Download The Community Reinvestment Act, Bank

The Community Reinvestment Act, Bank Performance in Housing Lending and Investment in Broward County
A Report Prepared for the Broward County Housing Council
April 2014
Carras Community Investment, Inc.
Table of Contents
Introduction
3
I. Broward Banking Market
3
II. Community Reinvestment Act Statute and Regulations
4
III. Broward Housing Credit Needs 9
IV. Home Mortgage Disclosure Act (HMDA) Analysis 14
V. Broward Banks Performance Evaluations
35
VI. Assessment of Broward Housing Council Work Program vs. Bank CRA Activities
38
VII. Summary of Findings
42
VIII. Recommendations 44
IX. Appendix
48
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Largest 14 banks – Performance Evaluation, Contact information, Performance Evaluation
SEPARATE DATABASES (see Broward Housing Council website: http://www.broward.org/browardhousingcouncil)
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Broward Banks and Branches
Broward Banks Performance Evaluation Hyperlinks
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Introduction
The Broward Housing Council seeks to better understand the level of community investment by regulated financial institutions relative
to affordable housing in Broward County’s low- and moderate-income communities and to low- and moderate-income persons. The
following report explains how the Community Reinvestment Act (CRA) works, summarizes key housing credit needs, provides a review
of Home Mortgage Disclosure data, analyzes the CRA performance of the largest banks in the market, assesses the financial institutions
level of investment and lending, and provides recommendations for increasing housing lending and investment in Broward County.
I. The Broward Banking Market
The banking industry has changed since 1977, and changed most rapidly since the erosion and eventual repeal of the Glass-Steagall Act
a decade and a half ago. It has undergone massive consolidation in the past decade, and is increasingly dominated by regional and
national institutions, making it much harder for regulators to hold banks accountable to “local” credit needs; This has challenged the
clear premise of the CRA that banks are required to help meet the credit needs of the local communities in which the banks do business
and take deposits. With bank consolidation and expansion of their business territories, banks can now be evaluated by their CRA
regulators at the Metropolitan Statistical Area level or larger. For Broward County, this means it is included in the Miami-Fort
Lauderdale-Pompano Beach Metropolitan Statistical Area. Banks can also get credit for reinvestment activities at the state level even if
they have no direct impact on their assessment area.
There are 57 banks in the Broward banking market including 32 Large (CRA- defined), 12 Intermediate Small (CRA-defined) banks, and
13 Small (CRA-defined) banks. The large banks have 424 branches, 28 intermediate small banks’ branches, and 28 small bank branches;
Of all bank deposits in Broward County ($39.4 billion), 89.4% ($36.7 billion) are in the 32 large banks with 44% of all deposits in two
banks – Bank of America and Wells Fargo.
See Appendix of Database of CRA Performance Evaluations of Broward Banks and Broward County Branch database.
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II. The Community Reinvestment Act Statute and Regulations
The Community Reinvestment Act (CRA), enacted by Congress in 1977 (12 U.S.C. 2901) and implemented by Regulations 12 CFR parts
25, 228, 345, and 195, is intended to encourage depository institutions to help meet the credit needs of the (entire, including low- and
moderate-income) communities in which they operate. The Community Reinvestment Act was passed by Congress mainly in response
to allegations primarily from community organizations and researchers that banks were discriminating against low-income communities
based on location (more commonly known as “redlining”); Often these communities were predominantly minority or adjacent to
minority communities.
The CRA requires that each insured depository institution's record in helping meet the credit needs of its entire community be evaluated
periodically (typically every three to five years). That record is taken into account in considering an institution's application for deposit
facilities (i.e. branches), including mergers and acquisitions. CRA examinations are conducted by the federal agencies that are responsible
for supervising depository institutions: the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance
Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC).
An amendment to the Community Reinvestment Act in 1990 requires that CRA ratings be made public. Each bank must maintain a public
file that contains the public section of its most recent CRA performance review, a list of its services and branches, written comments
from the public, and certain other information.
Before examiners from financial regulatory agencies can judge a bank's CRA performance, they need to get a general sense of the
community and how the bank fits into it. They consider a number of factors, including but not limited to:
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The community makeup – demographics
Local economic conditions
Existing opportunities for serving the community through lending and investments
The bank’s business strategy and products
The bank’s financial condition
The bank’s understanding of its local credit needs
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 Feedback and information from community organizations and government agencies as well as individuals on the bank’s
efforts toward meeting the community’s credit needs;
Performance Evaluation Standards
Regulatory examiners use specific standards, amended in 1995, for reviewing a bank's CRA performance. The examiners apply these
standards to rate a bank's overall record of helping to meet the credit needs of the specific area a bank has defined as its assessment
area. Depending on whether a bank is large or small, the standards used to review it (described in the sections below) are somewhat
different.
A bank may choose to develop its own strategic plan to be evaluated by rather than use the defined standards. Such a plan must be open
to public comment and must be approved by the bank's federal regulatory agency before it can go into effect. Very few banks are using
the strategic plan method of complying with the Community Reinvestment Act including none in the Broward market.
Wholesale banks, which do not make loans to retail customers, and limited purpose banks, which offer only a few products (such as
credit cards or auto loans), also receive CRA ratings. These ratings, though, are based on different standards since the banks' activities
are more limited. Only one bank in Broward County is considered a wholesale bank – Northern Trust.
Standards for Large Banks
Large banks—those with total assets of $250 million or more or that are affiliates of holding companies with assets of $1 billion or
more—are evaluated in three areas: lending, investment, and service.
Lending. When evaluating a bank's lending activities and the borrowers it reaches, examiners analyze loans for home mortgages, small
businesses, small farms, and community development (as well as consumer loans, in some cases). They look at information about:
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Responsiveness to credit and community development needs through lending practices.
The total number and total dollar amount of loans made in the assessment area.
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The geographic distribution of loans, that is the proportion of the bank’s total loans made within its assessment area – low-,
moderate-, and middle-income locations.
The characteristics of borrowers – how loans are distributed to people at various income levels.
Quality of service for credit needs of extremely economic disadvantaged areas, low-income individuals and small businesses.
The bank’s activity in community development – how many and what dollar amount of loans benefit low- and moderateincome people or geographic areas. How complex or creative are these loans?
Whether the bank uses flexible lending practices to address the credit needs of low- or moderate-income individuals or
neighborhoods
Use of creative lending practices to address credit needs of low- or moderate-income people or neighborhoods
Investment. When evaluating a bank's investments, examiners look not only at a bank's assessment area but also at a broader statewide
or regional area surrounding it. Examiners want to know:
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How much money the bank has invested – the level of qualified community development investments and grants.
How innovative or complex the investments are to support community development needs.
How well the investments respond to credit and community development needs, and
Whether the investments are a different type from those provided by most other investors.
Service. When evaluating retail and community development services, examiners focus on how well these services help meet the credit
needs of the institution's community. In the area of retail banking, examiners look at:
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How branches are distributed throughout the community.
The bank’s history of opening and closing branches, particularly those serving low- or moderate-income people or geographic
areas.
Whether the range of services provided meets the needs of various neighborhoods at all income levels.
Accessibility of services to all geographic areas and people of different income levels.
Way in which openings to all geographic areas and people of different income levels.
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Examiners also consider how responsive and creative a bank is in providing or helping other organizations provide financial services
that address special credit needs in the community or region—for example, more affordable housing or more available credit.
Standards for Small Banks
Small banks—those with total assets of less than $250 million, either independent or an affiliate of a holding company with total assets
of less than $1 billion—are evaluated by more streamlined standards than those used for larger banks. At a small bank, examiners look
at:
 The share of the bank’s deposits used to make loans,
 The percentage of loans made within the bank’s assessment area,
 Its record of lending to borrowers of different income levels
 The geographic distribution of its loans, and
 Its record of taking action in response to written complaints about its performance in helping meet the community’s credit
needs.
Examiners assign a bank an overall CRA rating based on factors included in the performance standards described above. The examiner
then weighs these specific factors and how they contribute to a large bank's overall rating of outstanding, satisfactory, needs to improve,
or the lowest rating—substantial noncompliance. A small bank receives one of these four ratings based on its performance under the
standards for small banks.
Regardless of whether the bank is large or small, any evidence of discriminatory or illegal credit practices will have a negative effect on
examiners' evaluation of the bank's performance and could lower its overall CRA rating.
CRA Public Comment File
Each bank must maintain a public file, updated as of April 1 each year that includes the following information:
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 For the current year and two previous years, all written comments from the public about how the bank is helping meet
community credit needs. The file must also include the bank's response to these comments.
 A copy of the public section of the bank's most recent CRA performance evaluation. The bank must place the copy in its public
files within 30 business days after receiving it. If the bank received a less-than-satisfactory rating during its most recent
examination, it must include a description of efforts to improve its performance and update that report every three months.
 A list of the bank's current branches with their street addresses and the geographic areas they serve. The list must also show
this information for any branches the bank has opened or closed during the current year and previous two years.
 A list of services—including hours of operation, available loan and deposit products, and fees—offered at the bank's branches.
This list must note any significant differences in its services at particular branches.
 A map of the bank's assessment area showing its boundaries and identifying the various geographic areas within it, either on
the map or in a separate list.
 Information on loans that are included in the bank's review.
 A copy of the bank's strategic plan, if the bank is evaluated by one.
In the Appendix of this report is a summary of Performance Evaluations and Public Comments for the largest 14 banks in Broward
County.
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III. Broward Housing Credit Needs
In 1977, Congress enacted the Community Reinvestment Act (CRA), which required federal financial regulatory agencies to encourage
regulated financial institutions to help meet the “credit needs” of their local commnities, including low- to moderate-income
communities. Defining those credit needs can come from a variety of sources including community organizations, public community
and economic development agencies, the public, financial regulatory agencies and the bank’s understanding of low- and moderateincome area market needs.
In Broward County, those credit needs related to (affordable) housing can be best seen in HUD-required Consolidated Plans for CDBG
Entitlement Communities in their Housing Needs Assessment and Market Analysis sections of the Plan. In addition, other housing credit
needs are demonstrated in the Broward Housing Council’s Housing Needs Assessment which is currently being updated. Often these
credit needs are not communicated directly with banks who make their own conclusions of what housing credit needs exist (Note: None
of the banks surveyed for this report showed any public data that was collected from the above sources and placed in the CRA Public
Comment File).
In order to provide a better “narrative” of the above recommended data, the Broward Housing Council held a “Housing Credit Needs
Forum” in August 2013; Key housing advocates and stakeholders, developers, government agency representatives and bankers
summarized what they felt were the key housing community credit needs. The following are the highlights of the Housing Credit Needs
Forum:
Monica Navarro, Chair of the Broward Housing Council
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All residents have a right to decent and affordable housing which can result in healthier, sustainable communities
Individually and collectively they are committed to create more housing opportunities
Affordable housing is a basic need, it’s about giving everyone the opportunity to go “home”
People who need affordable housing include teachers, bus drivers, etc.
With a minimum wage income, no one can afford a 2 bedroom apartment
Currently people “Graduate from homelessness to poverty<”
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Need to expand supply of affordable and supportive housing
When counted on one night, 123 households were at risk for homelessness and 65 of them were with children
The lack of affordable housing affects all aspects of someone’s life
Ralph Stone, Director of the Broward County Housing Finance and Community Development Division
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Affordable housing has been under the radar of media
When the recession hit it affected everyone, including renters
107,000 families today are severely cost-burdened: over 50% of income goes towards housing
There are a lot of affordable housing (Low Income Housing Tax Credit) applications coming in, but a very small number
actually receive assistance
Wages are still low, while prices of goods are reasonable although increasing
Majority of population is in the service industry and not able to meet demands of housing costs
South Florida is worst in the nation for moderate-income housing cost burden
Bulk of funding resources are from state/federal programs
o State Housing Initiatives Partnership (SHIP) has been cut by state
Broward does 100 – 200 new rental units a year, when Miami-Dade does 1,000 because of their local documentary stamp tax
Banking community is a key player for affordable housing, we have to make them aware of gaps
Bonnye Deese, Executive Director, Broward Alliance for Neighborhood Development
 Too often families have to pay mortgage insurance premiums for the life of their loan which makes it a lot more expensive in
the end
o Should have more than FHA as an option
 Need more banks to have portfolio (i.e. non-secondary market loans that are booked to the bank’s balance sheet) mortgage
loan products. Gibraltar had a portfolio product, buyers didn’t have to put down 80%
o Housing counseling can help bring up credit scores from the 400/500 range to 600/700 which is beneficial to
homeowner
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o There should be flexibility in underwriting guidelines
 When it comes to maintaining homeownership, the housing counselor is who families come back to when they encounter
issues in life. Housing counseling agencies need more support from banks
o Continuous education and scholarships should be provided
 Collaboration is key
Suzanne Weiss, Deputy Director, Neighborhood Housing Services of South Florida
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291 people have requested services for education and 72 have purchased homes which equates to a 40% success rate
o Realtors have been walking away from first time homebuyers lately
o Sellers are trying to get the best return rate
o Try to close sooner in 45 to 60 days
o Lender personnel need to be more knowledgeable about subsidies which would help expedite process
o Local knowledge should stay local More funding is needed in order to provide any counseling services
o HUD training is daunting and expensive
o Sometimes language becomes a barrier during process, but housing counselors can be a major help
Banks need to look at condo financing, rehab financing, take-out (i.e. permanent financing) strategy for rentals
Amanda Bartle, Executive Director, South Florida Community Land Trust
 Banks should consider non-profit organizations as businesses and lend accordingly. Loans should be based on the merits of
the project. For example, if we were to value Sunland Terrace, a 22-unit rental development, with the current single digit cap
rates and consistent cash flow, it would probably be appraised at $2;4M; Yet, we’ve only been able to receive a $240,000 line
of credit using the property as collateral - 10% of the value. Another example, we are renovating a 16-unit multifamily rental
building, Como Apartments. We are planning $750,000 in renovations, 100% of which are financed through forgivable, nonpayable grants. However, we are only able to get a $210,000 line for construction.
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 There’s a need for banks to underwrite loans locally and offer multiple lending products, including Community Land Trust
loans; recommends initiating a local housing campaign, with each organization (bank, nonprofit, developer, city, businesses,
etc.) committing to a common goal – overall message should be simple, something like “Homes in our Hometown: providing
50,000 affordable units in Broward”
 There is a need to build on the homebuyer education model in Broward County; It’s successful and much more is needed;
 There is a need for a collaborative entity of bankers and government/community representatives to discuss needs and
innovative responses. Banks should consider non-profits as businesses and lend accordingly. Loans should be based on the
merits of the project. For
Marcia Barry Smith, Independent Housing Consultant (former banker)
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Housing needs are being frustrated/stymied by the cookie cutter approach still in effect
We need to reduce the time it is taking to create lender-ready buyers to achieve their goal of homeownership
There has to be Job creation to support the effort of becoming a homeowner
Lenders/organizations are providing education yet lenders aren't stepping up to the plate especially with a portfolio product;
There needs to be more funding made available for pre and post purchase counseling
We need more effective voices in Tallahassee
Ana Castilla, Federal Reserve Bank of Atlanta (Miami Branch)
 Suggested that while there are several working groups focused on housing throughout the county, it may be useful to consider
a few specific work groups that would deal with a specialized area – such as lending – across organizational categories e.g.
bringing together CDFIs, banks, mortgage companies, local, state, federal government, syndicators, etc. to discuss financing
and funding streams.
 Regarding Community Land Trust’s (CLTs): Lenders need to recognize that the CLT culture embraces extensive stewardship;
CLTs are a perfect vehicle for multi-family housing and would keep costs low.
 Why aren't the big banks participating in CLTs in South Florida when they are doing so in other parts of the country?
 Who in Tallahassee is carrying the torch for CLTs?
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Many panelists emphasized the need for banks to come up with local solutions and products/services that don’t rely on FHA and Freddie
Mac/Fannie Mae. Collaborative pooling of funds to underwrite multi-family rental deals would be useful. Another comment focused on
the 4% Low Income Housing Tax Credit Program and how more gap funding and loan products are needed to make the deals work and
help meet the demand for affordable rental housing.
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IV. Home Mortgage Disclosure Act Analysis of Broward County
The majority of lending institutions in United States metropolitan areas are required by the Home Mortgage Disclosure Act (HMDA) of
1975 to collect and publically disclose information about applications, originations and purchases for home loans during each calendar
year. The law is intended to shed light on whether local lenders are adequately serving their communities’ housing finance needs, to
facilitate enforcement of the nation’s fair lending laws, and to guide investment activities in both the public and the private sectors.
In most instances, lenders are required to report data about:
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The loan application, such as the type and amount of the loan application, whether the loan was originated or denied, and, in
limited circumstances, its interest rate;
The property to which the loan relates, such as its type (single-family vs. multi-family) and location (including the census
tract);
The applicant's ethnicity, race, sex, and income; and
The sale of the loan, if it was sold (Federal Reserve Board, 2006).
This section provides a temporal and spatial summary of HMDA data for Broward County Florida from 2004 to 2011 with particular
attention to lending originations by race and ethnicity; During this time period, Broward’s HMDA data reflects the ongoing difficulties
in the housing and mortgage markets that began appearing in 2007 overall. Additionally, patterns of racial and ethnic disparities in terms
of both the number of loans originated and the lending product minority borrowers were approved for is apparent. Before the great
recession there were very high levels of untraditional lending in the form of high cost (sub-prime) and piggyback loans. Moreover, these
less desirable and high-risk loans tended to originate in majority minority communities of African American and Hispanic dominance.
While many of these trends have been reversed and/or subdued due to stricter lending policies following the housing bubble burst the
legacies are still lived daily affecting quality of life and community. Broward County was one of the hardest hit markets in the nation
relative to the negative effects of foreclosures, abandoned properties and limited household financial resources.
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Loan Originations
Broward’s HMDA data reflects the ongoing difficulties in the housing
and mortgage markets that began appearing in 2007. In Broward
County the number of originations peaked in 2005 at 102,758 and
then drastically declined between 2006 and 2008 regardless of race,
ethnicity or income. And while the housing market is seeing a positive
comeback in some regards, originations are still declining. This is
congruent with national trends in which the number of loans in 2011
represented the lowest volume of lending since 1995. In Broward
during 2011, only 21,134 home loans were originated, nearly an 80%
drop from 2005 (Figure 1). Between 2010 and 2011 the sharpest
decline in Broward County was in Roosevelt Gardens near W. Sunrise
Blvd and I-95 where originations dropped nearly 67%. Median loan
amounts are also declining across the County: in 2007 the median
loan origination was $213,000 and in 2011 it was $173,000 (Figure
3).
When broken down by type, 2011 purchase loans originations
dropped more so than refinance loans. This is likely reflective of
interest rate decreases that emerged late in 2011. Over all Broward
saw 51.12% of its loans originated for the purpose of purchasing a
home and 48.88% for refinancing in 2011 whereas in 2007 the
County was seeing much higher proportions of refinances (Figure 2).
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Number of Loans Over Time in
Broward County
120,000
100,000
80,000
60,000
40,000
20,000
0
2004
2005
2006
2007
2008
2009
2010
Figure 1, Originations in Broward County 2004-2011
(Data Source: Policymap)
2011
Loan Originations By Purpose
53%
55%
59%
47%
51%
62%
48%
49%
Refinances
Purchases
47%
45%
41%
38%
2004
2005
2006
2007
49%
53%
52%
51%
2008
2009
2010
2011
Figure 2, Loan Originations by Purpose 2004-2011 (Data Source: Policymap)
Median Loan Amount Over Time
$250,000
$200,000
$150,000
Broward
$100,000
Florida
National
$50,000
$0
2004
2005
2006
2007
2008
2009
2010
Figure 3, Median Loan Amount Over Time, 2004-2011 (Data Source: Policymap)
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2011
Loan Originations by Race and Ethnicity
Looking at loan origination from the viewpoint of race and ethnicity, data shows that in 2011 lending to White borrowers is concentrated
north of I-595 and along the corridor and east of I-95. Parkland and Weston also saw high percentages of White borrowers. The lowest
percentage of lending to White borrowers is in Lauderdale Lakes where conversely, the highest portion of African-American borrowers
are located. Hispanic borrowers of all races see less extreme high and low percentages across the County but in general there are higher
proportions of loan originations for this demographic south of the I-595 corridor.
In general throughout the county, the number of loans made to White borrowers is generally much higher than the number of loans
made to minority populations. For example, in Lighthouse Point, where 192 total loans were originated in 2011, 2 were made to AfricanAmericans and 18 to Hispanics (including White Hispanics); In Pompano where 28% of the population is African-American, only 7% of
originations were for African-American borrowers; and in Fort Lauderdale where 31% of the population is African-American only 5%
of originations were made to African American borrowers. The data shows similar findings in Hispanic lending disparities although to
less extremes. To use Fort Lauderdale again as an example, there is a 14% Hispanic population in the City yet only 10% of the loans
originated in the area were made for this demographic in 2011. Data shows that these are not isolated examples but are reflective of a
broader trend of lending across the County. Of course there are exceptions to the rule as exemplified by Lauderdale Lakes, a largely
African American community, where as noted the majority of lending was originated for African-American borrowers.
Maps 1 through 6 on the following pages detail the percentage of loans made to Whites, African-Americans, and Hispanics by cities as
well as by the actual number of loans made to the corresponding demographic categories. Note that trends are spatially realized which
is reflective the lending patterns following social, economic and demographic patterns of segregation throughout the County.
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Map 1, Number of loans made to Whites 2011
Map 2, Percent of all loans made to Whites, 2011
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Map 4, Number of loans made to African Americans, 2011
Map 3, Percent of all loans made to African Americans, 2011
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Map 6, Number of loans made to Hispanics, 2011
Map 5, Percent of all loans made to Hispanics, 2011
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High Cost Loan Originations
High cost loans, in the past referred to as sub-prime, are defined as such by having a reported rate spread. A rate spread is the difference
between the Annual Percentage Rate (APR) and a survey-based estimate of APRs currently offered on prime mortgage loans of a
comparable type.
In the fourth quarter of 2009, HMDA changed its rules for reporting rate spreads in an effort to more accurately capture the current
high-cost lending activity. Therefore, data shown throughout this section separates the first three quarters of 2009 from the last quarter
of 2009. For 2004-2009Q3, the rate spread on a loan was the difference between the Annual Percentage Rate (APR) on the loan and the
treasury security yields as of the date of the loan's origination. Rate spreads were only reported by financial institutions if the APR was
three or more percentage points higher for a first lien loan, or five or more percentage points higher for a second lien loan. A rate spread
of three or more suggested that a loan was of notably higher cost than a typical loan, indicating that it could be classified as high cost.
The new rules introduced in the fourth quarter of 2009 indicate that the rate spread on a loan is the difference between the Annual
Percentage Rate (APR) on the loan and the estimated average prime offer rate (APOR). With the rule change, rate spreads are only
reported by financial institutions if the APR is more than 1.5 percentage points higher for a first lien loan, or more than 3.5 percentage
points higher for a second lien loan. A rate spread of 1.5 or more suggests that a loan is of notably higher price than a typical loan,
indicating that it is to be classified as high cost.
Likewise, all loans without reported rate spreads are considered to be prime, as the APR is within reasonable range of the treasury
security yield (or, in the case of 2009Q4, 2010 and 2011, within reasonable range of the estimated average prime offer rate). The
Reinvestment Fund (TRF), a community development financial institution and research organization, previously noted high-cost loans
as "subprime", but changed the terminology with the release of the 2008 data to reflect language used by the Federal Reserve Bank.
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In 2011 in Broward County only 2.57% of loans originated were
high-cost loans compared to 2.41% of loans in Florida and 2.8%
nationally. Figure 4 shows that before the Great Recession however,
Broward lenders were providing much higher proportions of highcost loans when compared to both State and National benchmarks.
The legacy of which means that in Broward County more families
today are cash strapped by unaffordable and uncompetitive lending
products that heighten their risk of foreclosure. Map 7 shows the
areas that had higher concentrations of high cost lending in 2011.
These include Lauderdale Lakes, Lauderhill, North Lauderdale and
Broadview Park (notably all majority minority cities).
High-Cost Lending
45%
40%
35%
30%
25%
20%
15%
10%
5%
0%
2004
2005
2006
2007
2008
2009 2009
Q1-Q3 Q4
2010
2011
Map 7, Percent of all loans that were high cost, 2011
Broward
Florida
National
Figure 4, High cost lending 2004-2011
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High-Cost Lending By Race and Ethnicity
Examining high-cost loans originated in 2011 by race and ethnicity in Broward County two perspectives are used. The first looks at the
percent of all loans made to a particular racial or ethnic group that are also high cost while the second only looks at high costs loans and
measures the percent made to the same group. While related, they show two important sides of the analysis.
Map 8 shows that as a percent of all loans, Broadview Park (11%) had a higher than average percent of high cost loans made to White
borrowers in 2011. In general the percent of all high cost loans that were made to Whites have declined since its peak in the Q4 2009.
Similarly, since 2006 the percent of all loans made to Whites that were high cost have declined and are now at relatively steady at 2%
(Figure 5).
In 2011, Deerfield Beach (14%) and Lauderdale lakes (14%) had higher than normal percentages of all loans made to African-American
applicants that were high cost. Across the county and over time, high costs loans were much more common for African-Americans than
White borrowers especially before the great recession. Figure 7 shows that in 2005 and 2006 nearly 55% of all loans made to AfricanAmerican borrowers were high cost and while this number has reduced significantly since then, the proportion of African-American’s
receiving this category of loan is slowly growing again and in 2011 was nearly three times higher than White applicants and two times
higher than Hispanics.
The percent of all loans made to Hispanic borrowers in 2011 was, like for the White population, highest in Broadview Park (42%). Given
the higher proportion, however it can be assumed that the data shown in Map 9 is likely more reflective of high cost lending to White
Hispanics than White Non-Hispanics (the available data doesn’t differentiate however); Figure 6 shows that, similar to African-American
borrowers in Broward County, there were high percentages of Hispanics receiving high cost loan products before the Great Recession
and housing bubble burst.
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Figure 5, High cost lending to Whites 2004-2011
Map 8, Percent of loans to White applicants that were high cost 2011
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50%
45%
40%
35%
30%
25%
20%
15%
10%
5%
0%
Percent of all loans to Hispanics that were high
cost
Percent of all high cost loans that were made to
Hispanics
Map 9, Percent of all loans to Hispanic Applicants that were high cost 2011
Figure 6, High cost lending to Hispanics 2004-2011
25
60%
45%
30%
15%
0%
2004
2005
2006
2007
2008
2009 2009
Q1-Q3 Q4
2010
Percent of all loans to African Americans that were high
cost
Percent of all high cost loans that were made to African
Americans
Map 10 Percent of all loans to African-Americans that were high cost
Figure 7, High Cost Lending to African-Americans 2004-2011
26
2011
Piggyback Loans
Policy Map contains thematic data on the
number of loans originated for the purpose of a
home purchase that had multiple mortgages.
Termed "80-20 loans" or "piggyback loans", a
multiple mortgage transaction is when a buyer
obtains at least two loans in order to purchase a
home. The second loan finances that part of the
purchase price not being financed by the first
loan. The 80-20 or piggyback loan has been used
to avoid underwriting standards held by most
lenders that require private mortgage
insurance (or PMI) when less than a 20% down
payment is made by the buyer. Studies suggest
that these transactions have a higher risk of
default and foreclosure as the homebuyers have
little or no equity at risk.
100%
90%
80%
70%
Piggyback Loans as a percent
of all purchase loans
60%
50%
Prime Piggybank Loans as a
percent of all purchase loans
40%
High Cost Piggybank Loans as
a Percent of all purchase loans
30%
20%
HMDA data does not explicitly identify 80-20 or
piggyback loans therefore the Reinvestment
Fund (TRF) created an algorithm for estimating
transactions involving multiple loans to
purchase a property. First- and second-position
loans in the same census tract, from the same
lender, and to applicants with the same race,
ethnicity, gender, and income were flagged as
multiple loans for the same property. These
10%
0%
Figure 8, Piggyback Loans-2011
27
loans were then combined into one record, the loan amounts summed, thus reflecting the total loan for the property transaction. These
loans were originated for the purchase of an owner-occupied, one-to-four family dwelling, as reported by HMDA.
In Broward County in 2011, there were only 11 piggyback loans originated for the purchase of a home and only one that was a high cost
piggyback loan. The remaining 10 were prime loans (defined as loans with no reported rate spread). In 2011 the typical piggyback loan
for the purchase of a home was for $497,000, and made up only 0.1% of purchase loans made here. Across all purchase loans, the median
purchase loan amount was much smaller, for $172,000. This is in contrast to the years prior to the housing bubble. In 2006, there were
almost 11,000 (or nearly 30%) purchase loans made in Broward County that were piggyback loans and 80% of these were high-cost
piggybank loans (Figure 8).
28
Methodology
All data and mapping for this report was obtained from Policy Map, an online mapping and data analysis tool utilizing Home Mortgage
Disclosure Act (HMDA) data for 2004 through 2011. HMDA, enacted by Congress in 1975, requires most mortgage lenders located in
metropolitan areas to collect data about their housing-related lending activity, report the data annually to their regulators, and make the
data publicly available. The public database of lending activity is called the Loan Application Register and Transmittal Sheets (LARS &
TS). The Reinvestment Fund (TRF) aggregated originated purchase and refinance loans for owner-occupied, one-to-four family
dwellings, in order to construct categories that would be useful to policymakers and descriptive of neighborhoods and markets, such as
Prime Refinance Loans, or Purchase Loans to African-Americans.
Data in this report include originated loans made for the purchase and refinance of owner-occupied, one-to-four family dwellings, or,
where specified, for the purchase or refinance of manufactured housing. When performing aggregations and calculations on the HMDA
data, medians were not calculated and percentages were not computed where the count of loan events of that type or the denominator
of the calculation was less than five. These places are identified on the map as having Insufficient Data. If a cell in a table contains N/A,
the data are not available or have been suppressed according to these rules.
Further description of the source of the data can be found at the HMDA website (http://www.ffiec.gov/hmda/).
29
HMDA Policy Map Data Tables:
ALL ORIGINATIONS
2004
2005
2006
2007
2008
2009
2010
2011
98,096
$156,000
102,758
$190,000
88,940
$211,000
55,330
$213,000
22,651
$197,000
21,943
$180,000
21,777
$178,000
21,134
$173,000
789,869
$136,000
905,156
$165,000
812,598
$183,000
519,263
$184,000
257,847
$167,000
262,505
$156,000
240,933
$151,000
231,618
$146,000
11,746,438
$147,000
11,559,564
$161,000
10,070,623
$163,000
7,742,076
$168,000
5,611,779
$170,000
7,757,819
$176,000
6,743,289
$175,000
5,917,574
$168,000
Broward
Number of all loans
Median loan amount
Florida
Number of all loans
Median loan amount
National
Number of all loans
Median loan amount
PURCHASES
2004
2005
2006
2007
2008
2009
2010
2011
46,316
$175,000
47.21%
46,072
$215,000
44.84%
36,822
$235,000
41.4%
20,987
$237,000
37.93%
11,052
$209,500
48.79%
11,660
$172,000
53.14%
11,426
$170,000
52.47%
10,803
$172,000
51.12%
392,988
$152,000
49.75%
433,737
$185,000
47.92%
363,143
$205,000
44.69%
214,639
$201,000
41.34%
127,959
$175,000
49.63%
120,484
$148,000
45.9%
116,208
$144,000
48.23%
111,685
$144,000
48.22%
4,879,019
$156,000
41.54%
5,146,333
$170,000
44.52%
4,667,928
$174,000
46.35%
3,524,874
$176,000
45.53%
2,562,011
$174,000
45.65%
2,413,549
$164,000
31.11%
2,181,851
$168,000
32.36%
2,037,856
$166,000
34.44%
Broward
Number of all loans
Median loan amount
Percent of all loans
Florida
Number of all loans
Median loan amount
Percent of all loans
National
Number of all loans
Median loan amount
Percent of all loans
30
REFINANCES
2004
2005
2006
2007
2008
2009
2010
2011
51,780
$141,000
52.79%
56,686
$175,000
55.16%
52,118
$198,000
58.6%
34,343
$200,000
62.07%
11,599
$185,000
51.21%
10,283
$186,000
46.86%
10,351
$187,000
47.53%
10,331
$174,000
48.88%
396,881
$121,000
50.25%
471,419
$150,000
52.08%
449,455
$165,000
55.31%
304,624
$170,000
58.66%
129,888
$160,000
50.37%
142,021
$164,000
54.1%
124,725
$159,000
51.77%
119,933
$150,000
51.78%
6,867,419
$140,000
58.46%
6,413,231
$155,000
55.48%
5,402,695
$153,000
53.65%
4,217,202
$160,000
54.47%
3,049,768
$165,000
54.35%
5,344,270
$183,000
68.89%
4,561,438
$179,000
67.64%
3,879,718
$170,000
65.56%
Broward
Number of all loans
Median loan amount
Percent of all loans
Florida
Number of all loans
Median loan amount
Percent of all loans
National
Number of all loans
Median loan amount
Percent of all loans
HIGH-COST LENDING
2004
2005
2006
2007
2008
2009 Q1-Q3
2009 Q4
2010
2011
20,009
$143,000
20.4%
35,620
$185,000
34.66%
35,714
$217,000
40.16%
14,900
$221,000
26.93%
2,243
$169,000
9.9%
920
$132,000
4.82%
80
$131,000
2.81%
481
$108,000
2.21%
544
$127,000
2.57%
144,675
$122,000
18.32%
279,838
$159,000
30.92%
292,815
$184,000
36.03%
118,535
$185,000
22.83%
22,355
$139,000
8.67%
10,044
$119,000
4.37%
911
$103,000
2.77%
5,615
$102,000
2.33%
5,593
$108,000
2.41%
1,709,639
$116,000
14.55%
2,909,619
$145,000
25.17%
2,827,156
$152,000
28.07%
1,364,023
$144,000
17.62%
556,800
$107,000
9.92%
311,065
$103,000
4.53%
23,951
$81,000
2.67%
145,203
$88,000
2.15%
163,776
$99,000
2.77%
Broward
Number of all loans
Median loan amount
Percent of all loans
Florida
Number of all loans
Median loan amount
Percent of all loans
National
Number of all loans
Median loan amount
Percent of all loans
31
HIGH COST LENDING BY LOAN TYPE
2004
2005
2006
2007
2008
2009 Q1-Q3
2009 Q4
2010
2011
9,197
$157,000
19.86%
16,905
$210,000
36.69%
17,865
$239,000
48.52%
6,309
$247,000
30.06%
1,227
$171,000
11.1%
621
$129,000
6.28%
55
$133,000
3.1%
307
$107,000
2.69%
367
$128,000
3.4%
10,812
$131,000
20.88%
18,715
$168,000
33.02%
17,849
$198,000
34.25%
8,591
$203,000
25.02%
1,016
$166,500
8.76%
299
$137,000
3.25%
25
$113,000
2.33%
174
$111,000
1.68%
177
$122,000
1.71%
PURCHASE
Number of all loans
Median loan amount
Percent of purchase loans
REFINANCE
Number of all loans
Median loan amount
Percent of refinance loans
32
HIGH COST LENDING BY RACE AND ETHNICITY
2004
2005
2006
2007
2008
2009 Q1-Q3 2009 Q4
2010
2011
10,330
$149,000
16.24%
51.63%
19,930
$192,000
29.18%
55.95%
19,502
$224,000
35.02%
54.61%
8,255
$225,000
23.52%
55.4%
1,349
553
$172,000 $132,000
8.71%
3.97%
60.14%
60.11%
62
$128,000
2.97%
77.5%
324
$125,500
2.06%
67.36%
337
$146,000
2.17%
61.95%
5,861
$138,000
34.75%
29.29%
10,402
$178,000
54.72%
29.2%
11,133
$210,000
55.04%
31.17%
4,770
$216,000
40.32%
32.01%
616
$168,000
17.27%
27.46%
240
$128,000
10.83%
26.09%
12
$135,000
3.25%
15%
128
$82,500
4.69%
26.61%
163
$110,000
6.28%
29.96%
277
$159,000
12.81%
1.38%
582
$206,500
25.35%
1.63%
473
$245,000
29.14%
1.32%
203
$228,000
18.34%
1.36%
28
$146,500
4.49%
1.25%
18
$140,500
3.08%
1.96%
2
N/A
1.94%
2.5%
6
$135,500
0.83%
1.25%
8
$74,000
1.15%
1.47%
5,076
$150,000
22.73%
25.37%
10,188
$195,000
40.46%
28.6%
11,342
$228,000
46.67%
31.76%
4,464
$232,000
31.62%
29.96%
600
$176,000
12.54%
26.75%
196
$137,000
5.64%
21.3%
31
$133,000
5.44%
38.75%
132
$113,500
3.19%
27.44%
147
$127,000
3.44%
27.02%
11,663
$143,000
19.76%
58.29%
21,437
$184,000
32.77%
60.18%
20,936
$213,000
37.74%
58.62%
9,083
$217,000
25.84%
60.96%
1,432
$166,000
9.32%
63.84%
626
$128,500
4.64%
68.04%
44
$105,000
2.18%
55%
330
$106,000
2.14%
68.61%
371
$128,000
2.49%
68.38%
Loans to Whites
Number of all loans
Median loan amount
Percent of ALL loans
Percent of all HIGH COST loans
Loans to African Americans
Number of all loans
Median loan amount
Percent of ALL loans
Percent of all HIGH COST loans
Loans to Asians
Number of all loans
Median loan amount
Percent of ALL loans
Percent of all HIGH COST loans
Loans to Hispanics
Number of all loans
Median loan amount
Percent of ALL loans
Percent of all HIGH COST loans
Loans to Non- Hispanics
Number of all loans
Median loan amount
Percent of ALL loans
Percent of all HIGH COST loans
33
Purchase Originations by Type
2004
2005
2006
2007
2008
2009 Q1-Q3 2009 Q4
2010
2011
All Purchase
Number of all loans
Median loan amount
Percent of all loans
46,316
46,072
36,822
20,987
11,052
11,660
$175,000 $215,000 $235,000 $237,000 $209,500 $172,000
47.21%
44.84%
41.4%
37.93%
48.79%
53.14%
----
11,426
10,803
$170,000 $172,000
52.47%
51.12%
High Cost Purchase
Number of all loans
9,197
16,905
17,865
6,309
1,227
621
Median loan amount
$157,000 $210,000 $239,000 $247,000 $171,000 $129,000
Percent of purchase loans 19.86%
36.69%
48.52%
30.06%
11.1%
6.28%
55
307
367
$133,000 $107,000 $128,000
3.1%
2.69%
3.4%
Prime Purchase
Number of all loans
37,119
29,167
18,957
14,678
9,825
9,262
Median loan amount
$180,000 $219,000 $229,000 $232,000 $215,000 $176,000
Percent of purchase loans 80.14%
63.31%
51.48%
69.94%
88.9%
93.72%
1,722
11,119
10,436
$172,000 $172,000 $174,000
96.9%
97.31%
96.6%
Piggyback Loans
2004
2005
2006
2007
2008
2009 Q1-Q3 2009 Q4 2010
2011
Total
Number of all loans
Median loan amount
Percent of all loans
5,221
10,186
$270,000 2,841
159
7
$195,000 $240,000 29.43%
$287,000 $421,000 $219,000
11.27%
22.11%
8,582
13.54%
1.44%
0.06%
----
9
11
$615,000 $497,000
0.08%
0.1%
0
N/A
0%
1
N/A
11.11%
0
N/A
0%
8
10
$599,000 $488,500
88.89%
90.91%
High Cost Piggyback Loans
Number of all loans
3,345
7,997
10,837
1,646
27
0
Median loan amount
$182,000 $235,000 $266,000 $280,000 $432,000 N/A
Percent of purchase loans 64.07%
78.51%
79.19%
57.94%
16.98%
0%
1
N/A
9.09%
Prime Piggyback Loans
Number of all loans
1,876
2,189
2,255
1,195
132
7
Median loan amount
$228,500 $270,000 $280,000 $309,000 $420,000 $219,000
Percent of purchase loans 35.93%
21.49%
20.81%
42.06%
83.02%
100%
34
V. Broward Banks Performance Evaluations and Public Comment Files
In the Appendix of this report, is a comprehensive listing of all 57 financial institutions in the county comprised of 32 large banks, 12
intermediate small banks, and 13 small banks (See Appendix 2 Database of all Broward Banks, available on the Broward Housing Council
website - http://www.broward.org/browardhousingcouncil/). Each bank listed has a hyperlink to their latest CRA Performance
Evaluation (see Page 4) as well as a listing of all their branches and deposits for each branch. In addition, the Appendix provides further
information on the largest 14 banks in the market with well over 90% of the deposits in the Broward market. This additional information
includes excerpts from the bank’s latest Performance Evaluation related to Broward County and housing, CRA Public Comment File
entries related to Broward County and housing, and additional information that each of these banks were requested to provide related
to their view of credit needs and/or other pertinent information related to Broward County and housing.
The following matrix provides an overview of each large bank in Broward County with overall CRA rating system-wide and overall CRA
rating for Florida operations. There is no CRA rating given for the Broward market. Individual ratings for the three required “tests” –
Lending, Investment and Service (see Pages 5 and 6) – are also provided both for the overall CRA rating for the institution as well as the
CRA Rating for Florida. In addition, each entry provides the date of the Performance Evaluation as well as the percentage of market
share in Broward County.
35
Large Banks in Broward County – Market Share and CRA Performance Evaluations
BANK
Banco Popular North
America
Bank of America
Bankunited, National
Association
BB&T
County
Market
Share
based on
Deposits
(as of
June 30,
2012)
CRA Rating for Institution
CRA Rating for Florida
Evaluation
Date
Investment
Test
Overall
Lending Test
0.09%
Satisfactory
Low Satisfactory
23.90%
Outstanding
Outstanding
Low
Satisfactory
Outstanding
4.16%
Satisfactory
High Satisfactory
Outstanding
Overall
Lending Test
Outstanding
Satisfactory
Low Satisfactory
Outstanding
High
Satisfactory
Outstanding
High Satisfactory
Low
Satisfactory
Outstanding
Satisfactory
High Satisfactory
Outstanding
High Satisfactory
High
Satisfactory
2.29%
Outstanding
High Satisfactory
Outstanding
Outstanding
0.15%
Satisfactory
High Satisfactory
High
Satisfactory
6.47%
Outstanding
Outstanding
Outstanding
Low
Satisfactory
High
Satisfactory
0.32%
Outstanding
Outstanding
Outstanding
CNLbank
0.12%
Satisfactory
Low Satisfactory
Comerica Bank
0.15%
Outstanding
Everbank
0.32%
Fifth Third Bank
0.15%
Capital Bank, National
Association
Citibank, National
Association
City National Bank Of
Florida
Investment
Test
Service Test
Satisfactory
Service Test
Outstanding
5/31/11
Outstanding
High
Satisfactory
High
Satisfactory
3/31/09
No data presented in CRA exam for Florida activities.
10/9/12
5/23/11
11/15/10
Outstanding
Outstanding
Outstanding
High
Satisfactory
7/26/10
Outstanding
Outstanding
Outstanding
Outstanding
Outstanding
5/29/12
Low
Satisfactory
High
Satisfactory
Satisfactory
Low Satisfactory
High
Satisfactory
7/25/11
Outstanding
Outstanding
Outstanding
Satisfactory
High Satisfactory
Outstanding
8/16/10
Satisfactory
High Satisfactory
High
Satisfactory
Satisfactory
High Satisfactory
Satisfactory
High Satisfactory
Outstanding
High
Satisfactory
High
Satisfactory
Low
Satisfactory
High
Satisfactory
High
Satisfactory
Satisfactory
Low Satisfactory
Outstanding
High
Satisfactory
High
Satisfactory
Low
Satisfactory
4/30/12
11/14/12
0.18%
Low
Low
Satisfactory
High Satisfactory
Outstanding
Satisfactory
Low Satisfactory
Satisfactory
Satisfactory
Low
High
Satisfactory
High Satisfactory
No data presented in CRA exam for Florida activities.
Satisfactory
Satisfactory
Last CRA exam was before bank failed in Jan. 2010 - rebuilt and now owned by Bond Street Holdings
Gibraltar Private Bank &
Trust Co.
0.21%
Outstanding
Outstanding
High
Satisfactory
Outstanding
Outstanding
Outstanding
High
Satisfactory
Outstanding
5/5/10
Great Florida Bank
1.08%
Satisfactory
High Satisfactory
High
Satisfactory
Outstanding
Satisfactory
High Satisfactory
High
Satisfactory
Outstanding
10/24/11
Firstbank Of Puerto Rico
First-Citizens Bank & Trust
Company
Florida Community Bank
2.90%
0.15%
36
8/7/12
10/19/09
Large Banks in Broward County – Market Share and CRA Performance Evaluations
BANK
HSBC Bank
County
Market
Share
based on
Deposits
(as of June
30, 2012)
1.80%
CRA Rating for Institution
Overall
Outstanding
Lending Test
CRA Rating for Florida
Investment
Test
Outstanding
Outstanding
Iberiabank
0.24%
Satisfactory
Low Satisfactory
High
Satisfactory
JP Morgan Chase
6.15%
Satisfactory
High Satisfactory
Outstanding
Mercantile
0.37%
Outstanding
Outstanding
Outstanding
New York Community
Bank
High
Satisfactory
Low
Satisfactory
High
Satisfactory
3.07%
Satisfactory
Low Satisfactory
Ocean Bank
0.21%
Satisfactory
Low Satisfactory
PNC Bank, National
Association
0.72%
Outstanding
Outstanding
Regions Bank
2.14%
Satisfactory
High Satisfactory
Outstanding
Sabadell
0.25%
Outstanding
Outstanding
Outstanding
Overall
High
Satisfactory
Low
Satisfactory
High
Satisfactory
High
Satisfactory
Needs to
Improve
Low
Satisfactory
High
Satisfactory
Low
Satisfactory
High
Satisfactory
Low
Satisfactory
Low
Satisfactory
High
Satisfactory
Stearns National Bank
0.16%
Satisfactory
Low Satisfactory
Low
Satisfactory
SunTrust Bank
6.60%
Satisfactory
High Satisfactory
Outstanding
2.25%
Outstanding
Outstanding
Outstanding
1.77%
Outstanding
Outstanding
Outstanding
Outstanding
Third Federal Savings
0.65%
Satisfactory
High Satisfactory
U.S. Century Bank
0.32%
Satisfactory
Low Satisfactory
Wells Fargo
20.05%
Outstanding
Outstanding
High
Satisfactory
Low
Satisfactory
Outstanding
High
Satisfactory
High
Satisfactory
Outstanding
TD Bank, National
Association
The Northern Trust
Company
Lending Test
Service Test
37
Outstanding
Investment
Test
Outstanding
Outstanding
Needs to
Improve
Needs to Improve
Needs to
Improve
Outstanding
Outstanding
Outstanding
left blank
Outstanding
Outstanding
Needs to
Improve
Low
Satisfactory
Low
Satisfactory
High
Satisfactory
Needs to Improve
Satisfactory
Low Satisfactory
Satisfactory
Low Satisfactory
Satisfactory
High Satisfactory
Outstanding
Outstanding
Outstanding
Outstanding
Low
Satisfactory
Low Satisfactory
Needs to
Improve
Satisfactory
High Satisfactory
Outstanding
Outstanding
Outstanding
Outstanding
Service Test
High
Satisfactory
Low
Satisfactory
High
Satisfactory
High
Satisfactory
Needs to
Improve
Low
Satisfactory
Low
Satisfactory
Low
Satisfactory
High
Satisfactory
Low
Satisfactory
Low
Satisfactory
Outstanding
No data presented in CRA exam for Florida activities.
Low
Satisfactory
Low
Satisfactory
Low Satisfactory
Satisfactory
No data presented in CRA exam for Florida activities
Satisfactory
Low Satisfactory
Evaluation
Date
10/5/09
6/13/11
12/31/10
1/26/10
3/14/11
5/2/11
9/30/09
6/14/10
7/12/10
11/7/11
10/12/10
12/31/11
5/10/10
Low
Satisfactory
High
Satisfactory
1/17/12
8/2/10
9/30/08
VI. Assessment of Broward Housing Council Work Program vs. Bank CRA Activities
The Broward Housing Council has adopted the following items as areas of emphasis in its 2014 Broward County Housing Council Work
Program. Banks play a critical role in implementing many of the action items that serve as a strategic plan framework for increasing
affordable housing in Broward Council.
Item I: Education and Advocacy
A. Continue and encourage all entitlement communities to fund foreclosure counseling and assistance strategies.
B. Support Homebuyer Education courses through HUD Certified Counseling Agencies for programs supported with local,
state and federal affordable housing funds.
C. Continue to educate municipalities, local business leaders, and legislative leaders on affordable housing issues.
D. Forward 2014 Broward County Affordable Housing Needs Assessment study to all municipalities and the Legislative
Delegation.
Assessment: Banks must provide evidence of providing “service” under the CRA Performance Evaluation test along with “lending” and
“investment;” Part of the service test is the support of education and advocacy efforts; While many of the large banks provide some
financial and in-kind support for counseling and education courses, there is a strong need for improvement in funding organizations that
provide such services in addition to banks conducting more counseling and homebuyer education sessions on their own.
There is little evidence that banks play any role in educating municipalities, local business leaders and legislative leaders on affordable
housing issues. While there are three organizational entities that focus on educating and advocating for affordable housing (Broward
Housing Partnership, Broward Housing Council, and Broward Alliance for Neighborhood Development), only a handful of Board seats
are held by bankers and funding support is minimal.
No bank cited in their Performance Evaluation or CRA Public Comment File, the 2011 Broward County Affordable Housing Needs
Assessment study.
38
Item II: Legislation
A. Support retaining the funding for State Housing Initiatives Partnership (SHIP) program.
B. Support establishing a Local Documentary Stamp Tax program based on the Miami-Dade model.
Assessment: None of the banks have indicated through their Performance Evaluation or Public Comment File, support for funding of
the SHIP Program or for establishing a local Documentary Stamp Tax program.
Item III: Foreclosure Counseling and Education
A. Continue and encourage foreclosure counseling workshops throughout Broward County by local nonprofit HUD certified
Housing Counseling Agencies and local banks.
B. Support training for foreclosure counselors.
Assessment: See Assessment under Item I.
Item IV: Provide New Affordable Multi-Family Rental Units
A. Prioritize resources for new multi-family development.
B. Create flexible sources of “gap financing” for new multi-family development.
C. Support local government and private sector funding, including but not limited to: youths transitioning out of foster care,
special needs population, veterans, and families.
D. Recommend Florida Housing Finance Corporation (FHFC) increase the 250 set-aside of units for Broward County tax credit
projects.
E. Recommend FHFC award projects based on the greatest needs vs. project driven.
Assessment: Based on CRA Performance Evaluations and CRA Public Comment Files, there is minimal lending and/or investment
activity in creating new affordable multi-family rental units; From Broward banks, there are no flexible sources of “gap financing” for
new affordable multi-family development.
39
Item V: Homelessness: Rapid Re-Housing/Supportive Housing
A. Encourage entitlement communities to jointly or individually fund projects that add new transitional and/or permanent
supportive housing.
B. Evaluate the number of “net” new units of transitional and/or permanent supportive housing;
C. Net reduction in the number of unsheltered homeless persons as indicated in the 2014 Homeless Point In Time count.
Assessment: Based on CRA Performance Evaluations and CRA Public Comment Files, there is no evidence of banks financing transitional
and/or supportive housing.
Item VI: Community Reinvestment Act (CRA) Activities by Banks in Broward County Follow-Up
To be determined
Assessment: This report is the key initial implementation step to better understand how Broward banks serve the housing credit needs
and to provide recommendations for future activities.
Item VII: Assessment of the Countywide Affordable Housing Land Use Plan Policy 1.07.07
To be determined
Assessment: Not applicable
Item IX: Maintain the Broward Housing Council Website and Quarterly Newsletter
A. The website shall include, but not be limited to, the following elements:
a. Federal, state and local housing agency’s links
b. Federal, state and local training opportunities (public and private)
c. Federal, state and local funding and resource information
d. Broward County entitlement communities' Consolidated Plans, Annual Action Plans, and Local Housing Assistance
Plans
40
e. Request for Proposals (RFP) for affordable housing strategies
f. Nonprofit, for-profit and foundation affordable housing activities/opportunities
g. Policy and Data Research
h. Best Practices at the local, state and federal level
B. Prepare quarterly newsletter to be distributed via e-mail.
Assessment: Not applicable.
Item X: Produce the Housing Council Annual Report
A. Production and funding for homeownership.
B. Resources and clients for foreclosure counseling.
C. Production and funding for home repair.
D. Production and funding for barrier-free/special needs populations.
E. Production and funding for multi-family rental.
F. Report on all Housing Council Work Program activities.
G. Report on total units and funding for the Housing Authorities.
H. Add success case studies.
Assessment: Not applicable.
41
VII. Summary of Findings
Most of the large banks’ Performance Evaluations that were examined more closely provided little up-to-date information relative to
Broward performance. Many of these banks have markets and community lending assessment areas that stretch across multiple regions
and states. The Performance Evaluations are limited in their review of the Broward market and the banks’ performances; Also, many of
the banks are new to the Broward market e.g. BB&T, TD Bank, PNC, Chase and thus their Performance Evaluations are limited to regions
and areas where they already had considerable market presence. The researchers reached out to the 14 largest banks and requested
information in their CRA Public Comment File related to Broward County and housing. No bank was able to provide any information
from this File including most recent CRA Performance Evaluation (public section), list of current branches, list of services at branches, a
map of their assessement area, and information on loans. Either the public (including government agencies and non-profit organizations
are unaware of the File) or the banks have been ignoring the requirement. Finally, all large banks surveyed were asked if they would
like to provide further data relative to their performance and assessment of community (housing) credit needs in Broward County and
the response was tepid.
The minimal data that was provided through these reports mostly provided Home Mortgage Disclosure data for lending to single family
homeowners. The researchers have completed a more thorough analysis of home mortage lending data detailed in Section IV. Scant
data or evidence was provided to “innovative and creative qualified community investments” leading to the conclusion that little
emphasis is placed by Broward banks on investments in Broward County and affordable housing.
1. The Broward banking market with 57 financial institutions, many of them the largest in the country, is a significant one that is
rapidly expanding branches, products and services.
2. All banks in Broward have received a CRA Performance Evaluation rating of “Outstanding” or “Satisfactory;”
3. The Broward banking market has recently stabilized after the tumultuous Economic Recession of 2008 to 2013 with many new
instititions that have greatly expanded or have taken over failing or failed instittuions.
4. While Performance Evaluation is relatively available on regulatory web sites, these Evaluations often provide little data or
information that is applicable to Broward County market needs and responses.
5. None of the largest 14 banks utilize the CRA Public Comment File
42
6. Innovative and creative responses particularly for “CRA Investments” are rare and overall community development lending and
investment relative to affordable housing production is extremely limited.
7. Home mortgage loan originations are rising but still pale in comparison to pre Economic Recession activity.
8. Lending to African American and Hispanic borrowers indicates a significant disparity from the percentage of home mortgage
originations to Whites borrowers.
9. High-cost loans (i.e. subprime) have dropped dramatically since 2007 however the higher concentration of such loans persists in
minority areas and communities.
10. Most significant housing credit needs include more homebuyer education and counseling services, affirmative marketing of
mortgage products to low and moderate income communities, lines of credit for non-profit housing organizations, creation of
community land trust mortgage products, gap financing for multifamily rental transactions especially those utilizing 4% Low
Income Housing Tax Credits and equity investments in collaborative funds for housing development.
43
VIII. Broward CRA Recommendations
The Community Reinvestment Act is a powerful tool to bring banks together with government and the community to leverage public and
private investments that generate wealth and stability to working class neighborhoods. However, as banks have consolidated and grown,
and CRA assessments cover larger areas, it is incumbent upon the community and government to ensure that the CRA remains effective
and that those banks meet the ongoing needs of Broward’s low- and moderate-income communities and persons.
As a whole, this reports provides evidence of concern by the overall level of investment level of housing lending and investment. Robust
and consistent community development lending, investments, and services are critical to sustaining and improving the strong, vibrant,
diverse communities of Broward County. These banks can and should be doing more to ensure that our communities thrive. All banks
should commit to increasing its percentage of local deposits to the full range of targeted, strategic reinvestment lending and investments
for housing especially to low- and moderate-income persons and communities.
The following is a list of recommendations to help improve the overall community reinvestment performance of financial institutions in
Broward County:
Bank and Community Relations
A. Broward Housing Council: Provide a copy of the Broward Housing Council Work Program Report to each bank in Broward
County and request that the reports be placed on their CRA Public Comment File.
B. Broward Housing Council: Provide a copy of the Broward CRA Report to each bank in Broward County and request that the
reports be placed on their CRA Public Comment File.
C. Broward Housing Council: Provide copies of Consolidated Plans from Broward County and CDBG Entitlement Communities
including the Broward County Housing Needs Assessment/Market Analysis and the Broward Ten-Year Plan to End
Homelessness to each bank in Broward County and request that the reports be placed on their CRA Public Comment File.
D. Broward Housing Council: Provide copies of all reports (A-C) to the three bank regulatory agencies for inclusion on all CRA
Performance Evaluations for banks in Broward County and to the State of Florida Chief Financial Officer.
44
E. Broward Housing Council: Conduct a joint workshop between the Housing Council and the 14 largest banks to define
strategies for linking CRA activities with countywide affordable housing needs.
F. Broward Housing Council: Create a permanent Community and Banking Council to continue to monitor and evaluate bank
CRA performance, discuss issues, problems, challenges and opportunities and identify solutions.
Legislation
A. Broward County: The proposed Community and Banking Council should review and advise regarding affordable housing
legislation.
B. Broward County: Draft a County Linked Deposit ordinance that would require financial institutions receiving County deposits
to implement recommendations of this report
Residential Lending
A. Financial institutions: Encourage the creation of first-time homebuyer products with higher loan-to-value ratios
B. Financial institutions: Encourage the creation of mortgage loan products for community land trust homebuyers
C. Financial institutions: Affirmatively market mortgage products to low- and moderate-income communities and individuals
Homebuyer counseling
A. Financial institutions: Provide grants to homebuyer counseling agencies
B. Financial institutions: Create linkages to homebuyer counseling agencies and CRA home mortgage products including
community land trust loans, first-time homebuyer loans, portfolio loans and other customized loan products for low- and
moderate income homebuyers
C. Financial institutions: Create and/or expand homebuyer counseling programs and initiatives
Multifamily lending and investment
A. Financial institutions: Banks with distressed multifamily loans should implement a first look program to transfer distressed
properties to affordable housing developers.
B. Financial institutions: For the development of affordable housing (30 to 80% of AMI), transitional and permanent supportive
housing for homeless people:
45
1.
2.
3.
4.
5.
Banks should provide construction and/or permanent debt financing
Banks should make Low-Income Housing Tax Credits Investments
Banks should make investments in pre-development or acquisition loan funds
Banks should work collaboratively with government agencies in developing a mechanism to address “gap financing needs
Banks should make Equity Equivalent loans (EQ2 – a long-term deeply subordinated loan with features that make it
function like equity) with nonprofit housing development organizations and community development financial
institutions (CDFI’s);
Community Development Investing
A. Financial institutions: Increase the volume of innovative community development investing in Broward County including
grant-making, purchasing stock or loans from community development financial institutions (CDFIs), and equity investments
in affordable housing loan consortia with more flexible lending criteria, tax-credit equity funds and transit-oriented
development investment funds that include mixed-income housing
B. Financial institutions: Create an Investment Fund capitalized by Broward banks that can invest in low income housing taxcredit projects with flexible and innovative financing to help reduce gaps
C. Financial institutions: Establish lines of credit for affordable housing non-profits to support their community development
activities.
Acquisition and Home Rehabilitation
A. Financial institutions: Banks should offer loan products for acquiring distressed properties and home repair loans.
Foreclosures
A. Financial institutions: Provide and increase funding support to HUD-certified Counseling Agencies
B. Financial institutions: Provide workshops and support for foreclosure counseling and education
C. Financial institutions: Provide lines of credit to non-profit housing organizations to purchase foreclosed properties from
banks and other lenders
D. Financial institutions: Provide refinance loans to those who don’t qualify for loan modifications, to lower monthly payments
and stay in their homes
46
Report Dissemination
A. Broward Housing Council: “The Community Reinvestment Act, Bank Performance in Housing Lending and Investment in
Broward County” report should be placed on the Broward Housing Council website.
B. Broward Housing Council: To facilitate future interaction, create a searchable and interactive database on the Council’s
website for each bank and CRA contact person to facilitate bank communication between the bank and government and nonprofit agencies and community residents concerning CRA issues, needs and opportunities
C. Broward Housing Council: “The Community Reinvestment Act, Bank Performance in Housing Lending and Investment in
Broward County” report should be part of the Housing Council Annual Report
47
IX. APPENDIX
Table of Contents
CRA Information and Data for 14 Largest Financial Institutions in Broward Market
49
Largest 14 banks – Information and Performance Evaluations:
Florida Community Bank, National Association
BankUnited, National Association
Citibank, National Association
City National Bank of Florida
Comerica Bank
Fifth Third Bank
HSBC Bank USA, National Association
JPMorgan Chase Bank, National Association
PNC Bank, National Association
Sun Trust Bank
TD Bank, National Association
Wells Fargo Bank, National Association
Bank of America
Northern Trust
51
58
62
66
75
79
89
92
97
99
102
105
108
110
48
CRA Information and Data for 14 Largest Financial Institutions in Broward Market
The following is CRA data and information collected from the 14 largest financial institutions operating in the Broward County market.
These banks have over 90% of the market share of deposits of all banks. The information was collected by reviewing the most recent
Performance Evaluation (i;e; CRA examination) of each institution, a request for copies of all information in the institution’s Public
Comment File and a request for any other pertinent Broward County CRA performance and market assessment information that the
Bank wished to share.
While Performance Evaluations are useful in understanding a bank’s response to local credit needs, they are often constrained by the
following factors:
1. Banks are often evaluated every three to five years thus data and performance information is out of date or not relevant to current
economic conditions and needs.
2. The economic crisis of the last six years has taken its toll on a number of institutions that have been merged or acquired e.g
Washington Mutual is now JP Morgan Chase, BankAtlantic is now BB&T, etc.
3. Many of the large banks in the county are based in other states and have multi-state market assessment areas, thus much of the
Performance Evaluation is not relevant to their performance in Broward County. The report only reviews sections of the
Performance Evaluation that pertain to the local market.
None of the banks received a CRA Rating below “Satisfactory;”
The report researchers also contacted all 14 banks and requested copies of their CRA Public Comment File. None of the banks supplied
any information relative to the Public Comment File. They either cited that there was nothing in the File or did not provide it. Only four
banks responded to the request to provide any additional data and information relative to their CRA Performance in Broward County.
Finally, the researchers requested copies of the bank’s CRA Self-Assessment (a tool encouraged by regulatory agencies to self-monitor
bank performance). None provided it nor acknowledged whether they use the tool or not.
49
The information in the Appendix is organized by:





Performance Evaluation (PE) Date
Bank CRA Officer contact information
Pertinent Broward County CRA information from regulatory agency Performance Evaluation
Performance Evaluation rating is in the narrative portion of each bank’s PE
Additional information provided by financial institution relative to its CRA performance in Broward County
50
Performance Evaluation (PE)
Date: 07/09/12
Florida Community Bank (FCB), National Association
Bank Contact
(CRA Officer)
Nancy L. Merolla
Vice President, CRA Officer
NMLS# 784615
Florida Community Bank, N.A.
2500 Weston Road, Suite 100
Weston, FL 33331
954- 984-3341(direct)
954-214-2383 (mobile)
Pertinent Broward County Information and Data from Regulatory Performance Evaluation:
FCB’s last CRA exam was before bank failed in January 2010 - rebuilt and now owned by Bond Street Holdings – no CRA exam yet.
Formed out of 8 banks that had failed. October 14th 2013 CRA exam and awaiting results.
OCC regulatory.
Needs and how the bank meets them: We are focusing on affordable housing vs. small business. In Broward, we partner with cities and
non-profits in Broward. We originate loans, through Federal Home Loan Bank, we have won two awards in Miami Dade. Putting in two
applications in Broward multifamily affordable rentals for January round FHLB Atlanta Affordable Housing Round.
Bank participates with Community Reinvestment Group an affordable housing lenders’ consortium. CRG takes applications for 0%
interest for developers; It’s not permanent financing; it’s bridge financing.
51
Comments from CREDIT NEEDS FORUM -Nancy Merolla
Nancy Merolla, Panelist, Florida Community Bank
Florida Community Bank’s Commitment and Highlights of CRA Activities:












Residential Affordable Home Loan Portfolio Product First Time Homebuyers
FHLB – Atlanta – 2 successful applications for AHP grants
Purchasing up to $10mill of Habitat for Humanity/SW Florida mortgages
New Non-profit line of credit (several agencies in the room)
LIHTC deals
Investing in CDFI statewide and locally
Maintain a CRA Investment portfolio of $25million at all times
CRA Donations/Grants of over $200,000 in 2 years
1st: Partnerships and collaboration
2nd: Yes, recently
5th: There’s a model project for senior housing in Miami-Dade on South Beach, $500,000 going towards developer’s multimillion dollar expenses
6th: Be sure to meet with local lenders so it’s a win-win situation
The bank places loans in its portfolio for CRA - $4.6 million. This year $10 million in CRA portfolio loans in 16 counties.
Federal Home Loan Bank-Atlanta
 Member banks – act as sponsor to developer/non-profit – affordable housing
 FCB – 2012: 1 Award $133,0002013: Sponsored 2 applications: 1 Award $500,000
 Very competitive grant SCORING – points 100 *5 points if sponsor is a lender
 Next cycle: 2014 Rounds – Open in January Meet with SPONSOR BANK – ASAP/upfront
 Looking to become pro-active in lending
52

Lenders ALSO can assist in housing development – OTHER FORMS OF LENDING:
 Non Profit Operating Lines of Credit
FCB Non Profit Line of Credit - Required Documentation:











Project overview
Proforma of Project – Full cost breakdowns
Information on the Developer/Non Profit
Resume of Key Officers – noting prior experience
2-3 years tax returns or 990s
Rent Rolls – current and projected
Projected future Cash Flow
RE Tax information
Property Insurance
Appraisal Co-Star ( 3rd party Review/Market information before appraisal)
FCB Lending Guidelines:




Policy: 80% LTV up Debt Service Coverage: 1.15 or better
Terms: Amor: up to 25 years Fix, Adjustable, Hybrid Ex: fix 5 yrs –variable thereafter
Rate -Variables: based on structure, risk, terms, LTV, Amortize, collateral type
Future: The bank is a start up bank/de novo and awaiting for Freddie Mac approval. Upon approval the bank will expand product line
as well as continue to do portfolio lending. The bank is also stepping up Community Land Trust lending.
53
Pertinent Broward County Information and Data Submitted by Bank:
FCB Affordable Home Loan Program Affordable Housing Partners by MSA Updated August 26, 2013
Statewide:
Federal Home Loan Bank of Atlanta’s Set-Aside Program (FCB approval 8/23/12)
(Financial Assistance to Individual borrowers up to $5,000/Veterans up to $15,000)
Broward County:
Broward County Housing Authority – FSS Program
City of Ft. Lauderdale- NSP Program and Others
City of Hallandale- NSP Program and Others
City of Lauderhill - NSP Program and Others
City of North Lauderdale- NSP Program
City of Pompano Beach- NSP and SHIP Programs
Crisis Housing Solutions (as of 8/20/12) - Client Intake, Counseling Rehab w/subsidies-NSP
Community Redevelopment Associates of Florida, Inc. (as of 8/20/12)
City of Coral Springs- NSP Program
City of Coconut Creek – SHIP, CDBG and Other Programs
City of Miramar- NSP Program
City of Pembroke Pines- NSP Program
City of Deerfield Beach - NSP Program
Housing Finance Authority of Broward County (as of 8/30/12) – NSP, SHIP, HOME and Others
Housing Foundation of America, Inc. – H2H Program (as of 8/20/12)
Neighborhood Housing Services South Florida – NSP Program, LIFT (City Miami Only) and Others
South Florida Community Land Trust – CLT Program
Town of Davie - NSP Program
54
Pending/In Process of Consideration:
City of Margate- NSP Program
City of Lauderdale Lakes- NSP Program and Others
City of Fort Lauderdale – NSP Program, SHIP and Others
City of Sunrise - NSP Program and Others
Broward Alliance for Neighborhood Development (BAND) - NSP Program
City of Hollywood – AHP Program
Lauderhill Housing Authority
FCB’s Affordable Home Loan Guidelines approved by FCB Board July 19, 2012
Purpose: The Affordable Home Loan (AHP) Program will be used exclusively to accommodate persons of low to moderate income*
and/or first time homebuyers who are purchasing property that is located within the Bank’s assessment areas, for owner occupancy.
Interest Rate: The interest rate** will be derived from the following formula:
The higher of either: FNMA 60 day (mandatory delivery) rate at time of application, plus .50 basis points rounded up to the nearest
eighth; OR: a floor rate as established by the Bank’s Director of Residential Mortgage Group
Fees: A 1% origination fee will be charged**as well as other usual and customary costs as disclosed on the Good Faith Estimate.
Lock In: Maximum lock in period will be for 90 days from date of application**
Loan-to-value: (a) Single Family Residence/Condominiums - up to 95% LTV** without PMI for buyers with household income up to 120% AMI.
Combined loan to value (CLTV) which is the sum of the first mortgage plus all repayable/non-forgivable subsidies, may total up to 105% of the purchase price/appraised value.**
Buyer Contribution: At least 3%** of the buyers’ contribution must be from the borrower’s own funds; Grant money or a gift from a
relative may be added to these funds to meet any other requirements.
55
Term: 30 year; fixed rate only.
Purchase Price Maximums:
City/County subsidy maximum purchase price guidelines apply where grant funds are involved.
Otherwise, FHA maximums apply.
Qualifying Properties: Owner occupied, single family residences and condominiums only.
Maximum Income Guidelines: Maximum income for participation in this loan program will be up to 120%** of the area median income
(AMI), adjusted for household size*, of the Metropolitan Statistical Area (MSA) in which the property is located.
Maximum Debt to Income ratios: 35% for housing; 42% for total debt** Total debt ratios up to 45% will be considered if at least two
of the following compensating factors are presented:
 Excellent credit history
 Job stability
 2+ months PITI in reserves or LTV <80%
 Rent-to-PITI increase shock @/<40%
Escrow: An escrow account for the collection of Taxes, Insurance (Flood and Hazard or HO6) is required.
Closing Costs: Can be a gift or seller concession up to a maximum of 6% of sales price.
Employment: FNMA guidelines will apply for all required standards of employment (except part time which should be one year
minimum), seasonal, overtime hours as well as the Self-employed borrower.
Credit: Minimum credit score of 600;** This may be waived by Department Manager’s approval;
Collection accounts -if any- (except medical) must be paid in full prior to closing. Proof of a payment plan of at least 6 consecutive months
with all timely payments may be considered in lieu of pay off.
56
Excessive overdrafts within the most recent 180 days prior to application may be a reason for denial. All derogatory credit requires an
explanation.
Short sales/deed-in-lieu of previously owned property must have occurred at least 2 years prior to closing date with satisfactory
explanation and documentation. There must be no recourse for deficiencies by the former Lender. Any exceptions will be at the discretion
of the Underwriter, Director of Residential Mortgage Group and Chief Credit Officer (CCO).
Delinquency: 2X30 days late (maximum 2 accounts) in last 6 months is allowed. This and all previous late payments must be explained
in writing.
Education: Every applicant must have proof of having attended a HUD Certified “Community Home Buyer’s Class”;
* Adjusted for family size; based on MSA median incomes
** Some individual program guidelines may vary
Regarding Neighborhood Lending Partners, FCB is not aware of any pending Broward Projects
57
Performance Evaluation (PE)
BankUnited, National Association
Date: 10/09/12
Bank Contact
(CRA Officer)
Claire F. Raley
SVP, CRA/Community Development Officer
BankUnited, N.A.
7815 NW 148th Street
Miami Lakes, FL 33016
305-817-8159 – Direct
786-493-8614 - Cell
305-698-4247 – Fax
www.BankUnited.com
Pertinent Broward County Information and Data from Regulatory Performance Evaluation:
With no operations outside of Florida, Bank United’s CRA ratings are also its state of Florida ratings;
In its 2012 Performance Evaluation conducted by the Office of the Comptroller of the Currency (OCC), BankUnited received an overall
"Satisfactory" rating, with "High Satisfactory" ratings in both the Lending and Service Tests, and "Outstanding" in the Investment Test.
BankUnited offers a full range of financial products and services through a 97 branch network in Miami-Dade (26), Broward (22), Palm
Beach (17), Sarasota (3), St. Lucie (3), Indian River (2), Collier (3), Lee (3), Martin (3), Pinellas (6), Hillsborough (3), Manatee (1) and
Charlotte (1) Counties. The bank expanded its activities and opened branches in Seminole (2) and Orange (2) Counties in December
2011.
MD 22744 - Broward County received a limited scope review.
58
Lending Test
BankUnited has an excellent level of community development (CD) loans in the Miami-Dade MD. This performance had a positive impact
on the overall Lending Test conclusion. During the evaluation period, BankUnited made 16 CD loans, totaling $51 million. Of the total,
seven loans helped meet critical affordable rental housing needs in the county, five were to support activities which revitalized and
stabilized low- and moderate-income geographies, two were to qualifying small business programs, one was for services targeted toward
low- and moderate-income people, and one was to a Title 1 school to help support one of its programs targeting youth. These loans are
responsive to the need for affordable rental housing for low- and moderate-income individuals and stabilization needs, which are both
noted as needs of the assessment area.
In the MD 22744 - Broward County, the bank’s lending performance is stronger than the bank’s overall lending performance due to
better geographic and good borrower distribution to low- and moderate-income areas and borrowers. Performance in the Broward MD
positively affects rating conclusions.
Investment Test
Based on limited-scope reviews, the bank’s performance in all of the limited-scope areas is weaker than the bank’s overall outstanding
performance. The volume of the investments was good for all the limited-scope areas with the exception of the Charlotte County MSA
that had poor performance with a low volume of investments and in Sarasota County where performance was very good. The
performance in the limited-scope areas had a neutral impact on the Investment Test conclusions.
59
Service Test
Based on limited-scope reviews the bank’s performance in the Sarasota County MSA, Broward County MD, Hernando, Hillsborough,
Pasco, and Pinellas Counties MSA, Collier County MD, Orange-Seminole County MSA, Martin and Saint Lucie Counties MSA, and Charlotte
County MSA is not inconsistent with the bank’s overall “High Satisfactory” performance under the Service Test in the state;
Pertinent Broward County Information and Data Submitted by Bank:
The Bank has always been and remains committed to serving the needs of all of its communities, especially in core markets such as
Broward County. Our strategic conversations with community leaders and nonprofit partners have increased in 2013 in all of our
markets and have provided us with a deeper understanding of the community needs. In Broward County, for example, we have actively
engaged with community groups and have become aware of the needs for housing and credit counseling services (including homebuyer
education, foreclosure prevention and loss mitigation, and financial literacy education); affordable and accessible bank products and
services; affordable housing mortgage products; volunteer service commitments; and community development loans and investments
targeted to affordable housing development, both rental and homeownership.
60
Based on these discussions, the Bank has targeted its efforts to address affordable housing needs in its assessment areas, including
Broward County, in the following ways:
 Enhancing Community Housing Assistance Mortgage Program through the following changes:
o Elimination of origination fees
o Flexible underwriting
o Participation with key affordable housing organizations and programs such as
o BAND, NHSSF and City of Hollywood
o Development of a Community Land Trust (CLT) product
 Establishing an internal residential mortgage origination process that features local underwriting decisions and the ability to
portfolio loans.
 Hiring an Affordable Housing Loan Officer who is providing targeted outreach in our markets, including Broward County.
 Supporting nonprofit housing and credit counseling programs in Broward County.
 Launching a community service pilot in Broward County that has provided financial education programming to low-income
adults.
 Engaging Broward nonprofit organizations in a Focus Group regarding BankUnited's affordable housing program and
consumer checking and savings products.
 Building a highly experienced real estate lending team and placing an increased focus on multi-family lending — both market
rate and affordable housing. Multi-family lending is expected to be a strong growth area for BankUnited, including in Broward
County.
 Expanding BankUnited's government banking program. This includes assisting local governments to examine strategies for
leveraging public funding for affordable housing.
61
Performance Evaluation (PE)
Citibank, National Association
Date: 07/26/10
Bank Contact
(CRA Officer)
Lloyd Brown II
CRA Officer
Citibank
Global Community Development
601 Lexington Avenue, 20th Floor
New York, NY 10022
Ramon L. Rodriguez
Citi Community Officer
Citibank Community Development
305- 599-5874
Pertinent Broward County Information and Data from Regulatory Performance Evaluation:
Factors for Florida Rating





Lending levels that represent excellent responsiveness to the credit needs of the rating area.
Excellent distribution of loans by income level of geographies and adequate distribution among borrowers of different income
levels.
Community development lending had a significant positive impact on lending performance.
Excellent responsiveness to the assessment area’s investment needs based on the volume of qualified investments originated
during the evaluation period.
Good branch distribution was the primary reason behind the Service Test. In addition, Citibank had an excellent record of
opening and closing branches and an adequate level of community development services.
62
Within Florida, 70;8% of the bank’s deposits are concentrated in the Miami-Miami Beach-Kendall assessment area; therefore, it was
selected for a full-scope review. The Fort Lauderdale-Pompano Beach-Deerfield Beach assessment area has the second largest
concentration of deposits at 16.0%.
Lending Test
Based on limited-scope reviews, the bank’s performance under the Lending Test in the Fort Lauderdale-Pompano Beach-Deerfield Beach
area is not inconsistent with the bank’s overall outstanding performance in Florida.
Investment Test
Based on a limited-scope review, the bank’s performance under the Investment Test in the Fort Lauderdale-Pompano Beach-Deerfield
Beach assessment areas is not inconsistent with the performance noted in Florida.
63
Service Test
Based on the limited-scope reviews, Service Test performance in the Fort Lauderdale-Pompano Beach-Deerfield Beach MD is not
inconsistent with the performance noted in the Miami-Miami Beach-Kendall MD.
Pertinent Broward County Information and Data Submitted by Bank:
64
Examples of 2011 Community Development Lending and Investment Activities:
Investment- Ehlinger Apartments
On November 30, 2011, Citi made an equity investment of $23,612,461 in a proprietary fund sponsored by the Richman Group, U.S.A.
Institutional Tax Credit Fund LXXI, L.P. (the "Fund"). The Fund was formed to invest in low-income residential projects that qualify for
Low Income Tax Credits ("LIHTC") in accordance with Section 42 of the Internal Revenue Code. The Fund acquired an interest in the
Ehlinger Apartments. Ehlinger Apartments is a new construction, 9% LIHTC development which will consist of 155 units housed in 8
three-story buildings. The subject will contain 6 one- bedroom/one-bath, 95 two-bedroom/two-bath, and 54 three-bedroom/two-bath
units. Of the 155 units, 16 will be affordable at 28% of AMI and the remaining 139 units will be restricted at 60% of AMI. In addition,
the project features a separate clubhouse building for residents' use. Proposed project rents will range from $352 to $1,100 per month,
which are approximately 32% below current market rates. Ehlinger will be developed by Carlisle Development Group who is the leading
provider of affordable housing with over 72 LIHTC projects and more than 8,381 units completed to date or under construction.
Loan- Broward Gardens
On October 10, 2011, Citi extended a $4,200,000 loan that supported the development of Broward Gardens Apartments, a 96-unit
affordable housing project. The loan originally closed in April 2008 with a maturity date of October 11, 2011. The borrower requested
an extension; the new maturity date is October 10, 2012. Under multi-family construction loans originated by Citi, borrowers
occasionally need additional time past the initial maturity (and past any automatic extensions) of the construction loan in order to meet
conversion conditions for permanent financing. If an extension is requested, Citi does a complete risk evaluation and decides whether or
not to extend further credit to the borrower in order for the borrower to complete and convert the project. The property is operating
under a Section 8 HUD HAP contract, which commenced on June 11, 2007 and runs until June 10, 2027. Under the Section 8, the US
Department of Housing and Urban Development (HUD) enters into contracts (Housing Assistance Program a/k/a as “HAP”) with
property owners to provide rental assistance for a fixed period of time for low-income families. The program allows low-income tenants
to rent apartment units at a reduced rate.
65
Performance Evaluation (PE)
City National Bank of Florida (CNFB)
Date: 05/29/12
Bank Contact
(CRA Officer)
Michelle Christensen
First Vice President
Compliance & CRA Manager
City National Bank
25 West Flagler Street
Miami, FL 33130
305-577-7251 Office
305-577-5536 Fax
citynational.com
Pertinent Broward County Information and Data from Regulatory Performance Evaluation:
The major factors that support this rating (same for institution and Florida) include:






Lending activity that reflects good responsiveness to the credit needs of the bank’s assessment areas, given performance context.
Excellent geographic distribution of loans with a substantial majority of loans being within the bank’s assessment area;
Adequate distribution of loans among borrowers of different income levels and businesses of different sizes.
An excellent level of community development loans that is strong enough to positively impact the overall Lending Test rating.
An excellent level of qualified investments responsive to assessment area needs.
Service delivery systems that are readily accessible to geographies and individuals of different income levels and a good level of
community development services.
As of December 31, 2011, CNBF had total assets of $4.0 billion. Deposits totaled $2.9 billion and the total loan portfolio (net of unearned
income), which represents 50 percent of total assets, was $2;0 billion; The loan to deposit ratio was 69 percent; Components of the bank’s
66
loan portfolio include commercial real estate loans (40 percent), residential real estate loans (34 percent), commercial and industrial
loans (13 percent), construction loans (11 percent), and other loans, including consumer loans, (3 percent).
CNBF offers a full range of financial products and services through a 26- branch network in Miami-Dade (15), Broward (5), and Palm
Beach (3) Counties as well as in Orange County (2) and Martin County (1). Miami-Dade County represents the core of the bank’s business,
with 90 percent of total deposits as of June 30, 2011 and 67 percent of the total number of loans analyzed as part of this examination.
Assessment Area
**The MSA 33100 (Miami-Ft. Lauderdale-Palm Beach, FL) assessment area will receive a full-scope review. MSA 33100 is comprised of
three Metropolitan Divisions (MDs), including: MD 33124 (Miami-Miami Beach-Kendall, FL) which consists of Miami-Dade County, MD
22744 (Fort Lauderdale-Pompano Beach-Deerfield, FL) which consists of Broward County, and MD 48424 (West Palm Beach-Boca RatonBoynton Beach, FL) which consists of Palm Beach County.
Mortgage Lending Products: City Smart Community Mortgage Product
Mortgage lending is not a primary business line, with the exception of the bank’s City Smart Community Mortgage product, which focuses
on mortgage loans to low-and moderate-income borrowers; This strategy had a particular impact on the bank’s ability to originate
refinance loans as it does not have a large portfolio of existing borrowers for whom refinancing could be an option. The majority of
existing borrowers have used some form of assistance to purchase their homes and many times these programs do not allow for
refinancing or have provided such a low interest rate that it is not practical for the borrower to refinance.
In the later part of the evaluation period the volume of home purchase City Smart Community Mortgage loans was negatively impacted
by increased marketing of FHA loans, primarily by the larger banks. This product became more competitive, offering lower interest rates
than could be offered by CNBF. At this time CNBF does not have the staffing or expertise necessary to offer FHA loans.
67
MD 22744 (FORT LAUDERDALE-POMPANO BEACH-DEERFIELD, FL)/BROWARD COUNTY
Overall, lending activity in Broward County is excellent, given performance context. Lending activity is good for home mortgage loans
and excellent for small loans to businesses, given performance context.
Lending Tests
Home Mortgage Loans
Overall, the geographic distribution of home mortgage loans in Broward County is good, given performance context. The distribution of
home purchase loans is good and distribution of refinance loans is adequate, given performance context. The percentage of home
purchase loans in low-income geographies significantly exceeds the percentage of owner-occupied housing units in those geographies.
In moderate-income geographies, the percentage of home purchase loans is somewhat lower than the percentage of owner-occupied
housing units in those geographies. In both low- and moderate-income geographies, the bank’s market share of home purchase loans
exceeds its overall market share of home purchase loans.
For refinance loans, the percentage of loans in low-income geographies exceeds the percentage of owner-occupied housing units in those
geographies and in moderate-income geographies the percentage of refinance loans is significantly lower than the percentage of owneroccupied housing units. For low-income geographies the bank’s market share of refinance loans exceeds its overall market share of
refinance loans, but the bank’s market share of refinance loans is significantly lower in moderate-income geographies than its overall
market share of refinance loans.
68
Distribution of Home Mortgage Loans by the Income Level of the Borrower
Overall, the distribution of home mortgage loans by the income level of the borrower in Broward County is good, given performance
context. The distribution of home purchase loans is excellent and the distribution of refinance loans is adequate, given performance
context. The percentage of home purchase loans to low-income borrowers is somewhat lower than the percentage of low-income families
in the county, but consistent with performance context issues noted above. The percentage of home purchase loans to moderate-income
borrowers significantly exceeds the percentage of moderate-income families in the county. In both low-and moderate-income
geographies the bank’s market share of home purchase loans exceeds its overall market share of home purchase loans.
For refinance loans, the percentage of loans to low-income borrowers is significantly lower than the percentage of low-income families
in the county, but not inconsistent with performance context issues noted above; The percentage of the bank’s refinance loans to
moderate-income borrowers is lower than the percentage of moderate-income families in the county, but consistent with performance
context; The bank’s market share of refinance loans to low-income borrowers exceeds its overall market share of refinance loans but its
market share of refinance loans to moderate income borrowers is somewhat lower than the bank’s overall market share of refinance
loans.
69
70
·1 Loans
Tabl e 5. Geograph.1c o·ISl"b
rl UrIOn 0f Mulrt
1amuy
GeographicDistribution: MULTIFAMILY
Assessmert Area:
Geography: FLORIDA
Total Muttifamily
Loans
#
%of
Total"
Low-Income Geographies
Evaluation Period JANUARY 1, 2009 TODECEMBER31, 2011
Moderate-Income
Geograph~
%ofMF
Units"'
%BANK
Loans""
%MF
Unrts"'
%BANK
Loans
Midde-lnoome
Geographies
%MF
%BANK
Units"'
Loans
Upper-Income
Mari<et Share (%) by Geography'
~raphies
%MF
Unrts'"
%BANK
Loans
Overal
Low
Mod
Mil
Upp
Full Review:
MD 22744(Ft LauderdaleP001pano Beach)
MD 33124(Miani-Miami
Beach-Kendal)
MD48424(West Palm
Beach-Boca-Boynton
Beach)
Limited Re.oiew:
MSA 36740 Par1ial (Orange
and Seminole Counties)
MSA 38940 (St Lucie and
Martin Counties)
1
1
0
0
0
50.00
2.27
000
32.411
100.00
411.64
000
16.61
000
000
000
000
000
000
50.00
6.85
0.00
35.49
0.00
30.24
100.00
27.42
0.00
0.00
0.00
0.00
0.00
0.00
000
3.13
000
32.78
0.00
31.51
0.00
32.58
000
000
000
000
000
0.00
0.00
2.73
0.00
27.37
0.00
50.42
0.00
19.47
0.00
0.00
0.00
0.00
0.00
0.00
000
2.19
000
14.37
0.00
43.56
0.00
39.88
000
000
000
000
000
0.00
71
Community Development Lending
CNBF has an excellent level of community development loans in Broward County considering the level of its presence in the county. This
performance had a positive impact on the overall Lending Test conclusion for Broward County. During the community development
evaluation period, the bank made five community development loans in Broward County totaling $11 million. Virtually all ($10.3 million
representing 4 loans) community loan activity helped to revitalize and stabilize low- and moderate-income geographies. Of these four
loans, two are providing working capital to existing business so they can maintain operations thus retaining 78 jobs. The remaining two
were to purchase a shopping center and an office building, both in moderate-income geographies. These loans will help to stabilize the
geographies by retaining jobs and providing necessary services. One community development loan totaling $475,000 helped to provide
eight units of rental housing affordable to low- and moderate-income residents. The retention of jobs is responsive to assessment areas
needs as evidenced by the high unemployment rates throughout the evaluation period.
Product Innovation and Flexibility
The bank makes good use of flexible mortgage programs to help meet credit needs in its assessment area; CNBF’s use of these flexible
programs had a positive impact on conclusions under the Lending Test.
Throughout all portions of the MSA 33100 (Miami-Ft. Lauderdale-Palm Beach, FL) assessment area, CNBF offers its City Smart
Community Mortgage Program which is targeted to low- and moderate-income homebuyers. A proprietary product initiated by the bank,
the mortgage features flexible underwriting criteria, 95 percent loan-to-value ratios, no private mortgage insurance requirements, and
reduced closing costs. During the evaluation period, the bank originated 226 City Smart mortgages in the full-scope MSA 33100
assessment area.
City Smart Mortgages allow for multiple layers of financing, enabling borrowers to participate in programs designed to assist low- and
moderate-income individuals and families to become homeowners. Local community development corporations (CDCs) and cities often
have home purchase assistance programs that can benefit City Smart borrowers and in some cases, HUD Section 8 housing assistance
payments can be used for mortgage payments.
72
Additionally, the bank had a Financial Hardship Payment and Loan Modification Program in place during the evaluation period. Under
the program, existing borrowers impacted by a financial hardship and meeting certain criteria can have payments deferred for a
maximum of 90 days. The bank extends the term of the loan based on the amount of time payments are deferred and does not charge
interest on the deferred payments. During the evaluation period, 264 borrowers were assisted under the program, and 108, or 41
percent, were to borrowers with homes located in low- or moderate-income geographies. Loan modifications are not analyzed in other
portions of the Lending Test.
Investment Tests
During the community development evaluation period, the bank made a $5 million investment in a CRA qualified investment fund. The
investment is backed by multiple mortgages on properties that are helping to provide rental housing affordable to low- and moderateincome residents; This investment is shown in Table 14 under “MSA 33110” investments because it benefitted both Miami-Dade and
Broward Counties.
**Broward County benefited from approximately 30 percent of the MSA investment discussed above. The loan in Broward County
that secures the investment is for a 312-unit rental complex in Broward County built using Low Income Housing Tax Credits and
where rents are affordable to low- and moderate-income residents. The mortgage is important because it allows for the complex to
continue providing affordable rents that meet the identified need for affordable rental housing for low- and moderate-income families
and individuals.
Also, the bank has a prior period investment in the Florida Housing Tax Credit Fund, Ltd, which serves all of the state of Florida, with the
potential to serve the bank’s assessment area; This investment is shown under the caption “Statewide” and it helps the Fund continue
meeting affordable housing needs in Florida, and potentially within the bank’s assessment area;
Overall, the bank’s community development investments are responsive to assessment area needs, primarily addressing the need for
affordable housing and permanent jobs for low- and moderate- income persons. Affordable housing needs are considered critical
throughout the overall MSA assessment area, as are jobs, as evidenced by high unemployment rates. Investments are not considered
innovative or complex and private investors routinely provide these types of qualified investments.
73
Community Development Services
Considering the level of the bank’s presence in Broward County, CNBF provided a good level of community development services; During
the evaluation period, bank records indicate that bank employees spent approximately 426 hours on community development services
conducted through 12 local community based organizations that have the primary mission to assist with housing opportunities
affordable to low- and moderate income individuals and families. Bank employees also provided technical assistance to local nonprofit
organizations by serving as board members; CNBF’s community development lender conducted 37 First Time Home Buyer seminars;
Bank records indicate 635 people attended First Time Home Buyer seminars. A financial literacy seminar conducted by a residential
lender had approximately 400 people in attendance. The programs, presented in both English and Spanish, include discussions on
budgeting, savings, the loan process, credit, etc.
Examples of organizations that CNBF frequently partners with in providing community development services includes the Broward
County Housing Authority, an organization focused on creating, providing and increasing affordable housing opportunities to Broward
County residents and Oasis of Hope Community Development Corporation that provides basic community housing services to low- and
moderate-income families and individuals.
Pertinent Broward County Information and Data Submitted by Bank:
No additional information submitted.
74
Performance Evaluation (PE) Comerica Bank
Date: 10/16/10
Bank Contact
(CRA Officer)
Carol A. Molnar
Vice President
Florida CRA Manager
Comerica Bank
1675 North Military Trail, Sixth Floor
Boca Raton, Florida 33486
561.961.6632 (Phone)
561.961.6650 (Fax)
[email protected]
Pertinent Broward County Information and Data from Regulatory Performance Evaluation:
Major factors supporting Comerica Bank's rating in the state of Florida include the following:




Excellent geographic and borrower distribution of HMDA-reportable loans in the Fort Lauderdale assessment area;
Good geographic distribution of CRA-reportable loans;
Good borrower distribution of CRA-and HMDA-reportable loans in the West Palm Beach assessment area;
An adequate level of community development lending in the West Palm Beach assessment area and a poor level in the Fort Lauderdale
assessment area;
 A good level of community development investments; and
 Demonstrated leadership in the provision of community development services.
75
Fort Lauderdale-Pompano Beach-Deerfield Beach, Florida MD
Comerica Bank's operations within the assessment area are consistent with its operations statewide. HMDA-reportable lending within
the assessment area represents 43.3 percent of the bank's total HMDA activity in the state, while its CRA-reportable lending represents
24 percent of its total CRA activity.
Lending Test
The bank's overall lending performance in the Fort Lauderdale MD is good, with the lack of community development lending the primary
factor detracting from the excellent performance in HMDA lending.
During the two-year period, the bank originated 52 CRA-reportable loans, 18 home equity loans, and originated or purchased 65 HMDAreportable loans within the assessment area.
The overall distribution of CRA-and HMDA-reportable lending within the Fort Lauderdale assessment area reflects a good level of
penetration throughout the assessment area. The geographic distribution of HMDA-reportable lending is excellent. The bank originated
or purchased two or 5.7 percent and 26 or 74.3 percent of its 2008 mortgage loans to borrowers in low- and moderate-income census
tracts, respectively. The aggregate of lenders made 2 percent and 19.8 percent in LMI tracts, respectively. One loan or 3.3 percent was
originated by the bank in a low-income tract in 2009, while seven or 23.3 percent were in moderate-income tracts. The aggregate of
lenders originated 1.3 percent and 14.8 percent of loans in low-and moderate-income tracts, respectively.
The bank originated 17 home equity loans in 2008 and only one in 2009. None of the loans were made in low-or moderate-income census
tracts. Comparing the percentage of owner-occupied housing in low-and moderate-income census tracts to the bank's percentage of
lending within these tracts is another way to evaluate performance. In this regard, it is noted that one percent and 23.8 percent of owneroccupied housing is located within low-and moderate-income census tracts, respectively. Limited opportunities exist for mortgage
lending in low-income tracts. Comerica's mortgage lending in moderate-income census tracts is excellent compared to the performance
of the aggregate and the local demographics.
76
Distribution by Borrower Income
The distribution of HMDA-reportable lending is excellent, especially to moderate-income families. The bank originated or purchased one
or 2.9 percent and ten or 28.6 percent of its mortgage loans to families with low-or moderate incomes in 2008, respectively. This
compared to 3.4 percent and 13.9 percent for the aggregate of lenders, respectively. In 2009, the bank originated or purchased five or
16.7 percent and 12 or 40 percent of its mortgage loans to families with low-and moderate incomes, respectively. This compared to 4.9
percent and 16.5 percent for the aggregate of lenders, respectively.
None of the 18 home equity loans made by the bank in 2008 and 2009 were originated to low-or moderate-income borrowers.
The bank's performance within this category can also be evaluated by comparing the percentage of mortgage lending to the presence of
families within low-and moderate-incomes within the assessment area. Families with low-or moderate-incomes total 20.9 percent and
18.2 percent, respectively and 8.7 percent live below poverty level. Comerica outperformed the aggregate of lenders and made more
HMDA loans to moderate-income people than their presence in the community.
Investment Test
The bank's level of community development investment is excellent in the Fort Lauderdale MD. For the evaluation period, the bank and
its various affiliates used the following investment vehicles, for a total dollar amount of $4.6 million:


**Investments: The bank has made commitments totaling almost $9 million in low-income housing tax credits. Cash disbursements
totaled $4,533,184.
Donations: The bank contributed $106,205 to organizations and/or programs with a qualified community development purpose.
77
Pertinent Broward County Information and Data Submitted by Bank:
Comerica Florida's focus is primarily a wealth management and business, both small and middle market institution. Our lending is
focused in these areas. As other institutions with this focus, most residential loans are purchased on the secondary market which will
free funds to make additional affordable loans to individuals and families. We do not have remarks, letters, etc., in our Public File.
78
Performance Evaluation (PE) Fifth Third Bank
Date: 11/14/11
Bank Contact Jadira Hoptry
(CRA Officer)
VP | CRA Manager for South Florida
Community and Economic Development
Fifth Third Bank
999 Vanderbilt Beach Rd
8th floor
Naples FL 34108
(239) 449-7083 (phone)
(239)357-5972 (cell)
[email protected]
Pertinent Broward County Information and Data from Regulatory Performance Evaluation:
R! R!TN
for State of lorida: “Satisfactory”
The lending test is rated: “Low Satisfactory”
The investment test is rated: “Outstanding”
The service test is rated: “igh Satisfactory”
The major factors supporting this rating include:





An adequate responsiveness to the credit needs of the community.
An adequate geographic distribution of loans throughout the assessment area.
A good distribution among borrowers of different income levels and an adequate distribution to businesses of different revenue sizes.
A relatively high level of community development loans.
An excellent level of qualified community development investments and grants.
79





A leadership position in providing community development investments and grants.
Retail delivery systems that are accessible to all geographies and individuals of different income levels and businesses of different
revenue sizes.
A record of opening and closing banking centers that has improved the accessibility of delivery systems.
Banking services and hours that do not vary in a way that inconveniences any portions of the assessment areas.
A relatively high level of community development services.
Scope of Examination
Full-scope reviews were conducted for six assessment areas in Florida: Cape Coral-Fort Myers, Deltona-Daytona Beach-Ormond Beach,
North Port-Bradenton-Sarasota, Orlando-Kissimmee- Sanford, Punta Gorda, and Tampa-St. Petersburg-Clearwater MSAs. Limited-scope
reviews were performed on the remaining five assessment areas: the Fort Lauderdale-Pompano Beach- Deerfield Beach and West Palm
Beach-Boca Raton-Boynton Beach MDs and the Jacksonville, Lakeland-Winter Haven, and Naples-Marco Island MSAs. The time period,
products, and affiliates evaluated for this assessment area are consistent with the scope discussed in the institution section of this report.
The three assessment areas receiving greater weight in determining the CRA rating for the state include Naples-Marco Island, OrlandoKissimmee-Sanford, and Tampa-St. Petersburg-MSAs. These three assessment areas had the largest deposit and/or lending volume in
Florida during the evaluation Period.
Description Of Institution’s Operations In Florida
Lending activity accounted for 4;5% of the bank’s total lending activity, while deposits accounted for 10;4% of the bank’s total deposits;
HMDA-reportable lending in Florida represented 3;9% of the bank’s total HMDA-reportable lending, while CRA-reportable lending
represented 7;4% of the bank’s total CRA-reportable lending. As of June 30, 2011, the bank ranked ninth among 313 insured institutions,
in deposit market share with 2.0% of the deposits within the state. As of December 31, 2011, there were 169 banking center locations
and 195 ATMs within Florida.
80
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN FLORIDA.
Lending Test
Fifth Third’s performance under the Lending Test within the assessment areas located in Florida is rated “Low Satisfactory;” Fifth Third’s
lending reflects an adequate responsiveness to the credit needs of nine of its 11 assessment areas; The bank’s lending demonstrated a
good responsiveness in the in the Naples-Marco Island MSA and poor responsiveness in the Punta Gorda MSA.
Lending Activity
Lending activity in Florida is adequate. Fifth Third is one of the top ten institutions in the state by deposit share. Fifth Third ranks ninth
out of 313 institutions with slightly less than 2.0% of deposit market share. In Florida, Fifth Third originated 3,954 home purchase, 3,702
refinance, 109 home improvement, and 2,624 small business loans; While deposits within the state represent 10;4% of the bank’s total
deposits, only 4.5% of the total loans were originated in Florida.
There were not enough home improvement loans originated in any of the 11 assessment areas or enough small business loans originated
in the Punta Gorda MSA to conduct meaningful analyses.
Geographic and Borrower Distribution
Overall, the distribution of loans among geographies is adequate. The geographic distribution of loans is adequate in seven of 11 of
Florida’s assessment areas. In three of the areas (Fort Lauderdale-Pompano Beach-Deerfield Beach MD and the Orlando-KissimmeeSanford and Tampa-St. Petersburg-Clearwater MSAs), the geographic distribution was good, while geographic distribution was poor in
the Punta Gorda MSA.
Overall, moderate gaps in lending were identified; however, significant lending gaps were noted in the Fort Lauderdale-Pompano BeachDeerfield Beach MD and the Lakeland-Winter Haven MSAs. No significant gaps were identified in the Cape Coral-Fort Myers and NaplesMarco Island MSAs.
81
Although moderate lending gaps were noted, low-income and moderate-income tracts generally represented a larger share of tracts
without lending than middle-income and upper-income tracts.
In most of these tracts, housing units were predominately multi-family dwellings and, in many instances, these tracts had high vacancy
rates, which may have impacted the ability to originate home purchase, refinance, and home improvement loans in these tracts.
In addition to lending, Fifth Third modified existing mortgage loans to borrowers in order to make the loans more affordable and assist
borrowers in avoiding foreclosure. Generally modifications in low-income and moderate-income tracts were a smaller share of the
market, while middle-income and upper-income tracts received a larger share of these modifications.
The distribution of loans among borrowers of different income levels is good, and the distribution of loans to businesses of different
revenue sizes is adequate. Borrower distribution is good in seven of the assessment areas, while it is adequate in three of the assessment
areas (the Naples-Marco Island and North Port-Sarasota MSA and the West Palm Beach-Boca RatonBoynton Beach MD). Borrower distribution is poor in the Punta Gorda MSA. Distribution of loans to businesses of different revenue sizes
is adequate in all ten assessment areas evaluated.
A detailed analysis for the geographic distribution and borrower-income distribution is provided with the analysis for each assessment
area.
Fifth Third participates in and offers various flexible lending programs and making loan modifications under its loss mitigation program.
Community Development Loans
In Florida, Fifth Third originated 32 community development loans totaling $119;8 million, which represents 9;0% of the bank’s
community development lending by dollar volume. This represents a relatively high level of community development loans made in
Florida. Fifth Third was a leader in providing community development loans in four of the assessment areas: the Jacksonville, LakelandWinter Haven, Naples-Marco Island, and Tampa-St. Petersburg- Clearwater MSA. The bank made a relatively high level of community
development loans in the Deltona-Daytona Beach-Ormond Beach MSA and Fort Lauderdale-Pompano Beach-Deerfield Beach MD, while
82
the bank made adequate level of community development loans in the Cape Coral-Fort Myers and Orlando-Kissimmee-Sanford MSA. The
bank made a low level of community development loans in North Port-Bradenton-Sarasota MSA and no community development loans
in the Punta Gorda MSA and West Palm Beach-Boca Raton-Boynton Beach MD.
Investment Test
Fifth Third’s performance under the Investment Test within the assessment areas located in Florida is rated “Outstanding;” The
institution funded $74.7 million in community development investments in Florida during the evaluation period. Investments reflected
an excellent performance in nine of the 11 assessment areas. The Naples-Marco Island MSA had a good amount of investments, while the
Deltona-Daytona Beach-Ormond MSA had an adequate amount of investments.
In addition to the qualified investments made inside the bank’s assessment area within the state, Fifth Third funded $5,000 in an
investment in Florida but outside the bank’s assessment area; Additional information regarding performance under the Investment Test
is provided in the respective analyses for each assessment area.
Service Test
Fifth Third’s performance under the Service Test is rated “High Satisfactory;” Service test performance in Fifth Third’s largest markets
in this state were generally good, including the Tampa-St. Petersburg-Clearwater, Orlando-Kissimmee-Sanford, North Port-BradentonSarasota, and Cape Coral-Fort Myers assessment areas. The performance was poor in the Lakeland- Winter Haven and Punta Gorda
assessment areas.
For details regarding the institution’s performance in the individual assessment areas, refer to the respective assessment area’s “Service
Test” section in this report.
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Retail Services
Retail delivery systems are accessible to all geographies, including low-income and moderate income geographies, individuals of
different income levels, and businesses of different revenue sizes in the institution’s assessment areas. Retail service distribution in the
Tampa-St. Petersburg-Clearwater and North Port-Bradenton-Sarasota assessment areas was stronger than those assessment areas
overall service test performance, but the retail service distribution in the Orlando-Kissimmee-Sanford, Naples-Marco Island and Cape
Coral-Fort Myers assessment areas was weaker than those assessment areas overall service test performance.
The institution’s record of opening and closing banking centers has improved the accessibility of its delivery systems, particularly to
low-income and moderate-income geographies and individuals. Two assessment areas had improved distribution due to a larger
increase in banking centers in low-income and moderate-income geographies than in middle- and upper-income geographies.
Banking services and business hours do not vary in a way that inconveniences any portions of the bank’s assessment areas and are
consistent with the services and hours discussed in the institution assessment.
Community Development Services
Fifth Third provided a relatively high level of community development services. Performance varied among assessment areas, with
performance excellent in the Orlando-Kissimmee-Sanford assessment area, good in the Naples-Marco Island and Cape Coral-Fort Myers
assessment areas, but poor in the Tampa-St. Petersburg-Clearwater and North Port-Bradenton-Sarasota assessment areas.
Limited-scope review performed on the Fort Lauderdale-Pompano Beach-Deerfield Beach area.
escription of institution’s operations in Fort Lauderdale-Pompano Beach-Deerfield Beach MD #22744.
Fifth Third’s assessment area includes the Fort Lauderdale-Pompano Beach-Deerfield Beach Metropolitan Division (MD) #22744, which
is comprised of Broward County. The MD is comprised of 12 low-income, 72 moderate-income, 117 middle-income, and 78 upper-income
tracts.
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According to 2000 U.S. Census data, the population within the assessment area was 1,623,018. The population increased to 1,748,066 in
2010, which represented a growth rate of 7.7%. The median family income in 2000 was 50,531 and increased slightly to $61,800 in 2011.
The estimated poverty rate in 2010 was 14.7%.
Fifth Third ranked 45th of 62 institutions in the MD, with 0.2% of deposits as of June 30, 2011. Deposits in the MD represented 0.1% of
the bank’s total deposits;
Fifth Third originated 275 mortgage loans in the assessment area, representing 0;1% of the company’s total mortgage lending; Fifth
Third Mortgage Company ranked 30th of 516 HMDA reporters in 2010, while the bank ranked 103rd. The bank originated 122 CRA loans
in the MDA, representing 0.3% of small business/small farm loans. Fifth Third ranked 25th of 115 CRA reporters in 2010.
Combined Demographics Report
Exam: Fifth Third Bank
Assessment Area(s): FL Fort Lauderdale-Pompano-Beach-Deerfield Beach
See Following Page:
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CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN THE FORT LAUDERDALE-POMPANO BEACH-DEERFIELD BEACH MD
#22744
Lending Test
Fifth Third’s performance under the Lending Test in this assessment area is consistent with the state rating mainly because of the
relatively low penetration of lending within the assessment area. Lending activity reflects an adequate responsiveness to the credit needs
within the assessment area because of the significant difference between the percentage of deposits in the assessment area compared to
the percentage of loans originated; The percentage of the bank’s total lending at 0;2% is slightly above the percentage of total deposits
at 0.1% in this area.
Significant gaps in lending were noted in all geographies, but low-income and moderate-income tracts represent the larger share of
geographies without lending. During the evaluation period, Fifth Third only originated loans in 64.0% of the census tracts within the
assessment area.
Despite the gaps, Fifth Third has a good distribution of loans among geographies. Fifth Third also has a good distribution of loans based
on borrower’s income levels and an adequate distribution of loans to businesses of different revenue sizes.
Fifth Third made four community development loans totaling $6.1 million in this assessment area. These loans represent 0.5% of the
total dollar volume of community development loans originated by the bank during the evaluation period. This assessment area ranked
33rd by total dollar volume for community development loans originated during the evaluation period. Of the four loans made within
this assessment area, three were for economic development totaling $6.0 million and one was for community services totaling $76,000.
Therefore, Fifth Third had a relatively high level of community development loans in this MD.
Investment Test
Fifth Third’s performance under the Investment Test in the assessment area is consistent with the state rating. Overall, the institution
funded nearly $1.3 million in community development investments. This represents an excellent level of community development
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investments given that 30.0% of the tracts in the assessment area are low- and moderate-income tracts, which provide additional
opportunities for community development activities. Further, the bank does not have a large presence in this assessment area.
Service Test
Fifth Third’s performance under the Service Test in this assessment area is below the state rating.
Retail services are consistent with the state rating but the bank provided no community development services, which is below the state rating.
Pertinent Broward County Information and Data Submitted by Bank:
As mentioned at the Broward Housing Council Housing Credit Needs Forum on August 8, 2013, Fifth Third Bank is actively engaged and
continually learning of community needs through partnerships with several Broward County housing intermediaries, county’s agencies
and various community organizations.
There are no “public comments” relative to housing credit needs for Broward County in Fifth Third’s current public file;
Fifth Third Bank is very active in the Broward community. With three branches, we have established strong partnerships and supported
many organizations in the area. We are members of the Affordable Housing TASK Force of Broward County. Mortgage Area Sales
Manager and Mortgage Originators participate in quarterly first time home buyer seminars facilitated by Neighborhood Housing Services
of South Florida. In addition, we had a booth and facilitated one of the presentations at the Broward Housing Authority Affordable
Housing Fair in the spring and are scheduled to attend the Housing Fair this Saturday, Nov 2nd at the Urban League of Broward
County. Our retail and mortgage team has also partnered and volunteered with Hispanic Unity VITA Program and Urban League of
Broward County Job Fairs and Carrier dates.
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Performance Evaluation (PE)
HSBC Bank USA, National Association
Date: 10/05/09
Bank Contact
(CRA Officer)
Edith W Bynes
Mortgage Consultant
HSBC Bank USA
1291 S Pompano Parkway
Pompano Beach, FL 33069 NMLS #484749
954-218-0643 (Phone)
954-903-7631 (Fax)
[email protected]
Pertinent Broward County Information and Data from Regulatory Performance Evaluation:
The major factors that support the Florida rating include:

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Excellent lending activity in the AA.
Excellent geographic distribution of loans.
Good distribution of loans by borrower income.
CD lending had a positive impact on the Lending Test.
Product innovation and flexibility had a positive impact on the Lending Test.
Excellent level of CD investments including those from prior periods and the continuing impact of these investments.
The bank’s branches are accessible to geographies and individuals of different income levels given the level of branches located in
low-and moderate-income geographies and the proximity of other branches to low-and moderate-income geographies.
A high level of CD services that are responsive to the needs of the bank’s AA;
Full-scope review of the Miami AA and limited-scope review of the Fort Lauderdale and West Palm Beach AAs. The state rating is based
primarily on the performance in the Miami AA. Home mortgage lending was weighted more heavily based on the volume of lending.
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Mortgage lending accounted for 86% of the lending volume in the Miami AA. Based on limited-scope reviews, the bank’s performance in
the Fort Lauderdale and West Palm Beach AAs is not inconsistent with the bank’s overall outstanding performance in Florida;
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Pertinent Broward County Information and Data Submitted by Bank:
No additional information submitted.
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Performance Evaluation (PE) JPMorgan Chase Bank, National Association
Date: 12/31/10
Bank Contact
(CRA Officer)
Erica Wicks
Assistant Vice President, CRA Management
JPMorgan Chase
Columbus, OH
614-213-5341
Pertinent Broward County Information and Data from Regulatory Performance Evaluation:
Factors for Florida Rating
 Excellent overall lending test performance is the result of significantly positive community development lending in the full-scope
area. Strong performance in the limited-scope areas had a positive impact on the state rating, supporting the excellent performance
in the full-scope Miami-Miami Beach-Kendall AA. Within the full-scope area, the distribution of loans within geographies of different
income levels was good, the distribution of loans to borrowers of different income levels was adequate, and lending activity was
excellent.
 Excellent responsiveness to the investment needs of the rating area based on the volume of qualified investments.
 Service test performance reflects a good distribution of branches and ATMs, as well as good hours of service and a good record of
community service.
JPMorgan Chase Bank, NA (Chase) has a proven history of commitment to the goals of the Community Reinvestment Act (CRA). Below is
a summary of the bank’s CRA activities in Broward County, Florida for the period January 2011 – June 2013.
This is an evaluation of the CRA performance of JPMorgan Chase Bank, N;A; issued by the OCC, the institution’s supervisory agency, for
the evaluation period starting January 1, 2007 through December 31, 2010. The agency evaluates performance in assessment areas
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(AAs), as they are delineated by the institution, rather than individual branches. This AA evaluation may include visits to some, but not
necessarily all of the institution’s branches; The agency rates the CRA performance of an institution consistent with the provisions set
forth in Appendix A to 12 CFR Part 25.
nstitution’s Overall R! Rating: “Satisfactory;”
Lending Test
Based on limited-scope reviews, the bank’s performance under the lending test in the Fort Lauderdale-Pompano Beach-Deerfield Beach,
Orlando, and Tampa-St. Petersburg-Clearwater AAs is not inconsistent with the bank’s overall excellent performance under the lending
test in the state of Florida.
In total, Chase made over $9.6 billion in community development loans within its various AAs and broader regional areas that include
its AAs. This figure for the bank as a whole is informational only, as conclusions and ratings in this evaluation are based on the bank’s
performance in the individual AAs and rating areas. Most (68%) of the community development loans made by the bank provided
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needed affordable housing. Another 19% of community development loans provided social services that assisted low- and moderateincome individuals and 13% helped to revitalize or stabilize low- or moderate-income geographies or provided economic development.
Most notably in the primary rating areas, the distribution of loans to geographies of different income levels is generally good while the
distribution of loans to borrowers of different income levels is considered generally adequate.
The volume of unfunded commitments to affordable housing programs helped to elevate the rating for several rating areas.
Mortgage Lending
The bank has a long history of helping homebuyers achieve the goal of homeownership, including those with low- and moderate-incomes.
Nearly 14,000 mortgage loans totaling $2.4 billion were made in Broward County, of which 28% of the loans were made to low- or
moderate-income borrowers; 16% of the loans were made in low- or moderate-income communities.
Investment Test
Performance in the Fort Lauderdale-Pompano Beach-Deerfield MSA is good and weaker than the overall performance in Florida. Weaker
performance is based on a lower or no amount of qualified investments relative to the bank’s operations in the AA;
The bank and its affiliates responded to affordable housing needs primarily through investments in Low-Income Housing Tax Credit
(LIHTC) partnerships or funds investments or acting as an equity placement agent for other investors into the LIHTC market. The bank
is a consistent, and frequently the top, investor in the LIHTC market in the nation. With these investments, the bank demonstrated
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excellent responsiveness to the identified community development needs of its communities, through investment vehicles that promote
affordable housing for low- and moderate-income individuals.
Notably, the U;S; Department of the Treasury’s Community Development Financial Institutions Fund (CDFI Fund) awarded Chase
$500,000 for serving economically distressed communities across the nation. The bank was recognized in 2011 by the U.S.
Department of the Treasury by receiving the Bank Enterprise Award, which supports FDIC-insured financial institutions that are
dedicated to financing and supporting community and economic development activities.
Community Development Loans, Investments and Grants
Chase provides significant financing for affordable housing, both nationally and in Broward County. In addition, the bank supports
economic development projects in low- and moderate-income communities. The bank has made over $23 million in community
development loans resulting in the development of 264 units of affordable housing units for low- and moderate-income households.
The bank also demonstrates excellent responsiveness to community development needs through its significant level of community
development investments. Chase makes substantial investments in Low-Income Housing Tax Credits (LIHTC) that help finance lowand moderate-income affordable housing. During this period, community development investments in LIHTC has totaled over $8.7
million for projects in Broward County; resulting in the development of 395 units of affordable housing.
Service Test
The bank’s performance in the Fort Lauderdale-Pompano Beach-Deerfield Beach area is weaker than the overall good performance in
the state, due to less accessible branch distribution.
The distribution of branches provides generally good accessibility to geographies and individuals of different income levels in the
bank’s AAs.
The bank’s level of community development services provided is good overall; Chase provides financial services education in LMI area
branches to homebuyers and homeowners trying to preserve their homes and in LMI area schools. The bank maintains a significant
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number of ongoing relationships with organizations that work on affordable housing, education initiatives, small business development,
and other community development goals.
Community Development Services
Homebuyer fairs, seminars, Mortgage Day events at local bank branches, technical assistance and memberships on community boards
are examples of community development services that are provided by Chase employees. The bank has hosted 35 homebuyer fairs and
seminars; held 5 Mortgage Day events; provided technical assistance to help promote and support programs for the development,
financing and marketing of affordable housing; and its employees served on boards with local organizations that help address affordable
housing needs in the market. During this period, more than 1,000 Broward County residents directly benefited from the bank’s
community development services.
Pertinent Broward County Information and Data Submitted by Bank:
Housing Related Products and Services
Home Loans
Purchase Money Mortgages
Home Equity Term Loans
Home Equity Lines of Credit
Home Improvement Loans
Home Construction Loans
Real Estate Loans
Commercial Construction Loans
Letters of Credit
Farm Loans
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Performance Evaluation (PE)
Date: 09/30/09
PNC Bank, National Association
Bank Contact
(CRA Officer)
Lucy A. Carr
Vice President
Community Consultant
Community Development Banking
PNC Bank
205 Datura Street, A2-YB63-02-1
West Palm Beach, FL 33401
561-803-9953
(office)
561-803-9427
(fax)
Pertinent Broward County Information and Data from Regulatory Performance Evaluation:
The major factors that support the Florida rating include:
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PNC’s distribution of lending by geography is poor;
The distribution of PNC’s lending by borrower income is adequate;
PNC’s level of community development lending is excellent and had a significantly positive impact on the lending test rating.
The bank’s level of qualified investments is good;
Service delivery systems are reasonably accessibility to geographies and individuals of different income levels.
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Pertinent Broward County Information and Data Submitted by Bank:
There is no Broward county information in the Public Disclosure of our last exam. That was dated 9/30/09, which was before any of
Florida became PNC. We are currently in the middle of an exam, and hope to have results to share before too long. There are no Broward
related public comments in our file.
The bank engages in very limited lending within the Florida AAs because loans are made as an accommodation to PNC Advisors clients.
Data in CRA exam is for Naples and Indian River. No data for South Florida. - Fred Garcon LMI Lender
The time the Bank evaluation was performed we were National City Bank. Wealth management issues in Naples, Vero Beach. Acquired
RBC, National City and retail expansion especially in Broward.
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Performance Evaluation (PE)
Sun Trust Bank
Date: 10/12/10
Bank Contact
(CRA Officer)
Beverly Kirton-Smith
Corporate Compliance Manager
SunTrust Banks, Inc.
P.O. Box 4418, Mail Code 663
Atlanta, Georgia 30302
[email protected]
Pertinent Broward County Information and Data from Regulatory Performance Evaluation:
Factors for Florida Rating
 Lending activity reflects excellent responsiveness to assessment area credit needs.
 The geographic distribution of loans reflects excellent penetration throughout the assessment areas. In addition, the
distribution of borrowers reflects good penetration among customers of different income levels and businesses of different
revenue sizes.
 The bank is a leader in making community development loans within the assessment areas.
 The bank provides an excellent level of qualified community development investments and grants in the assessment areas
and is often in a leadership position in response to the community development needs of the assessment areas.
 Retail services are reasonably accessible to the bank’s geographies and individuals of different income levels in the assessment
areas.
 The bank provides a limited level of community development services throughout the assessment areas.
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Conclusions for the Miami Assessment Area (Includes Broward)
The Miami, Florida assessment area includes Broward, Miami-Dade and Palm Beach counties in Florida. These counties make up the
Miami MSA.
Lending Test
The bank’s lending performance is excellent; Lending activity reflects excellent responsiveness to assessment area credit needs. The
geographic distribution of loans reflects excellent penetration throughout the assessment area. Also, the distribution of borrowers
reflects good penetration among borrowers of different income levels and businesses of different revenue sizes. Additionally, the bank
is a leader in making community development loans.
SunTrust Bank is a leader in making community development loans in the Miami, Florida assessment area. The bank originated 19
community development loans totaling $68.3 million during the review period. Most of the loans financed affordable housing or provided
funding to organizations that provide community services to low and moderate-income individuals. Housing-related loans totaled more
than $38 million and included loans involving LIHTCs and HUD-subsidized housing for the elderly. One loan was for the construction of
a condo project in the Overtown empowerment zone. A majority of the units were set aside for low- or moderate income buyers. Loans
related to community services included loans to nonprofit or not-for-profit organizations that provide employment, job training,
childhood education and advocacy, and other community-based programs with a focus on low- or moderate-income individuals or
families.
Investment Test
The bank’s performance under the Investment Test is excellent; SunTrust Bank exhibited excellent responsiveness to credit and
community development needs through its investment activities, which included support for affordable housing. The bank had 39
investments totaling $125.0 million, including 13 current period investments totaling $74.1 million. Qualifying investments included
purchases of HUD, GNMA and SBA 504 investment instruments and LIHTC investments. Additionally, funds were deposited at two
minority SunTrust owned financial institutions. Other qualifying investments funded small businesses, startup companies, and
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community development projects. The investments were responsive to community needs for affordable housing and business
development.
The bank also made contributions totaling approximately $567,000. Grants were provided to a variety of organizations across the
assessment area serving diverse community development needs. Examples of entities receiving qualifying contributions include a
nonprofit organization that provides support and resources to other nonprofit agencies and community groups serving low- and
moderate-income populations; multiple nonprofits providing food, shelter and educational services to homeless individuals; and several
CDCs and CDFIs.
Service Test
The bank’s Service Test performance is adequate; While retail banking services are generally accessible and effective, community
development services are limited in both number and scope.
Pertinent Broward County Information and Data Submitted by Bank:
No additional information submitted.
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Performance Evaluation (PE)
TD Bank, National Association
Date: 12/31/11
Bank Contact
(CRA Officer)
Dennis Lagueux
South Region Group Manager, Community Development
TD Bank
FL1-151-000 1200 Riverplace Blvd.
Jacksonville , FL 32207
T: 904-306-1115
BB: 803-315-9068
F: 416-585-3959
Pertinent Broward County Information and Data from Regulatory Performance Evaluation:
Factors for Florida Rating
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Good lending activity combined with excellent borrower and geographic distributions resulted in the Outstanding Lending
Test rating.
Excellent responsiveness to the investment needs of the AA through the volume of qualified investments originated during
the evaluation period.
Excellent Service Test performance is the result of overall excellent retail services combined with a good level of CD services.
TDBNA has three AAs within the state that were included in this evaluation. They include the West Palm Beach MD, Fort Lauderdale MD,
and the Miami MD. Over 53% of TDBNA deposits are in the West Palm Beach MD, which was selected for a full-scope analysis. In late
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2010, TDBNA acquired two financial institutions, which significantly expanded the bank’s operations in Florida and added several new
AAs. Given the timing of these acquisitions during the evaluation period, these added areas were not analyzed in determining the state
rating.
Lending Test
Based on limited-scope review, the bank’s performance under the Lending Test in the Fort Lauderdale and Miami MDs is not inconsistent
with the bank’s overall excellent performance in the state;
Investment Test
Investment Test performance in all of the limited-scope areas is not inconsistent with the excellent performance noted in the state.
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Services Test
Service Test performance in both limited-scope MDs is weaker than the overall excellent performance in the state and is considered
good. The weaker performance is due to branch distribution.
Pertinent Broward County Information and Data Submitted by Bank:
No additional information submitted.
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Performance Evaluation (PE)
Wells Fargo Bank, National Association
Date: 09/30/08
Bank Contact
(CRA Officer)
Kelly Kinsell
Community Development Officer
SVP Wells Fargo Bank
350 East Las Olas Blvd.
Fort Lauderdale, Fl 33301
MACZ6074-180
954-765-3812 (Phone) 954-765-3883 (Fax)
[email protected]
Pertinent Broward County Information and Data from Regulatory Performance Evaluation:
Wells Fargo compliance team inquiry results found there are no public comments for Broward County in Wells Fargo’s CRA Public File;
**Wells Fargo had not yet entered Florida as of the date of its latest CRA exam. Below data is for the institution as a whole, and does not
reflect any Florida activities.
Lending Test
Wells Fargo Bank, National Association (WFB) demonstrated lending levels that reflected excellent responsiveness to the credits needs
in the majority of assessment areas (AAs). During the evaluation period, WFB originated a very large volume of HMDA and CRA
reportable loans in relation to the dollar volume of bank’s deposits in its AAs;
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WFB’s geographic distribution and distribution by income of the borrower or revenue of the farm or business has been generally good.
Although there were some AAs where performance was excellent, other AAs showed only adequate performance. It is important to note,
however, that distribution of loans by revenue of the business was, with only few exceptions, excellent.
WFB’s volume and nature of community development lending had a significantly positive impact on the Lending Test rating. Community
development lending had a significantly positive impact on 12 of the 17 AAs in the full-scope primary rating areas and 24 of the 36 in the
non-primary full-scope AAs.
Home Mortgage 2011YE: In Broward County, FL, Wells Fargo provided 7,381 mortgage loans (total HMDA), extending $1.4 billion in
credit. Of that, 967 mortgage loans were in LMI communities, providing $115.9 million in credit and 1,781 loans were made to LMI
borrowers, providing $155.3 million in credit.
Home Mortgage 2012YE : In Broward County, FL, Wells Fargo provided 10,577 mortgage loans (total HMDA), extending $2.3 billion in
credit. Of that, 1,634 mortgage loans were in LMI communities, providing $288.5 million in credit and 914 loans were made to LMI
borrowers, providing $222.4 million in credit.
Investment Test
WFB’s performance, as measured primarily by volume of investments, was excellent in 11 of the 17 full-scope AAs in the primary rating
areas and 22 of the 36 full-scope AAs in the non-primary rating areas.
WFB has invested millions of dollars in many of its AAs in support of community development. Identified needs are great, and WFB has
addressed many of those needs, especially those for affordable housing. WFB often invests in large national or regional funds that, in
turn, make investments, typically in projects that qualify for Low Income Housing Tax Credits (LIHTC), in many of WFB’s AAs;
The qualified investments made by WFB are useful and effective in meeting the needs of its communities and their residents. With
exceptions, they are not innovative.
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Service Test
WFB’s retail delivery systems, including branches and ATMs, are readily accessible to a majority of the bank’s AAs;
WFB’s opening and closing of branches generally has not adversely affected the accessibility of its delivery systems, particularly in lowand moderate-income geographies and to low- and moderate-income individuals.
WFB is a leader in providing community development services in the majority of its full-scope AAs in the primary rating areas and many
of its full-scope AAs in the non-primary rating areas.
Pertinent Broward County Information and Data Submitted by Bank:
President Mr. John Stumpf Statement
“At Wells Fargo, Community Reinvestment is an integral part of our business culture; Wells Fargo has long understood that we can be
no stronger, nor more successful, than the neighborhoods and communities where we do business. Supporting our communities allows
us to better meet our customers' financial needs and helps us to achieve our goal to be one of America's best companies” – John Stumpf
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Performance Evaluation (PE)
Bank of America
Date: 07/25/13
Bank Contact
(CRA Officer)
Maria C. Alonso
Bank of America
SVP | Miami and Ft. Lauderdale Market Manager
Corporate Social Responsibility
305.347.2939
[email protected]
Pertinent Broward County Information and Data from Regulatory Performance Evaluation:
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Pertinent Broward County Information and Data Submitted by Bank:
No additional information submitted.
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Performance Evaluation (PE)
Northern Trust
Date: 06/25/12
Bank Contact
(CRA Officer)
Deborah Kasemeyer
Senior Vice President and CRA Officer
Northern Trust Corporation
50 South LaSalle Street
Chicago, IL 60603
phone (312) 444-4031
fax (312) 935-5867
[email protected]
northerntrust.com
Pertinent Broward County Information and Data from Regulatory Performance Evaluation:
CRA RATING FOR FLORIDA: Outstanding
The Lending Test is rated: Outstanding
The Investment Test is rated: Outstanding
The Service Test is rated: High Satisfactory
Summary of major factors supporting the bank’s rating:
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Lending levels reflect excellent responsiveness to assessment area credit needs.
Excellent geographic distribution of loans and excellent distribution of loans among borrowers of different income levels and
businesses of different sizes, as well as the use of innovative and flexible lending practices in serving assessment area credit needs.
A leader in making community development loans.
Excellent level of qualified investments that are responsive to assessment area credit needs.
Service delivery systems are reasonably accessible to census tracts and individuals of different income levels.
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
A relatively high level of community development services.
Scope Of Examination
The scope of the evaluation was consistent with the scope described in the institution summary. Full review examination procedures
were used to evaluate the Miami-Fort Lauderdale-Pompano Beach, FL MSA 33100, which includes three Metropolitan Divisions (MDs):
Fort Lauderdale-Pompano Beach-Deerfield, FL MD 22744, Miami-Miami Beach-Kendall, FL MD 33124 and West Palm Beach-Boca RatonBoynton Beach, FL MD 48424; Results from this assessment area were used to determine the full state’s rating; Limited review
procedures were used to evaluate the following assessment areas: Cape Coral-Fort Myers, FL MSA 15980, Naples-Marco Island, FL MSA
34940, North Port-Bradenton-Sarasota, FL MSA 35840, Port Lucie, FL MSA 38940, Sebastian-Vero Beach, FL MSA 42680 and the TampaSt. Petersburg-Clearwater, FL MSA 45300.
Description Of Institution’s Operations in Florida
As of June 25, 2012, the bank operated 24 branches in the state of Florida: 4 in moderate-income, 6 in middle-income and 14 in upperincome census tracts. Five of the branches, two of which are in moderate-income census tracts, have full service ATMs.
Major cities served include, but are not limited to, Miami, Broward, Palm Beach, Bradenton, Sarasota, Venice, Tampa, St. Petersburg,
Naples, Vero Beach, Fort Myers and Stuart. Refer to the individual assessment area summaries for demographic and economic conditions.
The assessment areas located in the State of Florida are as follows:
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CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS IN FLORIDA
Lending Test
TNTC’s performance relative to the lending test is rated Outstanding based on the distribution of home mortgage loans reflecting
excellent penetration among census tracts and borrowers of different income levels, the bank’s a leader in making community
development loans, makes extensive use of innovative and or flexible lending practices in serving assessment area credit needs and has
excellent responsiveness to the credit needs of low-income individuals and geographies and very small businesses.
Geographic And Borrower Distribution
The distribution of loans reflects excellent penetration among census tracts and borrowers of different income levels based on lending
patterns for HMDA-reportable home mortgage loans in the Miami-Fort Lauderdale-Pompano Beach MSA. Small business lending activity
reported under CRA was also evaluated and considered for the purposes of assigning a rating.
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The bank makes use of flexible or innovative lending practices and programs to enhance credit accessibility among low- and moderateincome populations and in low- and moderate-income areas. Specifically, the bank participates in the Miami-Dade County Surtax Loan
Program, the City of Miami Homebuyer Assistance Program, the Metro Miami Action Plan Housing Assistance Program, the City of North
Miami Homeownership Assistance Program, and offers the Neighborhood Home Ownership Loan Product to enhance access to credit
for safe, affordable and permanent housing. The table below details the NHOP loans originated in the state of Florida.
Loans originated through this program are included in the total home mortgage lending analyzed for the lending test.
Details regarding the bank’s lending patterns are discussed under the individual assessment area summaries;
Community Development Lending
TNTC originated a relatively high level of community development loans in the state of Florida during the review period: 43 loans totaling
$46.3 million. Community development lending activities were focused on affordable housing and community services, which is
consistent with needs identified by community representatives. The following table presents community development loans throughout
the state and additional information is discussed in the individual assessment area sections.
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Investment Test
TNTC’s performance relative to the investment test in the State of Florida is rated Outstanding based on an excellent level of qualified
investments during the review period, often in a leadership position.
The bank funded $65.3 million in qualified investments during this review period in the state of Florida: $40.4 million in mortgagebacked securities (MBS), $19.2 million in LIHTCs and $1.1 million in NMTCs. The majority of the investments were for the provision of
affordable housing to low- and moderate- income individuals in the state of Florida. There were prior period investments with current
balances of $18.5 million and $1.5 million in unfunded investments. The bank made $154,667 of grants and donations in the state of
Florida. Additional detail is discussed in the individual assessment area sections.
Service Test
TNTC’s performance relative to the service test in the state of Florida is rated High Satisfactory based on retail services being accessible
to essentially all portions of the assessment area and changes in the branch and ATM network not adversely affecting the accessibility of
the bank’s delivery systems; The bank also provides reasonable business hours that do not vary in a way that inconveniences its
assessment area, particularly low- and moderate-income geographies and individuals. The bank provides a good level of community
development services in the state of Florida.
Retail Services
Retail services are accessible to essentially all portions of the assessment area and changes in the branch and ATM network did not
adversely affect the accessibility of the bank’s delivery systems in the state of Florida; The bank had 24 branches located in the state of
Florida with 4 (16.7 percent) located in low- or moderate-income geographies. The table below provides a breakdown of the branch
distribution by income level of the geography. The bank provides reasonable business hours that do not vary in a way that
inconveniences its assessment area, particularly low- and moderate-income geographies and individuals.
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During the review period, TNTC closed one branch office in the Ft Lauderdale-Palm Beach-Deerfield MD assessment area; the branch
was located in an upper-income census tract; The change in the bank’s branch network did not adversely affect its accessibility,
particularly to low- and moderate-income areas and for low- and moderate-income populations.
Community Development Services
The bank provides a good level of community development services in the state of Florida. The majority of the services were provided
to organizations that deliver community services and affordable housing to low- and moderate-income individuals in the state of Florida.
The bank provided a relatively high level of community development services in the assessment areas subject to a full review.
Service activities were primarily in affordable housing and community services, which is consistent with community needs identified by
community representatives. The following table presents community development services throughout the state, additional information
is discussed in assessment area sections.
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MIAMI-FT LAUDERDALE-POMPANO BEACH, FL MSA 33100 – FULL REVIEW
Description Of Institution’s Operations In Miami-Ft Lauderdale-Pompano Beach MSA 33100
The Miami-Ft Lauderdale-Pompano Beach MSA consists of three MDs. Each MD consists of one entire county: Ft Lauderdale-Pompano
Beach-Deerfield, FL MD 22744 (Broward County), Miami-Miami Beach-Kendall, FL MD 33124 (Miami-Dade County) and West Palm
Beach-Boca Raton-Boynton Beach, FL MD 48424 (Palm Beach County). There are 891 census tracts in the assessment area of which 54
(6.1%) are low-income, 241 (27.0%) are moderate-income; 320 (35.9%) are middle-income; 271 (30.4) are upper-income and 5 (0.6%)
have unknown income levels.
As of June 25, 2012, the bank operated a total of eleven branches in the MSA; The following table presents the bank’s branches within the
three metropolitan divisions:
The bank operates one full-service ATM in an upper income census tract in the Miami-Miami Beach-Kendall MD.
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HMDA-reportable lending in this assessment area accounts for 14;0 percent of the bank’s total lending; CRA-reportable lending accounts
th
for 21.4 percent. Based on the FDIC Market Share Report as of June 30, 2011, the bank rank’s 10 of 112 institutions in the assessment
area with a market share of 2.4 percent. There have been no changes in the assessment area since the previous evaluation.
The following tables provide a summary of key demographics in the assessment area and its metropolitan divisions:
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Population
According to the 2000 census, 4.2 percent of the population is low-income, 28.1 percent is moderate-income, 37.7 percent is middleincome and 29.9 percent is upper-income.
Based on the 2010 U;S; Census Bureau data, the total population of the bank’s assessment area is 5;56 million comprised of 1;7 million
in Broward County, 2.5 million in Miami-Dade County and 1.3 million in Palm Beach County. The population of the counties in the bank’s
assessment area increased at a slower rate than the population for the state of Florida. Population growth in the West Palm Beach-Boca
Raton-Boynton Beach MD experienced the largest percentage increase while population growth in Fort Lauderdale-Pompano BeachDeerfield MD experienced the lowest percentage of growth.
Additional demographic information is presented in the following table:
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Income Characteristics
The 2006 to 2010 median family income for the assessment area increased 22.8 percent. This compares less favorably to the state of
Florida where median family income increased by 25.4 percent. All the MDs in the assessment area experienced increases in median
family incomes between 2006 and 2010. The Miami-Miami Beach-Kendall MD experienced the largest percentage increase in income
(24.4 percent) while the West Palm Beach-Boca Raton-Boynton Beach MD experienced the lowest percentage increase (20.0 percent).
The table below presents a comparison of the median family income for the assessment area and its metropolitan divisions to the state
of Florida.
The personal bankruptcy filing rate for both Broward and Palm Beach Counties decreased in 2011. Personal bankruptcy filings decreased
in Broward County from 6.8 per 1,000 population in 2010 to 5.8 in 2011 and in Palm Beach County from 4.7 in 2010 to 4.2 in 2011.
Broward County ranked sixth highest of the 67 counties in the state for personal bankruptcy filings comparing unfavorably at both state
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and national levels. Personal bankruptcy filings in Palm Beach County were 18 highest in the state. This compares favorably on both
the state and national levels. Personal Bankruptcy filings for the state of Florida were 5.7 per 1,000 population in 2010 and 4.7 in 2011
comparing less favorably on a national level 4.9 in 2010 and 4.3 in 2011. Data for Miami- Dade County was not reported.
Housing Characteristics and Affordability
The median housing value more than doubled within the assessment area and its metropolitan divisions between the 2000 census and
the 2006-2010 American Community Survey. The state of Florida experienced similar growth. According to 2000 U.S. Census Bureau
Data, there are 2,149,749 housing units in the assessment area, of these, 58.5 percent are owner-occupied. Of the total owner-occupied
units, 21.3 percent are in low-income geographies and 47.1 percent are in moderate-income geographies.
According to the 2000 census, the affordability ratios for the counties in the assessment area are: Broward County .41, Miami-Dade
County .32 and Palm Beach County .39. These ratios are below the state of Florida with an affordability ratio of .42, indicating that housing
is generally less affordable in the assessment area.
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Between December 2009 and December 2011, the percentage of homes in foreclosure increased in Broward and Miami-Dade Counties,
and decreased slightly in Palm Beach County. The table below presents the foreclosure inventory rate (FIR) at the county level.
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Labor and Employment
Unemployment rates in the assessment area are higher than the national average. This is particularly true for the Miami-Miami Beach–
Kendall MD, which has unemployment rates which are notably higher than the nation.
According to the National Association of Realtors data, 44,043 housing permits were issued in Florida during 2011, compared to 39,524
issued during 2010, an increase of 11.4 percent. Nationwide, housing permits increased 2.1 percent during the same period. By
comparison, housing permit activity in the three counties comprising the assessment area show larger increases in activity. Total housing
permits in Palm Beach County increased 65.4 percent from 1,511 in 2010 to 2,499 in 2011. Of the total permits issued, single family
housing permits increased 50.1 percent over 2010 levels while multifamily housing permits increased 140.8 percent. In Miami –Dade
County, total housing permits increased from 5,887 in 2010 to 7,574 in 2011, representing a 28.7 percent increase. Of the total permits
issued, single family housing permits increased 35.1 percent over 2010 levels while multifamily housing permits increased 21.0 percent.
Total housing permits in Broward County experienced the largest percentage increase from 1,168 in 2010 to 2,440 in 2011, a 108.9
percent change. Of the total permits issued, single family housing permits increased 47.3 percent over 2010 levels while multifamily
housing permits increased 428.0 percent. While demand for single family housing continues, there is also an increasing demand for
multifamily housing in the three-county area.
The largest industries in the assessment area are Professional, Scientific and Technical Services, Retail Trade and Health Care.
Information from five community contacts representing small business, economic development and housing sectors of the local economy
was used in evaluating bank performance in the assessment area. The area is still recovering from the recent economic recession and
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the collapse of the real estate market. The contacts stated financing for affordable housing, as well as operating and expansion financing
for small businesses are challenges facing the community.
CONCLUSIONS WITH RESPECT TO PERFORMANCE TESTS (MIAMI-FT LAUDERDALE-POMPANO BEACH, FL MSA 33100)
Lending Test
TNTC’s performance relative to the lending test is excellent based on the bank’s record of lending in low- and moderate-income
geographies and to borrowers of different income levels, product innovation and flexibility and the relatively high level of community
development lending.
Geographic Distribution of Loans
Home Purchase Loans
The distribution of the bank’s home mortgage loans reflects excellent penetration among census tracts of different income levels in the
assessment area based on the distribution of HMDA-reportable home purchase loans; The bank’s lending in the Fort LauderdalePompano Beach-Deerfield and the Miami- Miami Beach-Kendall MDs carried the most weight in assigning the rating. A discussion of the
bank’s performance in each of the metropolitan divisions follows:
Ft Lauderdale-Pompano Beach-Deerfield MD
Home purchase loans in this metropolitan division represented 85.5 percent of total HMDA-reportable originations. The bank originated
5.2 percent and 27.3 percent of its home purchase loans in low- and moderate-income census tracts, respectively. This compares
favorably to the aggregate of all lenders who originated 1.3 percent in low-income and 15.3 percent in moderate-income census tracts.
The percent of originations in low- or moderate-income geographies exceeded the percentage of owner-occupied housing units. The
number of home purchase loans originated in 2011 decreased by 26 loans from 2010. The percentage of originations in low-income
census tracts increased to 9.8 percent while the percentage of originations in moderate-income census tracts decreased to 17.6 percent.
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Ft l auderdale-Pompan o Beach-Deerfield MD
Home Mortgage l ending, 2010
G eographic Distrib ution
(OOOs)
Census
Bank l oans
Tract
Income
Level
e
s
I %. I
Home Purchase Loans
1,425
l ow
4
5.2
5.4
1,303
Moderate
21
27.3
4.9
3,797
Middle
27
35.1
14.1
Upper
19,925
25
32.5
75.3
Unknown
0
0.0
0
0.0
26,450 100.0
Total
77 100.0
Refinanced l oans
l ow
0
0.0
0
0.0
Moderate
0
0.0
0
0.0
1,024
Middle
4
30.8
17.8
Upper
9
69.2
4.735
822
Unknown
0
0.0
0
0.0
5,759 100.0
Total
13 100.0
Home Improvement Loans
l ow
0
0.0
0
0.0
Moderate
0
0.0
0
0.0
Middle
0
0.0
0
0.0
Upper
0
0.0
0
0.0
Unknown
0
0.0
0
0.0
Total
0
0.0
0
0.0
Multiiamily Loans
l ow
0
0.0
0
0.0
Moderate
0
0.0
0
0.0
Middle
0
0.0
0
0.0
Upper
0
0.0
0
0.0
Unknown
0
0.0
0
0.0
Total
0
0.0
0
0.0
Total Home Mortgage Loans
1,425
l ow
4
4.4
4.4
1,303
Moderate
21
23.3
4.0
Middle
31
34.4
4.821
15.0
Upper
34
37.8
24.660
76.6
Unknown
0
0.0
0
0.0
Total
90 100.0
32.209 100.0
Note: Percent11.ges 111Jllf not total to 100.0 percent due to rounding.
..
Aggregate of All l enders
(Peer)
=~(,
s•.
1.3
15.3
45.3
38.1
0.0
100.0
1.0
9.2
36.9
52.9
0.0
100.0
0.7
7.6
32.8
58.9
0.0
100.0
0.6
4.6
26.9
68.0
0.0
100.0
0.4
15.4
39.9
44.3
0.0
100.0
0.3
6.7
26.6
66.4
0.0
100.0
10.0
33.3
40.0
16.7
0.0
100.0
11.1
15.2
56.9
16.8
0.0
100.0
1.1
12.3
40.3
46.3
0.0
100.0
1.4
7.7
33.9
57.0
0.0
100.0
OwnerOccupied
Housing
..
1.0
23.8
45.9
29.2
0.0
100.0
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Home Purchase Loans
The distribution of the bank’s home mortgage loans reflects excellent penetration among borrowers of different income levels and
businesses of different sizes. The analysis is based primarily on HMDA-reportable home purchase loans; The bank’s lending in the Fort
Lauderdale-Pompano Beach-Deerfield and the Miami- Miami Beach-Kendall MDs carried the most weight in assigning the rating. A
discussion of the bank’s performance in each of the metropolitan divisions follows:
Ft Lauderdale-Pompano Beach-Deerfield MD
In 2010, the bank originated 20 home purchase loans to low-income borrowers representing 26.0 percent of total home mortgage loans.
This exceeded both the aggregate of all lenders that originated 7.8 percent to low-income borrowers and the presence of low income
families at 20.9 of the total families. The bank originated 30 loans to moderate-income borrowers, representing 39.0 percent of all home
purchase loans. The bank exceeded the performance of the aggregate of all lenders who originated 22.6 percent to moderate-income
borrowers and the demographic of moderate-income families present in the assessment area. In 2011, the bank originated 19.6 percent
and 27.5 percent to low- and moderate-income borrowers respectively.
The following table presents the bank’s lending in the Ft Lauderdale-Pompano Beach-Deerfield MD:
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Community Development Lending
TNTC is a leader in making community development loans. The bank originated 21 loans for affordable housing totaling $28.9 million
and 22 loans totaling $17.4 million for community services. The following table presents the banks community development loans within
the assessment area by metropolitan division.
Investment Test
The bank had an excellent level of qualified investments during the review period. The bank makes extensive use of innovative and/or
complex investments, often in a leadership position, to support community development initiatives and exhibits excellent
responsiveness to credit and community development needs.
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The majority of the new investments were made in Dade County: $9,216,421 in MBS for multifamily affordable housing, $18,172,077
LIHTCs and new market tax credits $1,095,916. New investments made in Broward County totaled $7,139,600 for mortgage backed
securities financing multifamily affordable housing. Investments in Palm Beach County represented $479,223 in low-income housing tax
credits and $841,004 in mortgage backed securities financing multifamily affordable housing. Additionally, $426,100 represents
investments in local community development financial institutions and $1,147,582 in investments for economic development projects
throughout the MSA.
The following table presents the bank’s investments during the review period.
In addition, the bank made $84,667 in grants during the review period in the Miami MD to organizations providing on community
services.
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Service Test
TNTC’s performance relative to the service test in the Miami-Fort Lauderdale-Pompano Beach MSA is good; The bank’s level of
community development services received more weight in assigning the rating; The bank’s delivery systems are reasonably accessible
to geographies and individuals of different income levels; The bank’s record of opening and closing branches has not adversely affected
the accessibility of its delivery systems, particularly in low- and moderate- income geographies or to low- and moderate- income
individuals. The bank provides a relatively high level of community development services.
Retail Services
As of the examination date, the bank operates 11 branches in this assessment area. Of those offices, three were located in middle-income
and eight were located in upper-income census tracts. Since the previous review, the bank closed one branch in an upper-income census
tract. The distribution of branches in this assessment area can be found in the Florida state section of this report. Services do not vary in
a way that inconveniences its assessment area, particularly low- and moderate-income geographies or individuals.
Community Development Services
The bank provides a relatively high level of community development services. A table containing information related to the Community
Development Services in this assessment area can be found in the Florida state section of this report.
Bank officers and employees provided over 792 hours of service to 19 qualified development organizations within this assessment area.
Community development services included serving on the boards of local organizations that provide affordable housing or community
services to low- and moderate-income individuals or geographies.
The bank’s performance in the Miami-Fort Lauderdale-Pompano Beach MSA, consisting of three metropolitan divisions, was given
greater weight in determining the overall rating for the state of Florida.
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