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Public Meeting Transcripts

Public Meeting Regarding NationsBank and BankAmerica

Friday, July 10, 1998

Transcript of Panel Twenty-Four


         1            MS. SMITH:    Good afternoon.  I'm reminding the 

         2   witnesses about our timing system.  We have a timer who 

         3   will give you a one-minute message when you have one 

         4   minute remaining.  She'll hold it up.  And then one 

         5   minute later -- we hope that you will see it.  Sometimes 

         6   you may not because you'll be looking at your text.  One 

         7   minute later, she will hold up the time expired message.  

         8   And then, if you still haven't looked up, then we have 

         9   the gong.  So that's the system that we'll be using.  Are 

        10   we all set?  

        11            This is Panel 23, and we're going to start with 

        12   Dr. Welbon.  

        13            DR. WELBON:   Good evening, Chairman Smith and 

        14   to the members of the board.  We are here representing 

        15   the Pastors and Ministers Congress of San Francisco and 

        16   adjacent cities and also the Northern California 

        17   affiliate of the National Congress of National Black 

        18   Churches, which represent over 25 million churches -- I 

        19   mean, 25 million members over the nation.  

        20            We are here in objection to the merger and the 

        21   resolution to the proposed merger by NationsBank 

        22   Corporation of Charlotte to acquire Bank of America 

        23   Corporation of San Francisco.  

        24            The Pastors and Ministers Congress of San 

        25   Francisco and adjacent cities, in conjunction with the 

        26   South Bay branch of the NAACP and the Northern California 

         1   affiliate of the Congress of National Black Churches, 

         2   which represent over 500 churches in the Bay Area and 

         3   active community-based organization, have formed a 

         4   coalition against a merger and hereby file their concerns 

         5   on behalf of the neighborhoods about the merger's impact 

         6   on the banking services to lower income and minority 

         7   neighborhoods.  

         8            The federal law, the Community Reinvestment Act 

         9   of 1977, requires banks to make loans in all 

        10   neighborhoods in which they have branches.  And we're 

        11   concerned about how Bank of America is closing most of 

        12   their bank branches in predominant African-American 

        13   neighborhoods in the area.

        14            In addition, I'd like to put a little quote 

        15   there, too.  If you now go to most of Bank of America -- 

        16   especially they've closed down most of them in the 

        17   predominant African-American neighborhoods in San 

        18   Francisco however.  But if you go into any Bank of 

        19   America, black males is an endangered species.  They 

        20   don't exist on the windows as tellers.  

        21            I would hope that you would consider a 

        22   comprehensive recruiting program that can enable young 

        23   black males to participate and be workers in the bank.  

        24   That's one point.  

        25            The next point is that -- our concerns is 

        26   that -- we are concerned about the poor community lending 

         1   records to minorities, especially African-Americans in 

         2   low-income areas.  Federal regulators should look at 

         3   their records very closely.  I'm talking about the bank 

         4   before the merger.

         5            We feel that these giant institutions should 

         6   expand their loan commitments nationwide in community 

         7   development loans and other investments, such as 

         8   assisting worthwhile community service projects.  We feel 

         9   that the bank should expand their small business loans, 

        10   affordable housing loans, loans to minority contractors, 

        11   especially African-American contractors, and economic 

        12   development loans and consumer loans.  

        13            It is our concern if these two banking 

        14   institutions are allowed to merge without these detailed 

        15   guidelines in place as part of this merger, it is our 

        16   views that these institutions may neglect or abandon this 

        17   community investment in California, especially in 

        18   African-American neighborhoods.  

        19            More important, we are very concerned about 

        20   these banking institutions' lending policies to 

        21   African-Americans, high-end policies of 

        22   African-Americans, especially African-American males as I 

        23   state.  

        24            Now let me just take you just a few steps 

        25   further.  We have signed an agreement from the National 

        26   Congress of National Black Churches with the Justice 

         1   Department.  If you want to see crime go down in our 

         2   neighborhoods, you can be a player at the table to help 

         3   us.  We have developed a very comprehensive innovative 

         4   program that we have submitted to the Justice 

         5   Department.  They have accepted our -- a one-year pilot 

         6   program.  And I submit the comprehensive program proposal 

         7   to NationsBank, to the Federal Reserve Board, to review 

         8   that proposal.

         9            We're working in the school systems.  We're 

        10   taking our churches to work and to the communities, the 

        11   school, with the police department, social service 

        12   agencies, et cetera, to put together a comprehensive plan 

        13   and to help young people stay out of trouble.

        14            And another thing that we're trying to do as 

        15   well, we are trying to put together a proposal to stop 

        16   jails from filling up.  Educate our young peoples, build 

        17   this nation, build a strong nation.  And this is what 

        18   this should be all about.  And this is why we're at this 

        19   time opposing the merger until such time that some of 

        20   these things are looked at very carefully and some of 

        21   these things are put in place so that we can really look 

        22   at the bank and you can look at America as it grows into 

        23   the 21st century, all colors, all peoples participating 

        24   and working.

        25            We want that kind of vision and we can -- you 

        26   can help us make it.  And that's why we're here at this 

         1   time opposing this merger.  Because you can be a great 

         2   player in helping us make this become a reality.  Thank 

         3   you very much.  

         4            MS. SMITH:    Thank you, Dr. Welbon.  

         5   Mr. Burgis.  

         6            MR. BURGIS:   Yes.  My name is John Burgis, and 

         7   I serve as senior vice president of financial services 

         8   and chief financial officer for Catholic Healthcare 

         9   West.

        10            Today I represent the concerns and hopes of 

        11   Catholic Healthcare West and a number of institutional 

        12   investors, including the general board of pensions of the 

        13   United Methodist Church, the Presbyterian Church U.S.A., 

        14   Christian Brothers Investment Services, the congregation 

        15   of the Sisters of Charity of the Incarnate Word, and 

        16   Sisters of Charity Health System.  These institutions 

        17   alone hold over 650,000 shares of NationsBank stock and 

        18   over 400,000 shares of Bank of America stock.  

        19            Catholic Healthcare West uses Bank of America 

        20   for its cash transactions and credit needs.  Both the 

        21   Sisters of Charity and the Sisters of Charity Health Care 

        22   System use NationsBank for their cash transactions.

        23            Let me begin with some background on Catholic 

        24   Healthcare West's relationships with Bank of America.  

        25   Catholic Healthcare West is a 3.5 billion dollar health 

        26   services delivery system with facilities and affiliated 

         1   physician groups in California, Arizona, and Nevada.  As 

         2   a religiously-sponsored organization, CHW seeks business 

         3   partners that demonstrate corporate social 

         4   responsibility.

         5            In 1991, CHW began a significant lending and 

         6   depository relationship with Bank of America, due in 

         7   large part to the bank's commitment to expanded community

         8   reinvestment.  During the ensuing years, we have noted 

         9   and admired Bank of America's efforts to differentiate 

        10   itself as a leader in corporate social responsibility.

        11            Particular accomplishments include focused 

        12   attention to developing and promoting access to 

        13   affordable financial services and products, driven by a 

        14   formal goal to achieve outstanding ratings in every CRA 

        15   examination; substantial financial commitment to Bank of 

        16   America Community Development Bank; dedicated and expert 

        17   leadership devoted to community reinvestment and 

        18   development; inclusion of environmental and social 

        19   considerations and criteria for lending to developing 

        20   economies; development of a strong environmental program, 

        21   including endorsement of the serious principals for 

        22   corporate and environmental responsibility and 

        23   accountability; sustained commitment to diversity in the 

        24   workplace demonstrated by effective equal employment 

        25   opportunity and promotion programs, minority purchasing 

        26   programs, and expanded family benefits programs.

         1             Relative to the proposed merger of Bank of 

         2   America and NationsBank, we urge the new corporation to 

         3   embrace a comparable, if not enhanced, stance towards 

         4   corporate responsibility.  In our view, the merger 

         5   presents a singular opportunity to develop an exemplary 

         6   enterprise that succeeds in the marketplace by becoming 

         7   the national leader in meeting community needs.

         8            In particular, we are concerned that the new 

         9   corporation commit formally and publicly to meeting the 

        10   credit needs of every community where it does business, 

        11   with special attention to low/moderate income clients and 

        12   persons of color.  To that end, we have asked Dr. Lind of 

        13   CANICCOR to prepare reports assessing both NationsBank 

        14   and Bank of America's performance in addressing the 

        15   credit needs of these historically under-served 

        16   populations.  

        17            Based on Dr. Lind's assessment, we ask the new 

        18   corporation to commit to both mortgage lending and small 

        19   business goals.  In mortgage lending, especially on 

        20   purchased mortgages and home improvement loans, we ask 

        21   that the new holding corporation seek to achieve, first, 

        22   performance levels above the industry level in the 

        23   assessment areas of the banking subsidiaries and lending 

        24   to black, Hispanic, and low-income borrowers and in 

        25   lending in low/moderate income tracts and, secondly, 

        26   performance levels at parity with the industry in all 

         1   other geographic areas in which the mortgage lending 

         2   subsidiaries operate in lending to black and Hispanic 

         3   borrowers.  

         4            With regard to business lending, we request that 

         5   the corporation achieve above the industry levels in 

         6   small business loans, especially first loans of 100,000 

         7   and under in low/moderate income tracts and, secondly, 

         8   loans to small businesses in low/moderate income tracts.  

         9            We believe that these goals would not impair the 

        10   financial viability of the corporation but would increase 

        11   the corporation's market.  Such goals would provide a 

        12   firm basis for a further development of these communities 

        13   and help ensure the corporation against violations of the 

        14   Equal Credit Opportunity Act.  

        15            In recent negotiations with a number of 

        16   corporations, we have been gratified by their readiness 

        17   to adopt similar goals and are confident that the merged 

        18   corporation will demonstrate a comparable willingness to 

        19   implement such goals.

        20            We were pleased with the announcement of a 

        21   community lending commitment of 350 billion over the next 

        22   ten years for the merged corporation.  It is, indeed, the 

        23   largest commitment announced to any merger so far.

        24            We welcome the new corporation's willingness to 

        25   detailed annual reporting of performance at national, 

        26   regional, and local levels.  We view such reporting as a 

         1   means to maintain public accountability and as a platform 

         2   for dialogue.

         3            However, we believe that the goals which I 

         4   outlined above serve a different function from these 

         5   commitments.  Commitments are what can be counted on, 

         6   while goals detail the benchmarks toward which the 

         7   corporation aims, thus goals are usually higher than 

         8   commitments and are more specific.  We are particularly 

         9   concerned that goals be developed to apply to local 

        10   markets and market sectors.

        11            As Dr. Lind points out -- well, I will stop 

        12   there and simply conclude by saying that, in closing, let 

        13   me reiterate my advocacy that the new corporation embrace 

        14   a vigorous stance toward corporate social responsibility 

        15   and seize the opportunity to develop an exemplary 

        16   enterprise that succeeds in the marketplace by becoming 

        17   the national leader in meeting community needs.

        18            MS. SMITH:   Thank you very much.  And next we 

        19   will hear from Dr. Lind.  

        20            DR. LIND:   Thank you.  I'm John Lind, executive 

        21   director of CANICCOR, an agency of a nonprofit 

        22   corporation.  CANICCOR serves as a consultant to 

        23   institutional investors on the social responsibility of 

        24   financial institutions.  It provides services in two 

        25   fashions.

        26            First, CANICCOR provides information to funds 

         1   that have social screens.  These include Kinder,

         2   Lynderberg & Domini, Calvert, and U.S. Trust.  Secondly, 

         3   CANICCOR provides analysis for and coordination between 

         4   institutional investors which take an active role with 

         5   the corporations in which they invest.  It is out of this 

         6   second role that I speak with you today.  

         7            As you have heard from John Burgis of Catholic 

         8   Healthcare West, church-related shareholders have sought 

         9   agreements with a number of major lenders to have goals 

        10   of lending at or above the industry level to each 

        11   under-served group and area in which the corporation 

        12   operates.  The industry level is defined as all reporters 

        13   under the Home Mortgage Disclosure Act.

        14            Concerns focus primarily on home purchase loans, 

        15   home improvement loans, and small business loans.  These 

        16   are products geared towards first-time home buyers, 

        17   households improving their living conditions, and small 

        18   businesses seeking to expand or sustain their 

        19   operations.  

        20            With regard to home purchase loans for owner 

        21   occupancy, neither NationsBank nor Bank of America have 

        22   been near the industry levels in their home areas, let 

        23   alone in distant areas.

        24            Bank of America's performances were outstanding 

        25   in 1992 with their development of Neighborhood Advantage 

        26   loans, and these performances were particularly good with 

         1   low/moderate income minority borrowers.  But in the 

         2   intervening years, the industry overtook Bank of America 

         3   and its performance levels dropped continuously.  

         4   However, this decline was retarded by the manufactured 

         5   housing lending unit.  Unfortunately, this unit was sold 

         6   during the spring of this year, and I have had to 

         7   eliminate its lending from my analysis to estimate Bank 

         8   of America's present performance level.  

         9            To its credit, Bank of America is beginning to 

        10   design some new products, but it will take time to get 

        11   these products into the marketplace.  

        12            NationsBank has performed poorly in its home 

        13   areas of North Carolina and surrounding states.  It has 

        14   aggressive -- it has an aggressive acquisition program 

        15   and recently acquired Boatmen's and Barnett banks, both

        16   of which perform much better than NationsBank.  It 

        17   remains to be seen whether NationsBank will have learned 

        18   from its acquisition or whether NationsBank's policies 

        19   will prevail and cause the lending performances to 

        20   decline.  

        21            Let me give you a few numbers to illustrate the 

        22   problem.  In 1996, NationsBank originated 14,092 loans to 

        23   black borrowers, the most difficult to serve group, in 

        24   its home territory of North Carolina, South Carolina, and 

        25   Virginia, 657 loans below the industry level of all Home 

        26   Mortgage Disclosure Act reporters.  If NationsBank were 

         1   to achieve the industry parity, lending to black 

         2   borrowers in these states should have increased by 45 

         3   percent.  

         4            In 1996, Bank of America issued 396 loans to 

         5   black borrowers in California, 186 loans below the 

         6   industry average.  To have achieved industry parity in 

         7   its lending to this sector, lending to black borrowers 

         8   should have increased by 47 percent.  

         9            Overall, in 1996, the two corporations performed 

        10   at 24 to 27 percent below the industry in lending to 

        11   black borrowers, 12 to 15 percent below the industry in 

        12   lending to Hispanic borrowers, 14 percent below in 

        13   lending to low/moderate income borrowers, and seven to 22 

        14   percent below in lending in low/moderate income tracts.  

        15   I refer you to my filing for details on home improvement 

        16   lending and small business lending.  

        17            Let me summarize by saying that we have had a 

        18   recent phone conversation with NationsBank and believe 

        19   that the goals we propose are not foreign to the 

        20   corporation.  However, even if these goals were adopted, 

        21   the merged corporation faces considerable challenge in 

        22   developing the necessary structures to attain these goals 

        23   in the near future.  

        24            NationsBank -- one, NationsBank and Bank of 

        25   America have very different corporate cultures which need 

        26   to cooperate and coordinate.  Two, their market areas are 

         1   very different, high housing price California versus 

         2   moderate-priced midwest and south.  So they will need a 

         3   diversity of loan products, and those products will have 

         4   little overlap.  And, three, both corporations are coming 

         5   from relatively poor performance levels in their distinct 

         6   market areas.  

         7            These challenges underscore the importance of 

         8   detailed reporting by loan type and market area on the 

         9   part of the merged corporation and the necessity of 

        10   providing a forum for discussion of the performance 

        11   results.  

        12            We do not expect miracles overnight, but we hope 

        13   to see progress according to a planned process.  Thank 

        14   you.  

        15            MS. SMITH:    Thank you very much.  Ms. Hizel.  

        16            MS. HIZEL:   Good afternoon.  I have the 

        17   pleasure of representing Youth Enterprises System 

        18   Incorporated, which, along with its parent organization, 

        19   Youth Development Incorporated, is one of the largest 

        20   nonprofit community development corporations in New 

        21   Mexico.  We develop affordable housing, as well as 

        22   counsel under-served communities primarily comprised of 

        23   residents with very low, low, and moderate incomes, the 

        24   majority of which are minority groups such as Hispanic, 

        25   Native American, and African-American.  

        26            Youth Enterprises System Incorporated is not 

         1   opposed to the merger but asks that the Federal Reserve 

         2   Bank consider these concerns and address any foreseen 

         3   problems to ensure a successful merger.

         4            Currently both NationsBank and Bank of America 

         5   are active lending institutions in the state of New 

         6   Mexico, and though NationsBank is a newcomer, some of its 

         7   employees are long-time banking partners from Boatmen's 

         8   and Sun West.

         9            The impact of the recent Sun West acquisition 

        10   was fairly smooth because the preliminary transactions in 

        11   which we were actively involved did not appear to slow or 

        12   diminish.  The residual effect has been, however, less 

        13   than favorable in that our current transactions are 

        14   tediously slow and inconsistent.  The cause seems to be 

        15   due to the fact that some of the new loan officers are 

        16   unfamiliar with our market and transaction types are not

        17   properly prepared or informed of our needs.  We hope the 

        18   merger will not displace any bank officers who are 

        19   familiar with our market and who are intimately familiar

        20   with our client and agency obligation.  The needs of our 

        21   communities are unique to New Mexico, as are the needs of 

        22   communities in say San Francisco or Houston.

        23            NationsBank was generous in its debut in New 

        24   Mexico, and Bank of America has also contributed to our 

        25   communities via organizations, businesses, and other 

        26   institutions.  We would suggest increased and more 

         1   focused bank contributions targeting affordable housing 

         2   and economic revitalization of older neighborhoods via 

         3   mini/macro-loan programs, nonprofit neighborhood credit 

         4   unions, and other new initiatives as necessary given the 

         5   current economic climate in our community.

         6            One of our major concerns is that the two bank 

         7   personalities will distort one another and cause chaos in 

         8   the delivery of contributions and bank products.  If the 

         9   cost of the merger is passed through to the 

        10   organizations, then the communities we serve by reducing 

        11   contributions and/or minimizing discounted and wavered 

        12   products, then the people we serve will suffer the 

        13   burden.  

        14            Many bank employees from both banks are 

        15   uncertain of their future.  Combine this with the Norwest 

        16   buy-out of Bank of New Mexico and Wells Fargo buy-out of 

        17   Norwest and the entire banking community is on its ear in

        18   New Mexico.  Our organization and others like us are not 

        19   able to function at full capacity because of the turmoil, 

        20   because of the lack of fluid transactions, new staff 

        21   coming, old staff going, and contributions at a 

        22   standstill.

        23            Last year we conducted over $11 million of 

        24   business not inclusive of our day-to-day banking business 

        25   in excess of 12 million a year.  This calendar year we 

        26   have not been able to close a single transaction with 

         1   NationsBank despite the fact that we have nine sites 

         2   under contract and were scheduled to close one bond 

         3   transaction on June 30th, 1998.  We had commitments from 

         4   the bonding agency and the rehab granting agency since 

         5   March and April of '98 respectfully and began discussions 

         6   on this 4.2 million deal in March of '98.  The deadline 

         7   has now been given as August 15th.

         8            We have memorandums of understanding with other 

         9   major mortgage lenders in our market but have not been 

        10   able to get one with NationsBank due to the lack of 

        11   response, nor Bank of America.  Again, I believe it is 

        12   due to the fact that policy changes are occurring, 

        13   staffing changes are occurring, and employees are 

        14   entering our marketplace with ideas that may have worked 

        15   in San Francisco but will never work in New Mexico.

        16            Our mortgage and commercial product is important 

        17   to our constituency and to us, and if this merger slows 

        18   the delivery of our product, of that product, then our

        19   production and growth potential is also diminished.  The 

        20   bank contributions are important to us and, without them, 

        21   we cannot conduct feasibility analysis and other 

        22   pre-development duties necessary to commit ourselves to

        23   long-term loans and other bank products.  Therefore, it 

        24   is critical that local officers conduct business as usual 

        25   to ensure the bottom line of the bank and the services of 

        26   the agencies are fulfilled.

         1            Deals work only if the bank is willing to 

         2   provide below-market interest rate, fee waivers, and 

         3   discount portfolio products to our constituency.

         4            The new merger is going to add to the existing 

         5   chaos, and though we are thankful we're not in your 

         6   shoes, it is important that this merger not diminish our 

         7   relationship but that it strengthens our relationship and 

         8   endeavors to build new and innovative ones to ensure our 

         9   common goals are met.

        10            We fear contributions will diminish, 

        11   below-market interest rates will go away, and New Mexico 

        12   employees will be replaced by employees unfamiliar with 

        13   New Mexico communities.

        14            The method of the merger is critical to all of 

        15   us, and we would like to stay abreast of all the changes 

        16   and expectations as they occur and provide as much 

        17   assistance as we can during the period to hope that our 

        18   existing products do not fail or falter.  Thank you.  

        19            MS. SMITH:    Thank you very much.  

        20            MR. FRIERSON:    I have a question for 

        21   Dr. Lind.  Could you go into a little more detail about 

        22   the methodology of the study that you used and address 

        23   whether the data allowed you to control for income as 

        24   well as race?  

        25            DR. LIND:   Well, my general methodology is to 

        26   take the home mortgage data and take the full HMDA report 

         1   for each MSA and basically scale down that portfolio to 

         2   the size of the lender in that MSA and then compare the 

         3   two.

         4            And so if the lender -- if the scaled portfolio 

         5   which is of the same size as the lenders had, you know, 

         6   65 loans to black borrowers but the lender had only 35 

         7   loans, then I say that the lender is below the industry 

         8   by 35 loans.  And then I can add those up as I go up to 

         9   higher levels of geography and corporate levels.

        10            And obviously I used the HMDA data in terms of 

        11   the income that's provided by the HUD income levels for 

        12   that -- for the given year that are provided by the FFIEC 

        13   in looking at the income distribution of the borrowers.  

        14            This is equivalent to the old market fraction 

        15   rate that was proposed by the OCC back -- by the FFIEC 

        16   back in December of 1993.  

        17            MR. FRIERSON:    Market share test?  

        18            DR. LIND:   It's basically the market share 

        19   test, but I've -- actually, Stephen Cross at OCC agreed 

        20   with me that we're talking the same language.  It's just 

        21   that it's convenient for me to phrase it this way because 

        22   I can add it up from -- to higher levels, whereas the 

        23   market share test is really good at the -- just at the 

        24   MSA level.  

        25            MS. SMITH:    But the income that you use is the 

        26   demographic information from the Bureau of the Census?  

         1            DR. LIND:   That's right.  

         2            MS. SMITH:    So that it tells you the income 

         3   level of given census tracts?  

         4            DR. LIND:   That's right.  I buy the FFIEC 

         5   census tape each year.  

         6            MS. SMITH:    I have a question for Dr. Welbon.  

         7   You mentioned a pilot -- a one-year pilot program and 

         8   having submitted a proposal.  I wasn't clear.  You 

         9   mentioned the Department of Justice and you mentioned the 

        10   Federal Reserve.  

        11            DR. WELBON:   That is correct.  

        12            MS. SMITH:    And what exactly is the proposal 

        13   for?  

        14            DR. WELBON:   We submitted in a very 

        15   comprehensive proposal that we submitted to the Federal 

        16   Reserve Bank and NationsBank as dealing with the school 

        17   systems.  We have an initial 1.5 million dollar grant on 

        18   the national level from the Congress of National Black 

        19   Churches, which I serve as the Northern California 

        20   chair.  And we are initiating a comprehensive innovative 

        21   program dealing with young peoples into the school 

        22   systems, also to make sure that they stay on the right 

        23   side of the track, and also that we haven't a lot of 

        24   violence in our school system at this particular time.  

        25   And we're trying to do something to bring that level 

        26   down.

         1            And we feel that -- and we feel that what is 

         2   happening in our school systems, there must be some sort 

         3   of proper -- reason why it's happening, especially kids 

         4   shooting one another and shooting our school teachers, et 

         5   cetera.  And we need to try to focus on what can be done 

         6   to solve that sort of problem.  And that's the type of 

         7   program that we have initiated with the Justice 

         8   Department and we're working with our school.

         9            We put a summits on in San Francisco, also in 

        10   Oakland.  And in the Northern California we're having 

        11   summits meeting with the teachers of the school, the 

        12   Justice Department, the social service department.  All 

        13   of those entities are working to establish a network and 

        14   a joint partnership to order for us put -- to help this 

        15   comprehensive program at work.

        16            I would rather see us take that $35,000 so we 

        17   incarcerate prisons, put young people in prison, and put 

        18   it into -- invest it into our young people.  Because we 

        19   have to look at we're investing into our future, our 

        20   young people.  America is on the -- it can be the most 

        21   beautiful country in the world, but we have to look at 

        22   the positive side and the negative side and work with 

        23   both sides to put together this innovative -- and with 

        24   your help, we can do that.

        25            MS. SMITH:   But the proposal is for joining in 

        26   a partnership?  Is it for --

         1            DR. WELBON:   The proposal has been submitted to 

         2   First Nationwide if you need to take a look at it, Bank 

         3   of America -- 

         4            MS. SMITH:    Well, I was interested in -- you 

         5   mentioned the Federal Reserve and I didn't know exactly 

         6   what role.  

         7            DR. WELBON:   Well, we submitted a copy to the 

         8   Federal Reserve.  

         9            MS. SMITH:    For our information?  

        10            DR. WELBON:   For your information.  

        11            MS. SMITH:    Okay.  I understand.

        12            Any other questions?  If not, we thank you very 

        13   much for your testimony this afternoon.  Be sure if you 

        14   have any supplemental comments to submit them by a week 

        15   from today close of business.  Well, 5:00 Eastern 

        16   Daylight Time.  And with that, I guess we're ready for 

        17   the next panel.  

Last update: December 3, 2010