FMCRC Delegation Dr. Joy Bruce (President, Asian American Federation of Florida) Ron Frazier (Chairman, BAC Minority Small Business Funding Corporation) Reggie Clyne (Board member, Wilkie D. Ferguson Jr. Bar Association) Roland Sanchez Medina Jr. (President, Cuban America Bar Association) Evelyn Bruce (Executive Director, NANAY Housing Resource Center) Debra Reyes (President & CEO, Neighborhood Lending Partners) Al Pina (Chair, Florida Minority Community Reinvestment Coalition) Damon Lester (President, National Association of Minority Automobile Dealers) Roger Campos (President, Minority Business Roundtable) Eunice Barnum (President, Sherwood Forest/Paradise Park Community Association Roderick Harvey, CPA (Board member, BAC Minority Small Business Funding Corporation) Meet With FDIC, CDFI Director, SBA Associate Administrator, Office of Congressman Alan Grayson, Federal Board of Governor Elizabeth Duke and White House Economic Team officals January 12-13 ...Details of meetings coming next week.
LETTER TO OCC REGULATORS-
FMCRC and Minority Community Leaders Oppose National Bank Charter Application By Raymond James Financial:
2302 W. St Louis Avenue Tampa Florida 33607
Office Comptroller of the Currency Mr. John C. Dugan Comptroller 250 E Street SW RE: Hand Delivered To OCC January 13, 2010 Dear Mr. Dugan: This letter is a follow up with our letter dated December 15, 2009 requesting the OCC to deny the national bank application by Raymond James Bank. The following are key statements from “We call on the OCC to deny the application by Raymond James to become a national bank. They have clearly demonstrated that they are not prepared to provide true access to capital for “Raymond James application for national bank status should not be allowed until it has demonstrated that is inclusive of all people. Presently, it does not practice supplier diversity, governance diversity, workforce diversity and its market diversity should be reviewed. Such practices, intended or unintended represent economic segregation and should not be tolerated.” Malik Ali, Harvard MBA 1979 President-Florida Minority Supplier Development Council “The Florida bank charter application of Raymond James must be withheld until its management has demonstrated that its policies and programs are inclusive of disadvantaged communities and the small businesses owned by members of those communities. The Raymond James management was asked to address their diversity and community involvement in their plans, but it refused to commit itself to outline its plans. Intended or unintended, such action is irresponsible and their bank application must be withheld until they address their responsibilities.” Raul Espinosa, Founder Fairness in Procurement “As a community of color, we are strongly opposed to institutions that do not include ethnic diversity in their comprehensive business management plans, or are not willing to address the needs of disadvantaged communities. We strongly feel that the Florida bank chapter application of Raymond James should be withheld until after it can document that its policies and programs are responsive to and inclusive of disadvantaged communities and small minority businesses.” Dr. Joy Bruce President, Asian American Federation of “The Brooklyn Neighborhood Association formally protests the approval of the charter for the Raymond James National Bank. The Raymond James National Bank was asked to disclose its plans for minority communities and the small business owners that are a vital part of our community. The request for a charter application must be withheld until its programs are inclusive of all minority groups and small businesses. Our communities are in need of a financial institution that is willing to extend credit and loans to the minority community. This institution has failed to respond to the concerns that we expressed.” Ayesha “The Minority Business Roundtable representing the CEO’s of the leading African American, Hispanic, Asian, Native American, and Women owned businesses in The economic distress of minority communities may be one of the most pressing issues facing minority communities across the Raymond James Bank is #7 in The Community Reinvestment Act (CRA) is a federal law that requires banks to meet the credit needs of their entire communities, including low-moderate income (LMI) neighborhoods. The CRA Act begins by reciting to Congress three findings. First, banks are required to serve the “convenience and needs” of the communities in which they are chartered to do business. Second, “the convenience and needs of the communities include credit services.” Third, banks (Raymond James Bank) have “continuing and affirmative obligation(s) to help meet the credit needs of the local communities in which they are chartered.” Raymond James has failed miserably to meet all three charters of the Community Reinvestment Act for
The HMDA data demonstrates, Raymond James Bank (An approved Thrift) has failed like no other A thorough CRA examination of Raymond James Bank, would uncover the following CRA violations of Raymond James Bank: 1) The OTS did not consider Raymond James Bank lending record according to race of the applicant (s) or the racial composition of the neighborhood in which the properties were located. As the data indicates, Raymond James Bank’s record of lending to minorities and underserved communities is sparse and isolated. 2) The OTS did not engage a standardized set of quantitative data or benchmarks when evaluating Raymond James Bank. 3) The OTS engaged a “subjective” process in providing CRA ratings. 4) The OTS allowed Raymond James Bank to define their geographic area in which they have CRA obligations. 5) The OTS had not considered the below par small business lending record to minority small businesses in Lack of Diversity at Raymond James Bank and Raymond James Financial: The lack of diversity at Raymond James Financial and Raymond James Bank Board of Directors and management team is a direct reflection of its lack of desire to reflect the population in which they serve. There is not one Latino, African American or Asian on either its board of management team. This lack of diversity at Raymond James Financial has a direct impact on it business practices and subsequently has resulted in a horrendous record of lack of access for capital and supplier diversity for The OTS has allowed Raymond Bank to exploited In We at FMCRC are requesting the Office of the Comptroller of the Currency (OCC) to deny the national bank charter application by Raymond James Financial/Raymond James Bank. In addition, FMCRC requests that the OCC hold community hearings for this application in both
In 2010, it is imperative for the new Congress and Administration to redefine the Federal Government’s role, especially within the Community Reinvestment Act. The current economic state of our country will create a significant increase in financial industry consolidation. If there is not proper oversight of the financial industry as this major shift occurs, as we have seen in past 10 years, it will have catastrophic results for minority families and businesses in We thank you for your consideration on this very important issue. If there are any questions or concerns, please contact myself at (813) 598-6361. Cordially, Al Pina Chair FL HQ:
www.fmcrc.org (941) 284-0688 office 1 Attachment: Raymond James CC: Honorable Barney Frank Honorable Chris Dodd Chair Chair House Financial Services Committee Senate Banking Committee 2252 Rayburn Bldg 448 Russell Building Secretary of the Treasury Mr. Thomas Alan James Department of the Treasury 880
Room 2134 Aracely Panameno (Director, Latino Affairs-Center for Responsible Lending) John Gamboa (Greenlining Institute) Greg B. Macabenta (National Chairman, National Federation of Filipino American Associations) Winnie Tang (President- Organization of Chinese Americans, South Florida Chapter) Elaine Black (President-Liberty City Trust) Ron Frazier (Chairman- BAC Funding Corporation) Joy Bruce (President, Asian American Federation of Florida) Raul Espinosa (President- Fairness In Procurement Alliance) Reggie Clyne Esq. (Wilkie D. Ferguson Jr., Bar Association) Orson Aguilar (Director, Greenlining Institute) Johnson Ng (Executive Director, United Chinese Association of Florida) Val Dagani (Founder, Filipino American Coalition of Florida) Doug Mayorga (President, Florida Minority Chamber of Commerce) Rolando Sanchez-Medina, Esq. (President, Cuban American Bar Association) Nydia Menendez, Esq. (President, Puerto Rican Bar Association) Jorge A. Mestre, Esq.(Hispanic National Bar Association) Kerth J. Conze, Esq. (President, Haitian Bar Association) Jay Kim, Esq. (Asian Bar Association) Dr. Rubio Arnesto (President, Cuban American Publisher’s Association) Sylvia Alvarez (President, Housing & Education Alliance) Tomas Lares (Coalition of Latino Central Florida Faith Based Organizations) Glorious J. Johnson (Council Member, City of Jacksonville) Dr. Bessie Fletcher (President, Mothers & Daughters Inc.) Vicente Rodriquez (Hispanic Publishers Association) Debra Reyes (President, Neighborhood Lending Partners) Dorothy Hughes (President, Gateway Economic Empowerment Coalition) Maria Benton (President, Spain in Jacksonville) Eddie Stanton (President, Mad Dads Inc.) Romeo De La Paz (Chair, Filipino American Foundation) Asian American Chamber of Commerce-Jacksonville (Dr. Mel Carbonell, President) Filipino American Coalition of Florida (Lita Martija, Convenor) Fil-Am Council of Jacksonville (Noli Vianzon, President) Florida's Space Coast Filipino American Charitable and Educational Foundation, Inc (Romy dela Paz, Chair) Asian American Federation of Florida (Joy Bruce, Interim President) NANAY, Inc (Bennie Trinidad, Exec Vice-President & COO) NANAY Housing Resource Center (Evelyn Bruce, Executive Director) QBIS Group, Inc. (Eva Bruce, Chair person & CEO) Cambodian American Community Services - (Jadranko (Jay) Gogalija, Government Affairs Financial Matters Program Director) Fil-Am Political Alliance of Florida (Ernie Ramos, Chair) Asian American Heritage Council (Karen Nguyen, President) A-Major Multimedia (Andrew Jeng - Vice-Chair) Organization of Chinese Americans - South Florida Chapter (Winnie Tang, President) Florida Chinese Federation (Winnie Tang, President) Council for Filipino American Organizations (CFAO), Central Florida (Mario Ordona, Chair) Bataan Corregidor Memorial Foundation, Osceola Co. (Pedro I Gonzales, MD -Chairman) Bayanihan International Ladies Assoc., Seminole Co. (Julieann Cruz - President) Filipino-American Assoc. South Orange &Osceola Co, Osceola Co. (Erlinda Rodas-President) Filipino American Veterans Assoc., Orange Co. (Angel Salvador-President) Gawad Kalinga Orlando, Orange Co. (Rainer Guevarra-Coordinator) Ilonggo Assoc., Orange Co. (Jeanette O'Meara-President) Knights of Rizal, Orange Co. (Alex de Guzman-Commander) Ladies for Rizal, Orange Co. (Naty Ordona, DMD-President) Philippine American Chamber of Commerce, Orange Co. (NV Bouffard-President) VisMindaLuz Assoc. Orange Co. (Nena Adonay-President) 80-20 Educational Foundation (Edward Lin, Director) NANAY Health Center Inc (Badette Llurba, Chair) Philippine American Federation of South Florida (Beth Marull, President) Philippine American Cultural Foundation of Florida (Edwin Dominado, President & Chair) Survey of Raymond James Financial/Bank ( Tampa-St Peterburg- Number Of Minority Respondents: 1065
January 13, 2010
pina@fmcrc.org
(813) 598-6361 cell
admin@fmcrc.org
Mr. Timothy Geithner Raymond James Financial
1. Does Raymond James Bank have an impact in your community?
Yes
2. How would you compare Raymond James with Bank of America in terms of serving the community?
Better 2% Worse 96%
3. What grade would you give Raymond James on community leadership?
F
4. In general, what is the on-the-street community view of Raymond James?
Grade
F
5. Can you name the Raymond James Bank President?
Yes
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FMCRC
Email: Porfiria Ramirez admin@fmcrc.org
2302 W. St Louis Ave Tampa FL 33607
(941) 284-0688
Civil Rights and legal issues or comments to:
Reginald J. Clyne
Clyne & Self, P.A./Civil Rights Attorney
Douglas Centre-Suite 1100
2600 Douglas Rd, Coral Gables Florida 33134