIER
  TODAY, AND I WANTED TO GET AN OPINION FROM PEOPLE ON THIS PANEL. THE NEEDS ASSESSMENT
  THAT'S DONE AS PART OF C.R.A. REQUIREMENTS, YOU KNOW, CURRENTLY THE RESPONSIBILITY
  IS ON THE BANKS TO DO THAT, AND THERE'S BEEN A LOT OF DISCUSSION ABOUT THIS AT
  PREVIOUS HEARINGS, AND SOME HAVE SAID THAT THEY THINK THE REGULATORS SHOULD BE MORE
  ACTIVELY PARTICIPATING IN DOING NEEDS ASSESSMENTS. IT'S NOT DOING IT ALTOGETHER.
  AND WE HAD SOME DISCUSSION ABOUT THIS ON ONE OF THE PANELS. IT WAS KIND OF SPLIT.
  SOME OF IT WAS THE REGULATORS HAVE MORE DATA THEY WOULD BE ABLE TO DO IT
  BETTER, BUT THEN THERE WERE SOME CONCERNS ABOUT THAT MIGHT INTERFERE WITH
  WHATEVER CONVERSATIONS CURRENTLY GO ON BETWEEN THE BANKS AND THE COMMUNITY GROUPS.
  THAT WOULD KIND OF LET THEM OFF THE HOOK. I WAS JUST WONDERING WHAT YOUR, YOU KNOW,
  WHAT'S THIS PANEL'S TAKE AS COMMUNITY FOLKS ON THE WHOLE QUESTION OF WHO
  SHOULD BE DOING THE NEEDS ASSESSMENTS? >> I FEEL STRONGLY THAT I THINK
  IF THE BANKS DO NOT KNOW THEIR COMMUNITIES, THEY SHOULD BE PUNISHED IN TERMS OF THEIR RATINGS.
  I DON'T KNOW HOW YOU GET AROUND THIS, BUT PERFORMANCE CONTEXT IS A PLACE?BASED
  AND EVEN REGION?BASED KIND OF THING. ONE OF THE ISSUES THAT WE HAVE IS THAT WE HAVE A
  LOT OF BANKS THAT ARE STATEWIDE OR EVEN THROUGHOUT THE UNITED STATES
  AND HAVE A TENDENCY TO DESIGN PRODUCTS THAT FIT IN A NATIONAL OR A STATEWIDE PLATFORM.
  WHEN IN A STATE LIKE CALIFORNIA, THE DIFFERENCE BETWEEN IMPERIAL VALLEY,
  THE DIFFERENCE BETWEEN SANTA CRUZ, THE DIFFERENCE BETWEEN FRESNO AND SACRAMENTO ARE
  LIKE FOUR DIFFERENT STATES. WE COULD FURTHER SEGMENT THAT DOWN INTO EVEN MORE THAN THAT.
  TO THE EXTENT THAT THOSE PEOPLE ARE ON THE GROUND AND IN THOSE COMMUNITIES,
  THEY HAVE TO KNOW THEIR COMMUNITIES. AT ONE TIME, AND I KNOW WE ALWAYS TALK ABOUT
  GOING BACK TO OLD?FASHIONED BANKING, BANKERS KNEW ABOUT TRANSPORTATION ISSUES.
  IT'S NOT JUST ABOUT LOW?INCOME HOUSING. IT'S NOT JUST ABOUT WHETHER IT'S SMALL BUSINESS LENDING.
  WE KNOW THE RELATIONSHIP BETWEEN POOR TRANSPORTATION, POOR HEALTH WITHIN OUR COMMUNITIES AND
  HAVING NEGATIVE IMPACTS WITHIN OUR COMMUNITIES THAT BANKERS ARE TRYING TO
  ADDRESS WITH THE C.R.A. IF THE PEOPLE ON THE GROUND AND IN THESE INSTITUTIONS DO NOT UNDERSTAND THE
  COMPLEXITIES AND THE NEEDS OF THEIR COMMUNITY, AGAIN, I SAY THEY SHOULD BE PUNISHED.
  NOW, TO THE EXTENT THAT THE FEDERAL RESERVE WERE TO GO OUT AND TO PROVIDE DATA,
  THAT'S ALMOST LIKE TELLING ME AS A LENDER, A BORROWER HAS GONE OUT
  AND HIRED A CONSULTANT TO DO HIS OR HER BUSINESS PLAN AND I'M GOING TO MAKE A LOAN TO
  THAT BORROWER WHO STILL MAY NOT NECESSARILY UNDERSTAND THAT BUSINESS PLAN BECAUSE
  IT'S NICE AND FANCY BECAUSE THEY'VE GOT A CONSULTANT WHO HAS BEEN ABLE TO PUT TOGETHER SOME GREAT DATA.
  I TEND TO LOOK AT THIS AS BEING A PRIMARY RESPONSIBILITY OF FINANCIAL INSTITUTIONS TO
  UNDERSTAND AND KNOW THE PERFORMANCE, THE CONTEXT OF THEIR COMMUNITY AND HOW THEY
  SHOULD BE PERFORMING IN THAT COMMUNITY WITHIN THE NEEDS THAT THEY HAVE.
  >> I THINK THAT THE BANKS SHOULD CONTINUE DOING THE ASSESSMENTS.
  BUT I THINK THE ASSESSMENTS SHOULD BE EVALUATED AND JUDGED ADEQUATE BY THE REGULATORS,
  NOT SIMPLY ACCEPTED AS PART OF A PLAN OR A PERFORMANCE. AND, IN FACT, IF THE ASSESSMENT ITSELF IS FLAWED,
  THEY SHOULD INFORM THE REGULATORS AS TO THE BANK'S C.R.A. PERFORMANCE.
  SO BOTH NEED TO BE PART OF THE PROCESS. A BANK SHOULD KNOW WHAT THE COMMUNITY
  LOOKS LIKE, BUT BECAUSE OF WHAT THEY SAY, IT SHOULDN'T BE ACCEPTED AS FACT.
  >> OKAY. I GUESSING I WOULD AGREE THAT THE BANKS SHOULD BE THE PRIMARY...
  SHOULD HAVE THE PRIMARY RESPONSIBILITY FOR THIS BECAUSE THEY ARE AND SHOULD
  BE CLOSEST TO THE COMMUNITY AND WHAT THE NEEDS ARE. I THINK THAT HAVING THAT...
  HAVING ACCESS TO DATA IS ONE THING, INTERPRETING THE DATA IS ANOTHER THING.
  AND INTERPRETING IT IN THE LIGHT OF NON?QUANTIFIABLE FACTORS IS ALSO SOMETHING
  THAT IS... CAN ONLY BE DONE IF YOU LIVE IN THE COMMUNITY. SO JUST BECAUSE THERE'S DATA
  DOESN'T MEAN THAT THE INTERPRETATION OF THE DATA IS GOING TO BE THE SAME
  IN EVERY COMMUNITY.AND SO I THINK THAT THAT'S WHY IT'S IMPORTANT TO HAVE THE BANKS DO THAT.
  HAVING ACCESS TO THE DATA THAT MAY BE THE REGULATORS WOULD HAVE IS REALLY CRITICAL,
  AND THEY HAVE... IF THERE'S MORE CAPABILITY ON THE PART OF THE REGULATORS TO PROVIDE THE DATA, GREAT.
  BUT I DO THINK IT SHOULD BE THE RESPONSIBILITY OF THOSE WHO ARE CLOSEST TO THE COMMUNITY,
  WHICH WOULD BE THE BANKS. >> THE LOW?INCOME HOUSING INSTITUTE RECOMMENDED THAT
  THE INDIVIDUAL BANK PERFORMANCE ASSESSMENT SHOULD BE OPEN TO COMMUNITY INPUT,
  AND I THINK THAT'S WHERE THE REGULATORS' PARTICIPATION AND NEEDS ASSESSMENT COULD HAPPEN.
  BECAUSE THROUGH A COMMUNITY INPUT PROCESS, YOU CAN DETERMINE WHETHER A COMMUNITY'S NEEDS
  ARE BEING ADDRESSED AND THROUGH AN APPEAL PROCESS TO PUT IN CONDITIONS THAT WOULD INCLUDE THE BANK,
  YOU KNOW, IMPROVING THOSE AREAS WHERE THE COMMUNITY NEEDS ARE STILL NOT BEING MET.
  >> I THINK WE FROM MY POINT OF VIEW WE NEED A SORT OF CHECK AND BALANCE.
  I MEAN, OUR GOAL AT C.R.C. IS NOT TO HAVE GREAT C.R.A. PROGRAMS AT THE BANKS BUT TO
  HAVE THE BANKS INTERNALIZE THOSE PROGRAM, SEE THEM AS GOOD BUSINESS AND MOVE FORWARD WITH THEM.
  SO I THINK THE CRITICAL THING IS FOR THE BANK TO REALLY UNDERSTAND AND TAKE IT ON.
  BUT I THINK IF WE'VE LEARNED ANYTHING IN THE LAST FIVE OR TEN YEARS,
  IT'S THAT ONCE IN A WHILE BANKS GAME THE SYSTEM AND MAY NOT TELL US THE WHOLE TRUTH.
  SO I THINK THERE NEEDS TO BE A RULE FOR THE REGULATORS TO REALLY OVERSEE THAT,
  MAYBE USING THE COMMUNITY TO BE SURE THAT WHAT'S HAPPENING IS REAL. AND IT'S REALLY BENEFITING THE COMMUNITY.
  I MEAN, HERE IN CALIFORNIA WE HAVE ALL THESE BANKS NOW THAT COME IN FROM OUT OF STATE.
  THEY SEE OUR BIG STATE. THEY SEE AN ABILITY TO MAKE LOTS OF MONEY.
  AND THEY THINK IT LOOKS LIKE MINNESOTA OR NEW YORK OR NORTH CAROLINA OR SOMETHING.
  YOU KNOW, AND THEY DON'T REALLY UNDERSTAND, YOU KNOW, WHAT GOES ON HERE,
  THE DIVERSITY, THE SIZE OF IT. I MEAN, MAYBE WE HAVE EIGHT REGIONS HERE.
  YOU KNOW THIS STATE IS THE SIZE OF MOST OF THE EAST COAST. SO THEY THINK IT'S LIKE
  RHODE ISLAND OR SOMETHING. YOU KNOW, IT'S A STATE. SO I THINK WITHOUT THERE BEING
  SOME PRESSURE FROM OTHER PLACES, THERE CAN'T BE A GOOD ASSESSMENT.
  >> I WOULD JUST ADD TO THAT THAT REGARDLESS OF WHO IS DOING THE NEEDS ASSESSMENT,
  IT'S CRITICAL THAT THE COMMUNITY IS PERCEIVED, NUMBER ONE, EITHER IN THE FRONT END
  WHERE THEY'RE PROVIDING THE INPUT, OR ON THE BACK END WHERE THEY'RE ABLE TO PROVIDE
  OVERSIGHT AND EITHER AGREE OR AMEND THE ASSESSMENT WHICH WAS CREATED.
  >> WE'RE A FEW MINUTES AHEAD. ANY FINAL... OKAY. WE'RE GOING TO BE MOVING ON TO THE VERY LARGE ROUND OF COMMENTERS.
  A COMMENT WAS MADE BY MR. FISHER EARLIER ABOUT KEEPING THE RECORD OPEN.
  THERE IS AN OPPORTUNITY FOR PUBLIC COMMENT TO BE ADDED TO THE RECORD
  THROUGH THE END OF THE MONTH. SO WE DO WELCOME ADDITIONAL COMMENTS.
  I'D LIKE TO THANK THIS PANEL FOR THEIR CONTRIBUTION. WE WILL ADJOURN FOR JUST OVER 15 MINUTES.
  WE ASK THE SPEAKERS IN THIS FINAL SESSION TO BE IN PLACE BY FIVE MINUTES
  TO 3:00 SO WE CAN GET STARTED. WE HAVE QUITE A LARGE NUMBER TO GET THROUGH.
  THANK YOU.