1. Ohio fair lending coalition
26th Annual Ohio Fair Lending Conference
13 November 2015
Thenessa Savitsky Research Analyst Organize! Ohio

2. Why do a bank challenge?
Reinforce the Community Reinvestment Act and HMDA Disclosure Act
Engage banks in fair lending
Encourage banks to improve outreach to disadvantaged communities
Community development
It’s important to take every opportunity you can to challenge these banks on their practices. For example, when a bank closes down a branch (?) or merges with another bank institution. We recently got an opportunity to do a bank challenge at Organize! Ohio when we discovered that New York Community Savings Bank was going to be merging with its corporate institution, New York Community Bancorp. I did research and outlined

3. Deposit and Market Share Value Totals for all Bank Institutions in Cuyahoga County, 2014
Institution Name  
Number of Offices
Deposits ($000)
% Market Share
KeyBank National Association 55
11,929,053
27.82%
PNC Bank, National Association 53
6,070,306
14.16%
Third Federal Savings and Loan Association of Cleveland 14
4,726,212
11.02%
Citizens Bank, National Association 45
4,306,757
10.04%
The Huntington National Bank 56
3,692,132
8.61%
Fifth Third Bank 39
2,590,571
6.04%
JPMorgan Chase Bank, National Association 18
1,879,276
4.38%
U.S. Bank National Association 46
1,672,693
3.90%
Dollar Bank, Federal Savings Bank 21
1,423,608
3.32%
New York Community Bank 20
1,398,142
3.26%
Firstmerit Bank, National Association 23
1,316,427
3.07%
First Federal Savings and Loan Association 13
993,294
2.32%
First National Bank of Pennsylvania 9
354,662
0.83%
Independence Bank 1
145,255
0.34%
Liberty Bank, National Association 2
124,158
0.29%
Peoples Bank, National Association
107,678
0.25%
Westfield Bank, FSB
49,230
0.11%
Talmer Bank and Trust 3
37,986
0.09%
The Lorain National Bank
24,929
0.06%
The Northern Trust Company
23,043
0.05%
The Pioneer Savings Bank
13,520
0.03%
Woodforest National Bank
3,993
0.01%
Beal Bank, SSB
606
0.00%
Credit First National Association
500
The Bank of New York Mellon Trust Company, National Association
Wells Fargo Bank, National Association
The data speaks for itself. It practically screams for itself.

4. Individual Branch Address
New York Community Savings Bank Individual Branch Deposit Totals in Cuyahoga County, 2014
Individual Branch Address
City
Zip Code
Deposit Total ($000)
      20133 Farnsleigh Road
Shaker Heights
44122
63,096
      26300 Cedar Rd
Beachwood
75,825
      27810 Chagrin Blvd
75,603
      15001 Snow Road
Brook Park
44142
48,805
      3300 Warren Road
Cleveland
44111
60,376
      1866 West 25th Street
44113
14,509
      1801 East Ninth Street
44114
32,727
      2066 Lee Road
Cleveland Heights
44118
45,308
      14033 Cedar Rd
South Euclid
92,139
      6500 Mayfield Rd
Mayfield Heights
44124
96,597
      6016 Turney Road
44125
71,741
      6290 Pearl Rd
44130
109,234
      5767 Broadview Road
44134
127,043
      720 Richmond Rd
Richmond Heights
44143
67,494
      4800 Great Northern Boulevard
North Olmsted
44070
72,867
      6520 Royalton Road
North Royalton
44133
66,866
      22255 Center Ridge Rd
Rocky River
44116
77,896
      34400 Aurora Road
Solon
44139
71,607
      14177 Pearl Road
Strongsville
44136
93,735
      30210 Detroit Road
Westlake
44145
34,674
      Total for Cuyahoga County
20 Office(s)
1,398,142
Figure 2. New York Community Savings Bank Deposit Totals for each Branch in Cuyahoga County, This table lists the locations and deposit totals for each branch of New York Community Savings Bank in Cuyahoga County for The values are in billions.
As shown above in Table 1, New York Community Savings Bank ranks within the upper tier for total deposit amounts in Cuyahoga County (ranked 10 out of 26 total institutions). Their deposit total is high relative to their amount of branch offices (20). Figure 2 explains this disproportion, as most of the deposits for New York Community Savings are concentrated in branches that are located in high-income neighborhoods, such as Beachwood, Mayfield Heights, and Strongsville. However, even in a low- to moderate-income city like South Euclid which accounts for the fifth highest amount in deposits ($92,139,000), New York Community Savings Bank makes no loans.

5. As shown above in Figure 3 to the right, New York Community Savings Bank ranks the lowest in terms of lending (tied with LoanDepot.com, LLC) in the entire county, with only 0.07% of the county market share loan value for

6. Figure 4 above demonstrates clearly how New York Community Savings Bank fails to lend at an appropriate rate. While it accounts for 3.26% of the deposit market share in Cuyahoga County for , it only accounts for 0.07% of the loan market share. Other institutions with similar deposit market share values such as U.S. Bank and JP Morgan Chase lend at a rate that is even greater than that of their market share value. Most of the other institutions represented here have equal ratios of deposit market share values and loan market share values. With the amount of deposits that New York Community Savings Bank accrues annually, it should be approving many more loans in the communities in which its branches are located.
They make no small business loans and hvaeno branches in low-income communities.
Figure 4. Average percentage ratio of deposits to loans in Cuyahoga County for the years for several lending institutions. New York Community Savings Bank is shown in comparison to other local lending institutions.

7. Originations and Purchases
Total Home Purchase Loans in Euclid and South Euclid vs. Income Level (2013)
Loans
Applications
Originations and Purchases
Pre-approvals
  Income Level # %
Amount ($000)
Amount($000)
Low < 50% 1
3.70 62
3.51
5.88
3.59
Moderate % 5
18.52
392
22.20 4
23.53
353
20.44
Middle % 2
7.41
111
6.29
11.76
6.43
Upper > = 120% 6
22.22
812
45.98
35.29
47.02 NA
14.81
389
22.03
22.52 3
Total(Ex-Preapprv) 18
66.67
1766
100.0 17
1727
Total(In-Preapprv) 27 9
Less Market 22
2,556 21
2,284
All Market 40
4,322 38
4,011
Home purchase loans accounted for 27 of all loan applications from FY 2013, though only 17 of them were originated (including preapprovals). This makes the origination rate in E/SE 63% for home purchase loans. By examining the amount of loans across income groups in Table 1A and adding them together, it can be seen that the total amount of home purchase lending was valued at $1,727,000 in E/SE, or a value of $102,000 per loan originated. Nearly 50% of this lending was for those with incomes above 120% of the median level income in the area. When compared to Moderate and Middle income loans (which are the same in number), that value is nearly twice as high. It is obvious that lenders prefer originating loans to those above 120% of the median area income

8. Distribution of Loans by Tract Income Level For New York Community Savings Bank and NYCB Mortgage Company, LLC in Cuyahoga County, 2013
Tract Income Level
Count %
Amount
Low 38
10.27
6,041
7.70
Moderate 64
17.30
12,318
15.70
Middle
142
38.38
32,858
41.88
Upper
126
34.05
27,241
34.72
Total
370
100.00
78,458
Figure 5 above shows the distribution of loans to low-, moderate-, middle-, and upper-income neighborhoods for both New York Community Savings Bank and its subsidiary NYCB Mortgage Company, LLC. The disparity between the loans provided to low-income and upper-income neighborhoods is troubling; together, these institutions lend to upper-income neighborhoods 27% more than they do low-income neighborhoods. The difference between lending to low-income and middle-income neighborhoods is even greater at 34%. This demonstrates that low-income neighborhoods are especially disfavored in lending, and that these institutions need to greatly improve their outreach methods to these communities.
Figure 5. Distribution of Loans by Tract Income Level for New York Community Savings Bank and NYCB Mortgage Company, LLC in Cuyahoga County, Obtained via CRA Wiz.

9. Race Ethnicity Minority Status
Race
Originated
Denied
Withdrawn
Incomplete
Purchased
Total
American Indian/Alaska Native 1
Asian 28 29
Black or African American 22 2 24
Hawaiian / Pacific Islander
White
105 15
130
2 or More Minority Races
Joint Race (White/Minority)
Race Not Available 14
170
185
Total Race 19
370
Ethnicity
Hispanic or Latino 3
Not Hispanic or Latino
153 17
180
Joint (Hisp/Lat / Not Hisp/Lat)
Ethnicity Not Available
Total Ethnicity
Minority Status   
White Non-Hispanic
101
124
Others, Including Hispanic 53 4 59
Total Applications
Figure 6 above shows that these institutions tend not to lend on an individual basis to people of color. Out of 170 total loan applications that were originated, more than 61.8% were to White people, 12.9% to Black or African American people, 16.5% to Asian people, 1.2% to Hispanic/Latino people, and 0.5% to people of mixed race. No Hawaiian, Pacific Islander, American Indian, or Alaskan Native people received loans, but 1 loan was denied to someone of American Indian/Alaska Native heritage, and 2 loans were denied to people of Black/African American heritage. People of color are more likely to be from low-income neighborhoods than White people, which places them at an intersection of racial minority status and low-income status that creates an even greater disadvantage.
Figure 6. Race and Ethnicity vs. Loan Application Status for New York Community Bank and NYCB Mortgage Company, LLC, 2013.

10. Implications & Next Steps
Addressing income and racial disparities in lending
Importance of open and accessible data
Citizen science & crowdsourcing data
Report submissions to FDIC
These lending patterns we see the numbers but these numbers are human. #70687 was a Native American widow with 3 children denied home refinancing loan after her husband died.
It’s easy to look at data, see these huge patterns, and not be moved, even when the numbers are startling. It’s more difficult when