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BANKING & COMMUNITY

FEDERAL
RESERVE BANK
OF DALLAS

Perspectives
FOURTH QUARTER 1998

Taste of Success
Entrepreneur Bites into Independence
with Schlotzsky’s Deli Franchise
For Theo Rolfe, the all-

Entrepreneur Theo Rolfe found the ingredients
for success in a Schlotzsky’s Deli franchise.
He now operates three stores.

INSIDE
HMDA and CRA Data Available

•
•
Banking on Habitat
•
Guide to Portfolio

Electronic Funds Transfer 99

Risk-Management Design
for CDFIs

American pie looks like a
sandwich. When he decided
to trade his career in big
business for entrepreneurship, Rolfe chose a Schlotzsky’s Deli franchise as his
charter for independence.
During his 15 years with
IBM, Rolfe worked with
several small businesses,
some of them franchises.
He had observed the franchise structures that were
most successful, the problems encountered, and what
worked and what didn’t.
At a franchising fair, Rolfe
investigated several organizations and learned of an opportunity to
purchase an established Schlotzsky’s franchise. “The timing was good,” Rolfe says.
“My purchase in 1993 coincided with
Schlotzsky’s corporate initiative to appeal
to a broader market by expanding the
menu (adding pizzas to the traditional
sandwich line) and remodeling its restaurants, called stores. My 10-year-old store
received a complete facelift.”
Rolfe says it was always his intention to
own a number of locations; consequently,
he is constantly looking for the next
opportunity. In 1995, he was attracted to

a shopping center under construction
on Interstate 30 at Eastchase Parkway in
southeast Fort Worth. It was in a highgrowth area, and a number of national
retailers were opening stores in the center. Rolfe negotiated a spot at the end of
the building, referred to as an “end-cap”
location, as well as a lane in the parking
lot for a drive-through window. Schlotzsky’s also offers freestanding stores.
Unlike purchasing an existing franchise, building a new location meant
Rolfe had to buy everything that went
into the new store—plumbing, equipment, floor and wall coverings, furniture,
cash registers—everything. And there
were licenses, permits and signs to buy.
The cost of opening the second store
required substantial financing in addition
to Rolfe’s $40,000.
Again, Rolfe’s timing was good. At a
Fort Worth Metropolitan Black Chamber
of Commerce after-hours networking
reception, Rolfe met Joe Reyes from the
local Small Business Administration (SBA)
office. Because the shopping center was
located in the target area for the William
Mann Jr. Community Development Corporation (WMCDC), Reyes suggested Rolfe
contact the WMCDC about financing.
The multibank CDC was formed in
1994 with capital from nine banks and
Continued on page 2

PUBLIC & PRIVATE PARTNERSHIP

Helping Schlotzsky’s franchisee Theo Rolfe, center, celebrate the growth of his venture are,
from left, Charles Comer of Wells Fargo Bank, LaVan Alexander of the Small Business
Administration, Ted Sparks of Wells Fargo Bank and Dan Villegas of the William Mann Jr.
Community Development Corporation.

Schlotzsky’s Continued from page 1
the city of Fort Worth to encourage economic development in the area. The
WMCDC joins with banks to provide
financing to small businesses in its target
area.
Dan Villegas, executive director of the
WMCDC, directed Rolfe to area banks,
including First Interstate Bank, now Wells
Fargo. The bank loaned Rolfe $216,500 to
open the second Schlotzsky’s store. The
WMCDC then loaned Rolfe an additional
$30,000 in operating capital.
According to Villegas, Rolfe’s proven
entrepreneurial spirit and business acumen and his willingness to invest $40,000
of his own money were strong factors in
the WMCDC’s deciding to participate in
the loan package. Those same factors
helped Rolfe obtain the bank loan, which
has an SBA guarantee.
While franchising has been around
since the Civil War, franchises have really
flourished in the past two decades. According to an SBA study titled “Franchising’s
Growing Role in the U.S. Economy,
2

1975–2000,” franchise sales could make
up 38 percent of total retail sales by the
year 2000. Capital Financial Corporation,
a Memphis-based company that provides
financial services to national and international businesses, estimates that a new
franchise opens every eight minutes of
every business day. Restaurants now
account for one-third of business format
sales.
Franchising generally takes two
forms —product/trade name and business
format. In the simplest form, a franchisor
owns the right to the name or trademark
and sells that right to a franchisee. A
more complex, and the most common,
form is the business format model, which
promotes a broader, ongoing relationship,
often with a full range of services.
Designed to improve the franchisee’s
odds for success, the business format
model provides a well-developed business concept, brand name and business
expertise—marketing plans, management
guidance, financing assistance, site location and training. Franchisees share the
economies of scale in mass advertising

FEDERAL RESERVE BANK OF DALLAS • PERSPECTIVES • FOURTH QUARTER 1998

and purchasing. The SBA study places
median costs to open a franchised small
business in a $25,000 to $150,000 range.
And franchisees pay royalties to the
franchisors, usually 4 percent to 6 percent of sales.
“In 1996 Schlotzsky’s required a
$10,000 franchise fee, with $7,500 due at
closing and $2,500 due later,” says Rolfe.
Most of the franchisees contacted in
the SBA study were satisfied with income
levels and their relationship with the
parent franchisors. Still, individuals considering franchising should study a franchise’s disclosure statements closely and
investigate the organization carefully
before signing any papers. Even with the
best franchises, conflicts arise. Many companies have franchisee councils to resolve
issues such as renewal rights, noncompete clauses, transfer rights and other
aspects of the franchising relationship.
Despite the success of many small
business franchisees, escalating costs
make it increasingly difficult in some
industries for small-business owners to
become franchisees. Some franchisors
require franchisees to purchase a package
of locations. The fact that Schlotzsky’s
offered franchises on a single location
was one of the reasons Rolfe chose the
corporation.
“Building a franchise one store at a
time is about the only way a person with
limited access to capital can get started,”
says Rolfe.
Today his Fort Worth store is among
the top three end-cap Schlotzsky’s in the
country in sales. It employs 17 people —
seven full time and 10 part time. And
Rolfe recently opened his third location,
in Weatherford, Texas. He arranged his
own financing for all three stores and
says that by building on each success,
financing has gotten a little easier with
each new franchise. ◗

Did You Know. . .?

Fast Facts
Entrepreneur Theo Rolfe was lured away from corporate America by the idea of being his
own boss and running his own business. Franchising provided the opportunity. With one successful store in operation, Rolfe had the chance to open a second location in a Fort Worth
CDC’s target area. Through a chance meeting with Joe Reyes, a local SBA representative who
directed Rolfe to the William Mann Jr. CDC, Rolfe opened the second location with a unique
financing package.
Loan Closed:
April 1996
Loan Package:
Owner’s Equity:
Wells Fargo
William Mann Jr. CDC
Total

$ 40,000
216,500 (floating prime + 2.25% for 7 years;
SBA guaranteed the bank loan)
30,000 (at 11% for 5 years)
$286,500

For more information:
William Mann Jr. CDC
(817) 332-8575

HMDA and CRA Data Available
Data on 1997 mortgage lending
activity required by the Home
Mortgage Disclosure Act (HMDA)
and data on small-business, smallfarm and community-development
lending required by the Community
Reinvestment Act (CRA) are now
available on the Federal Financial
Institutions Examination Council
(FFIEC) Web site at <www.ffiec.gov>.
Also available on the FFIEC’s
Web site are CRA ratings for all
subject financial institutions. The
address is <www.ffiec.gov/cracf/
crarating/main.cfm>. The site allows
the user to search and sort the CRA
ratings under a variety of options,
including bank name, city, state and
regulatory agency.

Community Affairs on Web

RESOURCE

SBA Franchise Registry
Since 1993, the number of SBA-guaranteed loans has doubled, and lending to smallbusiness franchisees has steadily increased. During this period the SBA has approved almost
12,000 loans to franchisees in nearly 1,200 franchise systems. In 1996 alone, SBA lenders
approved 3,708 loans for more than $978 million.
The growth in the number of franchisees seeking SBA loans has placed a burden on the
review process. The SBA identified potential problems, which led to formation of the Franchise
Registry. With 69 local SBA offices, the same contract might be deemed eligible in one office
and not in another. The heavy volume of applications could extend the review process, and
industry differences in financial and operational procedures could cause confusion.
Since by law the SBA can only lend to small businesses, it must verify that its borrowers are
indeed small businesses. When a franchisee seeks an SBA loan, the SBA or one of its lenders
must review franchise documents to ensure the franchisor does not exert so much control over
the franchisee’s daily operations and profits that it becomes the real owner of the business.
Because local SBA lenders or offices lack the resources to react to so many different
industry-specific situations, the SBA developed the Franchise Registry. Under the new process,
franchises that meet the SBA’s requirements are placed on the registry. Those seeking loans to
open franchises listed on the registry enjoy an expedited review process. Of course, the lender
must still approve the transaction independently. Currently 36 franchises are on the registry, and
another 46 are in the application process. The SBA has posted a list of franchises approved for
the registry on its Web site, <www.franchiseregistry.com>.
For more information on franchising, see the SBA Web site, <www.sba.gov>.

Enhancements to the Dallas
Fed’s Web site have made it easier
to access information about the
Eleventh District’s Community Affairs
Office. The address for the site is
<www.dallasfed.org>.

Inner City 100 Award
Initiative for a Competitive Inner
City is seeking nominations for the
Inner City 100, which will recognize
the fastest growing private companies located in America’s inner
cities.
The Inner City 100 list will be
published in the May 1999 issue of
Inc. magazine, and companies will
be honored at an awards gala. The
deadline to submit applications is
October 31, 1998. You can download the application from the Internet
at <www.inc.com/inner100>. For
more information, contact Ann
Habiby at (617) 292-2371.

FEDERAL RESERVE BANK OF DALLAS • PERSPECTIVES • FOURTH QUARTER 1998

3

Down to the Wire
Electronic Funds Transfer 99

The federal government’s deadline
for converting the nearly 1 billion payments it makes annually from paper
checks to electronic funds transfer is less
than three months away. The conversion
will affect millions of U.S. citizens who
receive government checks, such as veterans and railroad retirees, as well as
vendors.
The Electronic Funds Transfer 99
(EFT 99) initiative, which goes into effect
in January 1999, affects all federal government payments except income tax.
Because payments will be deposited
directly into the recipient’s account in a
financial institution, EFT is a safer, more
convenient and reliable way for recipients
to obtain their money than getting a
paper check through the mail.
Direct Deposit into Banking Accounts
Recipients with direct deposit options
on their current checking or savings
accounts can have their payments directed into those existing accounts.
However, the U.S. Treasury
Department estimates that more than 10
million federal benefit recipients do not
currently have banking accounts. The
Treasury is investigating a number of
options for delivering payments electronically to recipients without bank accounts.
One alternative is to encourage recipients to open a banking account. An
analysis of 15 banks in Texas indicates
that a number of low-cost or no-cost
4

accounts are available to customers at
banks throughout the state. Examples of
banks that offer these low-cost accounts
are Bank One, Texas in Dallas and
Southwest Bank of Texas in Houston.
Bank One, Texas offers a basic
checking account that requires no minimum deposit to open and has a $3
monthly maintenance fee, which is
waived if the customer uses direct deposit.
Southwest Bank of Texas offers a nominimum-deposit checking account to
individuals 55 and older with unlimited
automated teller machine usage for a $4
monthly maintenance fee.
Accounts Specified by the U.S. Treasury
The Treasury Department is developing its own low-cost account to allow
recipients to use EFT. Named the
Electronic Transfer Account (ETASM), it
will be offered through federally insured
financial institutions to anyone receiving
a government payment, regardless of
whether the recipient has an existing
account. However, recipients who elect
not to use an ETA or another account
in a financial institution will be paid by
check.
In addition, the Treasury Department
is working with states to link federal payments to state programs that provide
electronic benefit payments on a type of
debit card. Recipients would receive both
state and federal benefits on one card.
The Treasury Department is also
monitoring the development of arrangements between financial institutions and
nonbank entities such as check cashers
and money transmitters to ensure the
recipients are fully aware of all fees and
costs imposed by all parties.

FEDERAL RESERVE BANK OF DALLAS • PERSPECTIVES • FOURTH QUARTER 1998

Public Awareness
To ensure the program is successfully
implemented, the Treasury Department
has created an extensive nationwide public education campaign. The department
has scheduled conferences and workshops with various bankers’ associations,
community-based organizations, financial
institutions and government agencies that
work directly with recipients to educate
them about EFT 99.
Waivers
The Treasury Department will grant
financial hardship waivers to recipients
for whom EFT will cost more than receiving a paper check. Recipients with
physical or mental disabilities or geographic, language or literacy barriers can
also receive waivers from EFT requirements. Any recipient without a bank
account will receive an automatic waiver
until the Secretary of the Treasury
announces the ETAs are available.
Federal agencies will notify all current payment recipients of all their EFT
options, including enrolling in direct
deposit, opening an ETA or applying for
a waiver to continue receiving paper
checks. ◗

EFT 99 Workshops and Seminars
For information on conferences and workshops in
the Southwest region, which includes the Eleventh
Federal Reserve District, contact Dora Hernandez or
Tabitha Guydon, with Financial Management
Service, a bureau of the U.S. Treasury.
Financial Management Service
1619 E. Woodward St.
Austin, TX 78741
(512) 342-7310

Banking
on Habitat
Dallas Chapter
Develops Loan Program
for Banks
Volunteers work with the Dallas chapter of Habitat for Humanity
to construct a house for an area family.

Habitat for Humanity is known for its
innovation in creating home ownership
opportunities for low-income families.
Building on that innovation, the Dallas
chapter has developed an entirely new
way for financial institutions to partner
with Habitat in its commitment to making
mortgage loans available to homeowners
at zero percent interest.
The Banking on Habitat (BOH) program is the result of a collaboration
between Daryl Kirkham, retired chief
banking officer for Northern Trust Bank
of Texas and president of Dallas Area
Habitat for Humanity, and the Dallas
chapter’s executive director, Jim Pate.
Because of Habitat’s policy of not charging homeowners interest on their mortgages, banks have been unable to offer
their existing low-interest mortgage products to Habitat families. The BOH program is a two-level strategy to involve
banks in mortgages that are consistent
with Habitat’s policy.
Homeowners associated with Habitat
are active participants in the actual construction of their homes (and those of
other Habitat families) through sweat
equity. Each Habitat homeowner spends
400 hours working on his or someone
else’s home. Through donations of

funds, material and labor from individuals
and organizations, Dallas Area Habitat is
able to sell most of its homes for about
$50,000.
Banks participate in the BOH program in two ways. “Under BOH I, the
bank makes a charitable contribution to
Habitat in the form of foregone interest,”
says Pate. “The bank provides a $50,000
90-day construction loan that is converted
to a 25-year note at closing. The loans
are made at zero percent interest, and
they are secured with the Habitat mortgage to the homeowner.”
Once a bank has participated in BOH
I, it can then participate in BOH II,
which allows the bank to earn interest.
At closing, Habitat pairs a $25,000 donation with a $25,000 bank loan at zero
percent interest. Habitat then assigns its
$50,000 mortgage on the house to the
bank, allowing the bank to earn an
imputed interest rate of 6.36 percent over
the 25-year life of the loan. Habitat continues to service the loan.
According to Pate, 10 local banks currently participate in the Dallas BOH program, and other Habitat chapters around
the country are now duplicating the
Dallas program.
Kathy Magee, a private banker with

Northern Trust Bank of Texas and treasurer for Habitat in Dallas, says Northern
Trust holds a BOH portfolio of 43 loans
totaling approximately $1.1 million.
“Northern Trust has a long-term commitment to Habitat and its philosophy of
helping people help themselves,” says
Magee. “BOH is an innovative program
that provides participating banks with
performing loans while preserving
Habitat’s no-interest-mortgages philosophy. It also provides Habitat with a way
to leverage its mortgages to build more
houses.”
The big winners in this innovative
collaboration are low-income families,
who, through hard work and determination, get the chance to own their own
homes.
For more information, contact
Dallas Area Habitat for Humanity at
(214) 827-4037. ◗

FEDERAL RESERVE BANK OF DALLAS • PERSPECTIVES • FOURTH QUARTER 1998 5

Guide to Portfolio
Risk-Management
Design for CDFIs
Prepared by Shorebank Advisory Services
for NationsBank Community
Investment Group

Shorebank Advisory Services
(SAS) is an advisory and consulting subsidiary of Shorebank
Corp., a bank holding company
and a leading development
finance institution. SAS based the
report on the lending experience
of Shorebank financial institutions and the many other
community development financial
institutions with which SAS
has worked. This article was
excerpted and adapted
from the report.

Currently, hundreds of community
development financial institutions
(CDFIs) are helping meet the credit needs
of low- and moderate-income communities. To help these organizations better
manage their loan portfolios, the
NationsBank Community Investment
Group had Shorebank Advisory Services
develop a practical guide on portfolio risk
management design for CDFIs. The guide
provides an overview of the basic tools in
risk management, with a special focus on
CDFIs as lending intermediaries.
Banks, as well as other private and
public funders, have capitalized CDFIs
with the expectation that CDFIs will
make loans without extensive losses.
A particular challenge for CDFIs is that
their mission often includes taking greater
lending risk than a traditional bank
might, making it imperative that CDFIs
have effective portfolio risk-management
systems.

Portfolio risk management is an essential part of lending. Risk management is
a process of adequately identifying and
characterizing risk, then managing the
relationship with the client to maximize
the success potential of both the client
and the CDFI.
6 FEDERAL RESERVE BANK OF DALLAS • PERSPECTIVES • FOURTH QUARTER 1998

Since most CDFIs are dependent upon
borrowings or other third-party financial
arrangements for funding, portfolio riskmanagement policies and guidelines need
to be in writing.
The standard risk-management tools
of commercial and real estate finance
include
• credit policies that define the goals,
business lines and risk parameters
of the organization.
• clear lending and underwriting
guidelines to adequately identify,
characterize and price risk.
• appropriate loan monitoring and
review systems to detect changes
in credit quality and the more
important changes in the borrower’s circumstances (both favorable
and unfavorable).
• internal controls to evaluate the
performance of both individuals
and the entire organization.
• active oversight by both management of the CDFI and its board of
directors.
The successful CDFIs have adapted
these standard tools to fit the particular
market niche in which they operate and
the special financial and developmental
impact goals they adopt.

The guide divides portfolio risk management into three primary tasks —identifying risk, managing risk and monitoring
risk.

Identifying Risk: Credit Policies and
Management Guidelines
Credit policies and lending guidelines
should define boundaries for credit officers. They also drive risk rating systems.
It is important that written credit policies
be broad in scope to allow for individual
discretion and, at the same time, be narrow enough to provide direction to credit
officers.
While the written credit policies will
reflect the specific mission, there are, nonetheless, traditional components that all
credit policies should address, including
• diversification in loan product mix
and loan structure mix.
• maximum loan size and maximum
exposure to a single borrower.
• lending authorities and the board
of directors’ role in reviewing loan
requests.
• management guidelines that identify the kinds of lending transactions the CDFI will engage in and
the terms and conditions the CDFI
will require from its borrowers.

Managing Risk: Risk Ratings and
Loan Loss Reserves
Managing credit risk is the process of
obtaining both formal and informal information on borrowers and evaluating the
accuracy of the initial risk estimates. It
also recognizes that the quality of any
given loan will change frequently.
The aggregate change in the risk estimates of the overall portfolio is determined by the change in quality of each
loan in the portfolio. The aggregate
change determines the adjustments that
must be made in lending policies.
Managing credit risk enables the CDFI
to effectively lend in markets where the
risks are perceived to be too great for traditional lending institutions. This typically
involves the following actions:

• characterizing the risk of a loan at
the time it is approved, using the
risk rating system. (Most CDFIs
begin with a simple rating system,
then enhance and refine it to
reflect their own ongoing experience.)
• reviewing the risk classification of
each loan on a regular basis, and
raising or lowering the rating
accordingly.
• using the risk ratings to determine
whether adequate resources are
available to work closely with
those borrowers that require the
most time and attention.
• reviewing the “riskiest” loans on a
more frequent basis, ensuring adequate attention.
• using the portfolio evaluation to
evaluate the loan loss reserve adequacy and the adequacy of the
CDFI’s liquidity and capital.
Loan Loss Reserves. In managing the
loan loss reserve, the CDFI should follow
generally conservative practices, including
• growing the loan loss reserve
quickly so it can absorb early
losses.
• maintaining a consistent policy on
charge-offs of delinquent loans —
usually loans delinquent more than
90 days are charged off.
• reviewing the adequacy of the
loan loss reserve on a quarterly
basis.

Monitoring Risk: Portfolio Evaluation,
Reporting and Maintenance
Once a loan has been booked, its subsequent performance must be monitored.
Each loan carries a risk rating, which is
really nothing more than an estimate of
future behavior. Monitoring allows for
subsequent changes in the rating, when
warranted, and serves as a process to
validate the risk rating system’s accuracy.
Monitoring also permits ongoing review
of the adequacy of the CDFI’s loan loss
reserve.
Loan maintenance is the administration

of individual loans through a direct relationship with the borrower.
Any individual borrower will repay or
not repay a loan regardless of the particular risk that the CDFI has assigned to it.
Consequently, sound loan maintenance is
critical to the portfolio’s performance.
The importance of portfolio reporting
is to measure the performance on an
aggregate basis. Reporting also allows
board members and CDFI lenders to
evaluate the CDFI’s performance against
its goals and objectives.

Managing credit risk
enables the CDFI to
effectively lend in
markets where the risks
are perceived to be too
great for traditional
lending institutions.
Portfolio Reporting. Generally, the reports
include comparative information, particularly year to year and current year to
budget. The comparisons are essential to
identifying trends in the direction the
portfolio quality is heading. While there
is no predetermined number of reports,
or formats, each CDFI will develop those
that are most meaningful for its unique
mission and purpose. The commonly
used reports include
• total loans outstanding.
• new loans made for the period.
• delinquent loans.
• summary of changes in loan risk
ratings.
• analysis of loan loss reserve and
loan charge-offs.
• missing documentation.
• problem-loan list.
Continued on page 8

FEDERAL RESERVE BANK OF DALLAS • PERSPECTIVES • FOURTH QUARTER 1998 7

Risk Management
Continued from page 7

Portfolio Maintenance. If borrowers are
current on payments and are complying
with financial reporting requirements
(that is, monthly financial statements and
collateral value and/or accounts receivable reports) and loan covenants, the
loan officer may be able to devote more
time to marketing and to other loans.
Unfortunately, loans do not always
perform the way they are projected. Late
payments usually are the first indicator of
underlying problems. Loan officers need
to respond quickly to delinquencies,
making the delinquent loan report one
of the most important management tools.
In dealing with delinquencies, it is
important to recognize that the inability
to make a scheduled payment is only the
indication of more severe problems. The
first step should be to review the loan’s
risk rating and, if appropriate, change the
rating.
CDFI directors should review delinquent loan reports in detail and be provided with information that explains the
actions the loan officer is taking.

FEDERAL
RESERVE BANK
OF DALLAS

Conclusion
Successful development-oriented
lenders recognize that there is some
degree of risk in all of their loans. They
simply acknowledge this and use their
creative energy to make these risks
acceptable. The successful CDFI will
define its own standards of performance,
monitor itself against its standards and
adapt to changing conditions.

Perspectives
Fourth Quarter 1998
Federal Reserve Bank of Dallas
Community Affairs Office
P.O. Box 655906, Dallas, TX 75265-5906
214-922-5377

Gloria Vasquez Brown

For a copy of Guide to Portfolio
Risk-Management Design for CDFIs,
please contact Shorebank Advisory
Services at (773) 288-0066 or
<sas1sbk@aol.com>, or write
NationsBank
CDFI Initiative Manager
1605 Main St., Suite 502
Sarasota, FL 34236
or e-mail
<mary.schultz@nationsbank.com>.

Vice President
gloria.v.brown@dal.frb.org

Nancy C. Vickrey
Community Affairs Officer
nancy.vickrey@dal.frb.org

Ariel D. Cisneros
Community Affairs Specialist
ariel.cisneros@dal.frb.org

Jim V. Foster
Community Affairs Specialist
jim.foster@dal.frb.org

Bobbie K. Salgado
Houston Branch,
Community and Public Affairs Advisor
bobbie.salgado@dal.frb.org

◗

Shelia M. Watson
Community Affairs Specialist
shelia.watson@dal.frb.org
Publications Director: Kay Champagne
Writer: Barbara Cody
Editors: Jennifer Afflerbach, Monica Reeves
Design: Gene Autry
The views expressed are those of the authors
and should not be attributed to the Federal Reserve
Bank of Dallas or the Federal Reserve System.
Articles may be reprinted on the condition
that the source is credited and a copy is provided
to the Community Affairs Office.
Internet Web site: www.dallasfed.org

FEDERAL RESERVE BANK OF DALLAS
COMMUNITY AFFAIRS DEPARTMENT
P.O. BOX 655906
DALLAS, TX 75265–5906

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DALLAS, TEXAS
PERMIT NO. 151

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