1. Fair Lending Report for Euclid and South Euclid
Thenessa Savitsky Chip Bromley Eric Moizuk

2. Executive Summary 3 year study: 2011, 2012, 2013
Large amounts of deposits but very few loans
New York Community Savings Bank/Ohio Savings Bank had $92 million in deposits as of June 2015 but gave NO loans
Less lending in low- to moderate-income communities
Lenders with the most deposits had the lowest origination rates:
Huntington Bank
Fifth Third Bank
U.S. Bank

3. Statutes Affecting Fair Lending
1968 Fair Housing Act
1974 ECOA Equal
1975 Home Mortgage Disclosure Act (HMDA)
Amended in 1989 and 2010
1977 Community Reinvestment Act (CRA)
1991 City of Cleveland Local Lending Ordinance

4. Home Purchase Lending and Race: Euclid, 2011-2013
1A- Home Purchase Loans
1B- Home Refinance Loans
% White
2011
2012
2013
Census Tract #
Value ($000s)
, Euclid
83.93 19
1930 9
1040 15
2021 2
232 5
662 7
1296
, Euclid
50.24 18
1364 14
1068 23
1829 3
323 10
1,011 17
1688
, Euclid
30.62
116 4
277
719 1
109
714 84
, Euclid
46.18 21
1503
2059 16
1237
311
912
772
, Euclid
40.17
182
297
496
422
259
490
, Euclid
63.99 22
1816
1572
1923
448 11
1,109
899
, Euclid
56.7
1290
1213
981
354
1337
, Euclid
50.22
321
388 8
692 98 6
548
454
, Euclid
51.64 12
782
700 13
1027
427
371
983
, Euclid
43.11
351
266
352
108
169
495
, Euclid
23.38 92
247
207 53
, Euclid
41.16
1440 24
2171
2083
728
326
1758
, Euclid
9.03
154
166 82
, Euclid
18.95
1361
428
1088
597
167
559
, Euclid
46.36
608
285
685
152
491
543
, Euclid NA 76 46 50
, Euclid
, Euclid
344
Table 1

5. Home Purchase/Refinance Lending and Race: South Euclid, 2011-2013
2A- Home Purchase Loans
2B- Home Refinance Loans
2011
2012
2013
Census Tract
% White #
Value ($000s)
, South Euclid
19.05 6
535 18
1592
603 3
286 2
188 8
742
, South Euclid
52.55 16
1239 19
906 10 7
666 5
580 11
978
, South Euclid
62.32 9
660 17
1681
781
263
706
976
, South Euclid
68.34 15
2030 22
2889
2979 13
1588
1,037
1393
, South Euclid NA
718
378 4
348
197 1 77
354
, South Euclid
46.11 24
2079 23
1987
1343
669
788 21
1638
, South Euclid
75.99 12
1187
1909 20
2458
597
1,015
953

6. Home Purchase Lending
The tables above show the number and value of home purchase loans and home refinance loans given in Euclid and South Euclid census tracts for , with the percentage White population of each census tract included. The data is divided between home purchase loans (1A/2A) and home refinance loans (1B/2B).
The first column contains each census tract number, the second column contains the percentage of White people within the census tract, the third column is the number of home purchase loans given within the census tract, and the fourth column is the total dollar amount of loans given within the census tract. This same information is provided for 2011, 2012, and 2013 individually. 1B/2B contains all of the same information as 1A/2B, but for Home Refinance Loans.
Highlighted in orange are some of the highest numbers and dollar values of loans given. This information is important because the census tracts that received the most loans and highest loan dollar amounts are also those with the highest White population, over 50%.

7. Home Purchase Lending
Table 1 in the Appendix contains all of the information on home purchase loans from In total, there were 123 home purchase loans given out between 2011 and 2013 including 37 preapprovals, with only 20 denied, withdrawn, or not accepted. This gives the E/SE municipalities a loan origination rate on home purchase loans of 86%. Home Purchase loans accounted for 40% of all loan applications from
The average loan value was $123,000, while the total value across loans was just over $15 million. The majority of home purchase loans given were in middle and upper income census tracts as shown in Table 4 in the Appendix. The nine census tracts that had the highest number of home purchase loans given all reside among middle and upper income census tracts. The racial composition among these tracts tended to be white, with only three of them having a majority minority population. There were 6 loans total in the two low-income census tracts across all 3 years. An additional census tract in the moderate income category with a 90% minority population was given only a single loan across the three year time period.
Appendix Table 6 gives detailed information on tax liens for home purchase loans in the municipalities. In total, over the three years there were 2,305 different tax liens. By far the middle income census tracts tended to have higher numbers of tax liens, though with one exception of a low income census tract having the highest number in 2013 at 61. The pattern presented in the data is that there are higher numbers of tax liens in middle income census tracts because they have the highest number of loans in the first place, and that after 2011, lenders in the secondary home mortgage market began to purchase high numbers of the tax liens available, which explains the high numbers of second liens on homes in 2011 and the steep drop to almost zero in 2012 and 2013.

8. 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
Less Market 22
2,556 21
2,284
All Market 40
4,322 38
4,011

9. Home Purchase Lending
The table above shows the total amount of home purchase loans given in Euclid and South Euclid in the year 2013 based on income bracket.
Highlighted in orange is the percentage of originations and purchases in the low-income bracket and the high-income bracket. Loans in high-income communities are originated approximately 7 times that of low-income communities. While fewer applications are received from low-income communities, even lending to moderate- and middle-income brackets is very low in comparison to high-income brackets.
This data demonstrates that banks’ outreach to low-income areas is severely lacking, and that their lending tends to be reserved for applicants who make upwards 120% of the median income.

10. Home Refinance Lending
Table 2 in the appendix shows the data for Home Refinance Lending in Euclid and South Euclid. There were a total of 171 loans purchased and 118 denied, withdrawn, or not accepted for an origination rate at 59% (there were no preapprovals). Refinance lending accounted for 56% of all lending between 2011 and 2013.
The total value of loans originated was $20,645,000. Compared to home purchase loans, the average loan value is almost the same at $120,000. But across census tracts the lending was fairly even. There were few years/tracts that had extremely high numbers of loans, though there were still a few that had very low numbers. These were the same low income census tracts that were pointed out in Home Purchase lending as well. This time they totaled only 9 loans across the 3 years, where on average other groups totaled much closer to 40 loans.
As for tax liens, there were far more for Home Refinance lending compared to Home Improvement, around triple the number each of the 3 years. The trend in liens among middle income census tracts is also visible in Home Refinance lending, but the trend among purchased liens was absent in this data. Instead, there was an overall sharp rise in the number of liens placed on homes starting in 2012, with 2013 having just under triple the number of liens that were placed in 2011.

11. Home Improvement Lending
Table 3 contains the data for home improvement loans in the municipalities. Home improvement loans account for 4% of all lending from 2011 to 2013, with 8 originations and a total value of $329,000. The number of loans is so small that the origination rate and average value of each loan are not very meaningful in general. An analysis of loans via census tract is also significantly less valuable than for other loan types, but has been done to an extent here.
While not all of the census tracts with high numbers of tax liens coincide with those from the other loan types, the number of census tracts with high numbers of liens do fit into the two trends previously identified, that is, that after 2011 there was a spike in the number of liens purchased and more liens in middle income tracts.

12. Tax Liens (2011-2013) Nearly 1 in 10 properties has a tax lien on it
Most liens are on home refinance loans

13. Conventional/Government Loans vs. Race/Ethnicity, Euclid 2013
Summary Reports - Loan Purpose and Type: Euclid
2013 Peer Mortgage Data -- OH
Conventional Home Purchase
Conventional Home Improvements
Conventional Refinancing
Government Loans
Applicant Race
Count
Percent
American Indian/Alaska Native
0.00 3
2.08 1
0.15
0.19
Asian
2.94
0.69 6
0.92 4
0.76
Black or African American 31
30.39 57
39.58
172
26.26
319
60.53
Hawaiian / Pacific Islander 2
0.31
White 67
65.69 83
57.64
467
71.30
196
37.19
2 or More Minority Races
Joint Race (White/Minority)
0.01
0.57
Race Not Available
Ethnicity
Hispanic or Latino
1.96
0.98
0.46 7
1.33
Not Hispanic or Latino
100
98.04
136
94.44
643
98.17
507
96.20
Joint (Hisp/Lat / Not Hisp/Lat)
0.38
Ethnicity Not Available
4.17 11
2.09
Minority Status
White Non-Hispanic 66
64.71 80
55.56
455
69.47
193
36.62
Others, Including Hispanic 36
35.29 63
43.75
194
29.62
333
63.19
Property Type
One- to Four-Family
101
99.02
144
100.00
654
99.85
527
Manufactured Housing
Multifamily
Total
102
655

14. Conventional/Government Loans vs. Race/Ethnicity, South Euclid 2013
Summary Reports - Loan Purpose and Type: South Euclid 
2013 Peer Mortgage Data -- OH 
Conventional Home Purchase
Conventional Home Improvements
Conventional Refinancing
Government Loans
Count
Percent
Applicant Race
American Indian/Alaska Native
0.00 2
1.77 3
0.46 1
0.21
Asian 11
6.92 7
1.08
0.42
Black or African American 40
25.16 43
38.05
120
18.52
203
42.56
Hawaiian / Pacific Islander
0.15
White 75
47.17 49
43.36
360
55.56
128
26.83
2 or More Minority Races
Joint Race (White/Minority)
1.26 9
1.39 4
0.84
Race Not Available 31
19.50 19
16.81
148
22.84
139
29.14
Ethnicity
Hispanic or Latino 5
4.42 8
1.23 6
Not Hispanic or Latino
126
79.25 87
76.99
489
75.46
339
71.07
Joint (Hisp/Lat / Not Hisp/Lat)
0.62
Ethnicity Not Available 21
18.58
147
22.69
131
27.46
Minority Status
White Non-Hispanic 72
45.28 44
38.94
350
54.01
123
25.79
Others, Including Hispanic 54
33.96
215
45.07
Property Type
One- to Four-Family
159
100.00
113
646
99.69
477
Manufactured Housing
Multifamily
0.31
Total
648

16. Race vs. Loan Action Taken, Cuyahoga County 2014
Approved
Originated
Not Accepted
Denied
Total
American Indian/Alaska Native 34 5 60
110
Asian
388 32
202
785
Black or African American
1,367
106
2,135
4,202
Hawaiian / Pacific Islander 24 44 81
White
12,841
840
6,163
24,187
2 or More Minority Races 3 11 22
Joint Race (White/Minority)
164 9 69
290
Race Not Available
2,169
187
1,254
5,453
Total Race
16,992
1,187
9,938
35,130
Ethnicity
Hispanic or Latino
315 23
514
982
Not Hispanic or Latino
14,501
980
8,131
28,647
Joint (Hisp/Lat / Not Hisp/Lat)
144 12 63
270
Ethnicity Not Available
2,032
172
1,230
5,231
Total Ethnicity
Minority Status
White Non-Hispanic
12,363
808
5,665
22,997
Others, Including Hispanic
2,393
191
3,002
6,577
Total Applications
- Black/African American applicants’ loans are denied at twice the rate they are originated

17. Lending Institution vs. Loan Action, 2011-2013 Euclid and South Euclid
Market Share Rank (%)
Home Purchase
Home Improvement
Refinancing
Originated
Denied
THE HUNTINGTON NATIONAL BANK
3 (5.39%) 13 19
126 51 98
FLAGSTAR BANK
13 (0.68%) 11 9 5
WELLS FARGO BANK, NA
1 (11.81%)
160
181 94 45
CITIBANK, N.A.
10 (2.66%) 3 75 43 12
BANK OF AMERICA, N.A.
9 (2.8%) 34 48 23 10
US BANK, N.A.
7 (3.28%) 55 41 24
NEW YORK COMMUNITY BANK
18 (0.14%) 1
FIFTH THIRD BANK
11 (2.56%) 14 60 18 47
PNC BANK N.A.
4 (4.81%) 36 82 65 66
JPMORGAN CHASE BANK, NA
2 (7.82%) 58 2
169
123
US BK NA ND
6 (3.31%) 70 79
ALLY BANK
16 (0.17%)
CITIMORTGAGE, INC
12 (1.67%) 44
LOANDEPOT.COM, LLC
15 (0.24%) 7
FIFTH THIRD MORTGAGE COMPANY
5 (4.61%) 39 96 64 33
SUNTRUST MORTGAGE, INC
17 (0.14%) 4
QUICKEN LOANS
8 (2.97%) 8 54 26
NATIONSTAR MORTGAGE LLC
14 (0.38%) 6
TOTAL
416
100
1108
593
485

18. Aggregate Mortgage Lending
The table above shows the loan market share ranks/rates and the numbers of each type of loan given by the top 18 lending institutions in Euclid and South Euclid, as well as the number of loans that were originated and denied. The first column contains the name of the lending institution. The second column contains the loan market share rate, which is the percentage of loans that each institution gave as compared to every institution in Euclid and South Euclid. Highlighted in orange are the top 3 lenders in Euclid/South Euclid. Highlighted in red is New York Community Savings Bank, which ranks at the very bottom for lending, with only 0.14% of the total loan market share.

20. Lending Institution Market Share and Action, 2011-2013 Euclid and South Euclid
Denied
Originated
Origination Rate
THE HUNTINGTON NATIONAL BANK
(3rd) 5.48
295
149
33.55%
FLAGSTAR BANK
(13th) 0.05 6 12
66.66%
WELLS FARGO BANK, NA
(1st) 10.49
118
226
66%
CITIBANK, N.A.
(9th) 3.18 31
134
81.21%
BANK OF AMERICA, N.A.
(7th) 3.55 37 76
67.26%
US BANK, N.A.
(6th) 4.51
106 99
48.29%
NEW YORK COMMUNITY BANK
(16th) 0.02 1 0%
FIFTH THIRD BANK
(10th) 2.61
153 53
25.73%
PNC BANK N.A.
(5th) 4.54
174
180
50.84%
JPMORGAN CHASE BANK, NA
(2nd) 6.97
119
315
72.58%
US BK NA ND (2011 and 2012 only)
(11th) 1.90
129 17
11.64%
ALLY BANK
(15th) 0.03 2 5
71.43%
CITIMORTGAGE, INC
(12th) 1.84 3
60%
FIFTH THIRD MORTGAGE COMPANY
(4th) 4.71 89
217
70.91%
LOANDEPOT.COM, LLC (2011 and 2013 only)
(14th) 0.04 10
17%
QUICKEN LOANS
(8th) 3.46 20 40
TOTAL:
53.40
1292
1528
73.46%

21. Aggregate Mortgage Lending
The table above shows the market share rank and rates for 18 selected lending institutions in Euclid and South Euclid. In this analysis, the market share percentages are calculated using the total market share value for just these 18 institutions rather than for all of the lending institutions in Euclid and South Euclid, which is why the numbers differ slightly from Table X. The selected institutions account for approximately half of the total loan market share in Euclid and South Euclid.
This figure displays information on total lending according to lending institution. The highest market share percentage of all institutions is held by Wells Fargo, a bank that has zero branch locations in all of North East Ohio, at 10.49%. Second is JP Morgan Chase Bank at 6.97%, and third is Huntington Bank, at 5.48%. Over the course of the established time period, Wells Fargo had originated nearly 900 loans, while JP Morgan had almost 600, and Huntington under 500.
Origination rates vary widely among lending institutions. Some of them do not mean much, like institutions that had less than 20 total loans over the three-year period. Most of the institutions have origination rates well over 50% however; the average of all institutions was 58.88% (including those with less than 20 loans over the time period). The large banks that had low origination rates are of concern though. This group includes US Bank NA ND, Fifth Third Bank, and the Huntington National Bank. The low origination rates are of some concern, because between those three institutions there are 5 branch locations within the municipalities. This can be an indicator that they are not truly living up the expectations of the Community Reinvestment Act. Conversely, the institutions with the highest origination rates were Citibank NA, JPMorgan Chase Bank (1 branch), and Fifth Third Mortgage Company (2 branches), though the relationship between Fifth Third Bank and Fifth Third Mortgage Company complicates any surface level analysis of the depositories located in the municipalities.

22. Institution Market Share
Rank
Institution Name
Count
Market Share %
Total Dollar Amount ($000's)
Average Loan Size ($000's)
Minority Denial Rate to White Denial Rate 1
WELLS FARGO BANK, NA
116
8.30
11,211
8.91 97
1.08 2
JPMORGAN CHASE BANK, NA 86
6.16
8,255
6.56 96
1.06 3
US BANK, N.A. 80
5.73
6,252
4.97 78
1.30 4
FIFTH THIRD MORTGAGE COMPANY 65
4.65
6,954
5.53
107
2.71 5
QUICKEN LOANS
6,687
5.32
103
1.34 6
CITIBANK, N.A.
5,897
4.69 91
0.56 7
PNC BANK N.A. 50
3.58
3,703
2.94 74
1.94 8
BANK OF AMERICA, N.A. 41
2.93
4,187
3.33
102 9
CITIMORTGAGE, INC 36
2.58
2,939
2.34 82 NA 10
NATIONSTAR MORTGAGE LLC 19
1.36
1,869
1.49 98 11
LOANDEPOT.COM, LLC
0.64
1,002
0.80
111
0.00 12
FLAGSTAR BANK
0.21
403
0.32
134 13
SUNTRUST MORTGAGE, INC
286
0.23 95 14
BRANCH BANKING AND TRUST CO
285
Sub Total of Top Lenders
641
45.86
59,930
47.66 93
1.24
All Lenders ( 120)
1,397
100.00
125,780 90

23. Rank
Institution Name
Count
Market Share %
Total Dollar Amount ($000's)
Average Loan Size ($000's)
Minority Denial Rate to White Denial Rate 1
WELLS FARGO BANK, NA
195
10.21
16,092
6.42 83
1.54 2
US BANK, N.A.
130
6.81
11,138
4.44 86
1.66 3
CITIBANK, N.A.
110
5.76
9,665
3.85 88
1.84 4
JPMORGAN CHASE BANK, NA
103
5.40
8,592
3.43
1.23 5
FIFTH THIRD MORTGAGE COMPANY
100
5.24
8,188
3.27 82
2.51 6
PNC BANK N.A.
4.35
39,230
15.65
473
1.00 7
QUICKEN LOANS 81
4.24
8,219
3.28
101
1.77 8
CITIMORTGAGE, INC 59
3.09
5,221
2.08 NA 9
BANK OF AMERICA, N.A. 55
2.88
4,851
1.93
1.29 10
NATIONSTAR MORTGAGE LLC 40
2.10
3,623
1.44 91
0.00 11
LOANDEPOT.COM, LLC 19
2,161
0.86
114
3.11 12
SUNTRUST MORTGAGE, INC
0.31
534
0.21 89 13
FLAGSTAR BANK
506
0.20 84 14
BRANCH BANKING AND TRUST CO
0.26 50
0.02
0.33
Sub Total of Top Lenders
992
51.96
118,070
47.08
119
1.32
All Lenders ( 135)
1,909
100.00
250,750
131
1.16

24. Individual Bank Branches and Deposit Amounts, Euclid and South Euclid (2011-2014)
Institution
2011
2012
2013
2014
Citizen's Bank: 365 East 200th St
50,191
49,370
48,664
65,636
Citizen's Bank: Lake Shore Boulevard
39,315
40,705
38,591
37,559
Dollar Bank: 240 East 228th St
29,160
25,967
26,825
24,663
Fifth Third: Mayfield Rd
49,338
49,978
48,406
46,899
Fifth Third: Lake Shore Blvd
61,063
59,416
53,602
55,054
FirstMerit: S Lakeshore Blvd
4,664
5,546
6,154
6,170
JP Chase Morgan: Lakeshore Blvd, Euclid
30,001
30,306
32,502
35,507
Key Bank: Mayfield Rd (South Euclid)
80,203
80,885
77,842
80,465
Key Bank: Lakeshore Blvd
64,915
59,644
58,574
55,123
NY Community Bank: Mayfield Rd
85,743
88,212
91,435
92,139
PNC: 4017 Mayfield Rd
44,866
38,942
42,811
43,465
PNC: 285 Babbit Rd
44,701
43,709
94,558
129,066
Huntington: Cedar Rd
87,634
89,326
86,055
75,829
Huntington: 1545 E 200th St
30,415
28,983
32,908
30,472
Third Federal: Lake Shore Blvd.
109,731
106,503
103,422
101,432
USBank: Shore Center Drive
not open
2,562
2,732
2,840

25. Deposit Market Share – South Euclid
Institution Name
No. of
Deposits
Market 
Offices $0
Share
Fifth Third Bank
1,347
97,638,751 1
46,899
18.74%
KeyBank National Association
1,025
69,223,094
80,465
32.16%
PNC Bank, National Association
2,820
221,065,714
43,465
17.37%
The Huntington National Bank
757
49,171,176 2
79,367
31.72%
Number of Institutions in the Market: 4
5,949
437,098,735 5
250,196
100

26. Key Bank: South Euclid 4461 Mayfield Rd, Cleveland, OH 44121
Total Deposits: $80,465,000
Total Loans: $2,769,000

27. Loan Information for South Euclid Key Bank Branch, 2013
Loan Purpose
Home Purchase Loans
Home Improvement Loans
Refinance Loans 6 43 24
Loan Type
Conventional
FHA 70 3
Action Taken
Originated
Denied
Approved Not Accepted
Withdrawn
Closed For Incomplete 30 35 3 4 1
White
Black/Af. Am
Am. Indian/Alaskan Native
no info
# loans 30 22 2 19

28. Deposit Market Share – Cuyahoga County, 2013
Institution Name
State (Hqtrd)
No. of Offices
Deposits ($000)
Market  Share
Beal Bank, SSB TX 18
1,104,063 1
606
0.00%
Citizens Bank, National Association RI
817
64,448,546 45
4,306,757
10.04%
Credit First National Association OH
500
Dollar Bank, Federal Savings Bank PA
3,968,562 21
1,423,608
3.32%
Fifth Third Bank
1,309
95,095,079 39
2,590,571
6.04%
First Federal Savings and Loan Association 6
239,775 13
993,294
2.32%
First National Bank of Pennsylvania
300
10,832,509 9
354,662
0.83%
Firstmerit Bank, National Association
359
18,109,760 23
1,316,427
3.07%
Independence Bank
145,255
0.34%
JPMorgan Chase Bank, National Association
5,661
1,030,669,724
1,879,276
4.38%
KeyBank National Association
971
57,374,506 55
11,929,053
27.82%
Liberty Bank, National Association
54,320 2
124,158
0.29%
New York Community Bank NY
228
23,330,367 20
1,398,142
3.26%

29. Loan Market Share – Cuyahoga County, 2013
Rank
Institution Name
Count
Market Share %
Total Dollar Amount ($000's)
Average Loan Size ($000's)
Minority Denial Rate to White Denial Rate 1
WELLS FARGO BANK, NA
4,594
7.86
626,528
7.39
136
1.79 2
THIRD FEDERAL SAVINGS AND LOAN
4,358
7.45
610,541
7.20
140
1.44 3
THE HUNTINGTON NATIONAL BANK
3,627
6.20
457,847
5.40
126
1.45 4
JPMORGAN CHASE BANK, NA
3,242
5.54
461,178
5.44
142
1.58 5
PNC BANK N.A.
2,771
4.74
418,131
4.93
151
1.69 6
FIFTH THIRD MORTGAGE COMPANY
2,730
4.67
353,497
4.17
129
1.29 7
US BANK, N.A.
2,728
270,633
3.19 99
1.56 8
RBS CITIZENS, N.A.
2,520
4.31
200,840
2.37 80
1.76 9
KEYBANK NATIONAL ASSOCIATION
2,455
4.20
241,858
2.85
2.12 10
FIRST FEDERAL OF LAKEWOOD
2,299
3.93
383,683
4.52
167
1.32 11
DOLLAR BANK, FSB
1,634
2.79
162,870
1.92
100
1.65 12
FIFTH THIRD BANK
1,043
1.78
85,701
1.01 82
2.01 13
FIRST PLACE BANK
822
1.41
133,249
1.57
162
0.96 14
FIRSTMERIT BANK NA
621
1.06
113,312
1.34
182
2.87 15
FIRSTMERIT MORTGAGE CORP
259
0.44
39,715
0.47
153 NA 16
NEW YORK COMMUNITY BANK
238
0.41
54,899
0.65
231
0.62 17
NYCB MORTGAGE COMPANY LLC
138
0.24
24,327
0.29
176
0.32 18
LORAIN NATIONAL BANK
116
0.20
23,150
0.27
200
1.12 19
LIBERTY BANK, N.A. 33
0.06
26,757
811
0.00 20
WOODFOREST NATIONAL BANK
0.03
2,061
0.02
108
3.00 21
BNY MELLON, N.A.
0.01
6,248
0.07
781 22
INDEPENDENCE BANK
572
114
Sub Total of Top Lenders
36,260
62.01
4,697,597
55.40
130
1.86
All Lenders ( 403)
58,473
100.00
8,480,549
145
1.80
Loan Market Share – Cuyahoga County, 2013

31. Recommendations
Share findings with local lenders, especially those with significant deposits in Euclid and South Euclid
Set goals for increasing prime lending in low- and moderate- income census tracts
Devise a comprehensive investment plan for each lender
Meet with both bank managers and bank brokers
Publicize results to the broader community
Be aware of CRA opportunities i.e. mergers and closings that may affect lending in the community
Assign a staff person to be the CRA Fair Lending Officer
Recommend that Cuyahoga County be more directly involved in fair lending

32. Ohio Fair Lending Coalition 2015
Eric Moizuk
Thenessa Savitsky
Chip Bromley
Organize! Ohio
Ohio Fair Lending Coalition
2015