Full text of Bridges (Federal Reserve Bank of St. Louis) : Bridges, Summer 1997

The full text on this page is automatically extracted from the file linked above and may contain errors and inconsistencies.

™

Summer 1997

Linking Lenders And Communities

X

How to Sustain CRA’s Success
3

E

Hermann, Mo., entrepreneur honored

4

6

N

D

Communities Unabridged;
United Way in Memphis
provides HOPE
Addressing brownfield risks

7

I

Spanning the Region

8
Calendar

Alice M. Rivlin

Remarks by Federal Reserve Board
Vice Chair Alice M. Rivlin at the
Annual Meeting of the National
Community Reinvestment Coalition,
Washington, D.C., March 13, 1997

I believe very strongly that
the future of America over the
next few decades depends on
community action at the local
level. That is where the public
policy action is going to be as
we enter the 21st century.
The future depends on people all over the country working
together to make things better
in their particular
place. For community
development to succeed, a lot of different
groups—businesses,
labor, churches, educators, community organizations and various
levels of government—
need to work hard
together. Banks and
other financial institutions have to be part of
the team. Indeed,
community effort
works best when the
financial institutions in
the community believe
they have a long-term stake in
its vitality and act accordingly.

I did not come to my current level of enthusiasm for
local community action because
I am sour on the federal government or think there is little role
for national policy and national
institutions, such as the Federal
Reserve. I have spent much of
my career working hard to
improve national fiscal policy, and
I am working hard at the Federal
Reserve because I believe that
monetary policy matters a lot to
the health of the economy.
But there are limits to what
national policy can do.
Even when national responsibilities are being met, things can
still go badly in a lot of places.
Right now, average people are not
worried much about national or
international matters, but about
the things right around them.
Americans are deeply distressed
about decay in their neighborhoods, crime and drugs on their
streets, job migration, poor
schools and dilapidated housing.
These are the problems that only
effective local community action
can turn around.
Where does the Federal
Reserve fit in, and what can we
do to help you be more successful? First, and probably most
important, we can do our best

to keep the national economy
growing as fast as it can without
overheating or generating corrosive inflation.
Right now, the national preconditions for community development are very favorable. The
economy is growing at a healthy
clip, with payrolls up and unemployment low. With these labor
market conditions, businesses are
more willing to hire people with
lower skills and to provide the job
training and experience necessary
for people to get ahead. Family
incomes are beginning to rise,
making better housing more
affordable. The primary challenge for the Federal Reserve is to
try to keep this good news coming and be especially vigilant
against the threat of accelerating
inflation, which has so often
derailed our economy in the past.
Steady growth with low
inflation and low interest rates is
what community developers
need most. Growth produces
jobs and provides incomes for
people and profits for businesses;
stable prices and affordable interest rates enable families, businesses and communities to do
more with less. I cannot promise
that the Federal Reserve will
always be able to achieve these
continued on p. 2

CRA
continued from p. 1

goals. I can promise that we will do our best
to keep the economy on track.
My point here is to make clear that the
Federal Reserve’s role in supporting community development is not exclusively related
to CRA. To the extent that we are successful
in implementing sound monetary policy, we
directly further the goals of community
development.

BANKS AND COMMUNITY
DEVELOPMENT
Let me turn now to our other major
role—that of bank supervisor, which requires
us not only to protect the safety and soundness of the banking system, but also to
enforce the CRA.
Banks are natural participants in the
community development process. In the
broadest sense, most financial institutions
always could be considered “community
development” institutions. Chartered to
meet the convenience and needs of their
communities, most banks remain closely
tied to the economic health and growth
prospects of their local markets. Even those
larger interstate institutions, or mega-banks,
continue to depend on the collective health of
economies that are quite local in nature.
By virtue of their traditional functions—taking deposits and reinvesting
them in loans and other investments—
banks help create economic value and
growth by financing businesses, housing
and community facilities. These functions
are central to anyone’s concept of community development. Therefore, it is no wonder that the activities of banks often have
been a focus of attention when questions
about the health of neighborhoods and
local economies are raised. It is no wonder
that banks are viewed as natural and even
essential partners in the community development process. And it is no wonder that
banks remain central to any debate over

equal access to credit or barriers to economic opportunity for disadvantaged persons.

THE IMPORTANCE OF CRA
Getting beyond banks’ traditional role
of fostering general community growth to
a more collaborative effort in helping
meet specific community credit needs has
not always been easy. As generally conservative, risk-averse institutions, many
banks historically did not view low- and
moderate-income areas or people as profitable markets for their loans and services. Bankers sometimes did not know
enough about those communities and
neighborhoods, or about the wide variety
of tools and techniques they could use to
help meet credit needs in those areas.
Chartered to meet the convenience
and needs of their communities,
most banks remain closely tied to
the economic health and growth
prospects of their local markets.
The CRA was designed to change all
that. In the 20 years since CRA’s passage,
financial institutions have learned a lot
about low- and moderate-income markets
and how to serve them on a profitable
basis. They have learned that their loan
underwriting standards could be modified
to take into consideration common
arrangements found in lower-income families. For example, lower down-payment
mortgage products that recognize lack of
capital and consideration of consistent
income from multiple jobs or job changes
are now widely accepted.
Financial institutions have learned
effective marketing techniques that help
them reach low- and moderate-income
markets, such as use of targeted advertising
in ethnic or neighborhood newspapers, or
working with community organizations to

2

help counsel and screen potential applicants. Banks have learned that there are
many community-based organizations with
which they can work in making housing,
small business and other community development loans available.

REGULATORY ISSUES
Over CRA’s history, community groups
have focused on gaining access to information and to the regulatory decision-making
process. The push for public disclosure of
CRA ratings and evaluations, permanent
extension of the Home Mortgage Disclosure
Act and the new disclosures of small business lending data are just some examples.
As one who values public information and
open comprehensible governmental processes, I understand the importance of these
issues to community groups.
One of those recent issues emerged
from the Federal Reserve’s efforts to amend
our Regulation Y that governs the activities
of bank holding companies. Many community organizations are particularly concerned with the part of Regulation Y that
covers the application process used by
bank holding companies in mergers and
acquisitions.
We proposed the streamlined procedures
to reduce the overall costs and regulatory
burdens associated with the applications
process. Our original proposal drew over
300 comments from bankers, community
organizations and others. Most of the comments by community organizations and
public officials reflected concerns that the
streamlined procedures would make it
harder for the public to provide comments
on an applicant’s CRA performance and
other aspects of the convenience and needs
factor that the Board must consider.
Having participated directly in the
review and discussion of these comments, I
can assure everyone that all of them were
continued on p. 6

SBA and Missouri Banks Finance Successful Small Business

Hermann, Mo., now
has another reason to be
proud of Phyllis Hannan.
Owner of Laser Mark It
and Laser Light
Technologies, Hannan was
named the 1996 National
Small Businessperson of
the Year by the Small
Business Administration.
Hannan, a native of
Hermann, started Laser
Mark It in Glendale, Calif.,
in the mid-1980s. The
company uses laser technology to put marks such
as logos and serial numbers on products ranging from trophies to
medical instruments. As business took
off, Hannan decided to expand, but not in
California. Instead, she decided to open
Laser Light Technologies in her hometown. Hannan had secured land in the
Hermann Industrial Park and pursued
financing through the Meramec Regional
Development Corporation, a Small
Business Administration–certified development corporation. It is administered by
the Meramec Regional Planning Commission, an Economic Development
Administration (EDA)–funded Economic
Development District.
Using loans from SBA and BayHermann-Berger Bank, Hannan built and
equipped an 8,000 square-foot, state-ofthe-art plant. Opened in 1992, Laser
Light Technologies now services more
than 300 customers. Today, the plant
employs more than 50 people and houses
the engineering staff and research and
development teams for both the Hermann
and Glendale facilities. The Hermann
business was so successful that more
production space was needed, leading to
a 12,000 square-foot addition financed
with loans from the SBA and First Bank
of Hermann.

Phyllis Hannan, owner of
Laser Light Technologies
of Hermann, Mo., received
the 1996 National Small
Businessperson of the Year
award from the Small
Business Administration.

South African Banker
Visits Arkansas
In April, the Fed was host to Dr.
Etienne van Loggerenberg, Group
Development Manager for ABSA Bank in
Johannesburg, South Africa. Dr. van
Loggerenberg was in the United States to
research the Community Reinvestment
Act and the avenues banks use to comply with the regulation. The ABSA Bank
is proposing a similar regulation to the
South African government.
Arkansas was Dr. van Loggerenberg’s
first stop. In selecting banks to visit, Dr.
van Loggerenberg used the Internet to
identify outstanding rated banks. He
chose Southern Development Bancorporation’s Arkansas subsidiaries, Elk
Horn Bank & Trust and Arkansas
Enterprise Group in Arkadelphia and
the Good Faith Fund in Pine Bluff, to
obtain a rural bank’s perspective on
community reinvestment.
In describing his views of the CRA to
Dr. van Loggerenberg, Joe Miles, president of Elk Horn Bank, stated that he is
encouraged by the revised regulation
and says compliance for small rural

3

banks will be easier since lending is
their lifeline.
Dr. van Loggerenberg learned about
gap financing to manufacturing firms
from Brian Kelly, president of Arkansas
Enterprise Group. One of the many challenges of lending in the Arkansas Delta,
an area often compared to a third-world
country, is financing to companies that
create employment. AEG’s focus is on
manufacturers that export goods so that
income is being injected into the community. Since its inception, AEG has made
$14 million in development loans and
investments to 85 small companies.
Dr. van Loggerenberg also attended
an Affordable Housing Finance Lenders’
Forum at the Fed’s Little Rock Branch.
The Forum provided detailed information on local, state and national programs that banks can use to increase
their affordable housing lending in lowand moderate-income communities.
This provided Dr. van Loggerenberg an
expanded perspective on the government’s role in community revitalization.

U n i t e d Wa y ’s I nv o l v e m e n t P r o
Grant Leads to More Affordable Housing
Part of this article reprinted by permission of Tim Bolding.

Minnie Peats is an elderly woman living in Memphis who had never owned her
own home. However, since United Way of
the Mid-South focused its efforts on community building—and, specifically, affordable housing—Peat and her sister, Ella,
were able to pool their pension income and
buy one. “I have been living all these
years and never earned enough money to
own a home. This is just a blessing,”
Peat said.
Like many, the Peat sisters have
benefitted from United Way’s HOPE III
(Homeownership Opportunities for
People Everywhere) grant. The U.S.
Department of Housing and Urban
Development (HUD) awarded a $1 million implementation grant to United Way
in February 1994. United Way used it to
leverage an additional $1.6 million in grant
funding from the U.S. Department of Health
and Human Services, Tennessee Housing
Development Authority, Community
Foundation of Greater Memphis and the
City Department of Housing and Community
Development.
HOPE III builds on and significantly
expands United Way’s involvement in community building and affordable housing.
In late 1992, a group of community development corporations (CDCs) asked United
Way to be the lead agency in a consortium
to apply for a HOPE III planning grant,
predecessor to the implementation grant.
The bid was successful, and HUD awarded
$54,000 to United Way in February 1993.
The grant was used for an extensive study
to determine the feasibility of converting
government-owned properties into affordable housing for neighborhood residents.

The study showed that CDCs could purchase,
rehabilitate and sell the homes to low- and
moderate-income households profitably.
HOPE III gave United Way an opportunity to leverage financial resources to
support CDCs and affordable housing
development in greater Memphis. The
grant called for United Housing—a United
Way subsidiary corporation—to purchase,

program has helped individual home buyers attain mortgage financing and expanded
loan opportunities for financial institutions
to help meet their Community Reinvestment
Act requirements. Dorothy Cleaves, community investment coordinator for
NationsBank and United Way Housing
Committee member, said of HOPE III, “I
saw a tremendous opportunity for

rehabilitate and sell 30 government-owned
properties to low- and moderate-income
individuals and families. In addition, United
Housing agreed to provide training and
counseling to perspective home buyers.
United Housing fulfilled its grant
obligations by subcontracting with CDCs.
According to Tim Bolding, United Housing’s
director, “CDCs are used to giving away
their services. This program allows them to
do their critical work and get paid for it, too.”
The response to the program has been
overwhelming. Although United Way has
done little marketing, word has spread
throughout the community, and more than
700 people have gone through the homeowner training program. As of November
1996, HOPE III had completed 40 homes
throughout the Memphis area.
United Housing also has compiled a
variety of grants and mortgage products
into a package for low- to moderateincome home buyers. This facet of the

NationsBank. We have products that fit
what United Way was trying to do.”
With an abundance of interested and
qualified home buyers and the availability of
financing, the rehabilitated homes are selling
quickly. “We had a contract on the house
before the work was completed,” said Steve
Lockwood, executive director of VollintineEvergreen Community Association CDC and
a contractor on one of the HUD homes.
United Way’s success can be attributed
to following these four strategies:
1. Foster Leadership and Diversity.
Fostering leadership and diversity is fundamental to how United Way operates.
United Way’s Venture Fund grants are helping to open doors with direct grants to neighborhood associations, home buyer training
and HOPE III subcontracts to CDCs and
small minority entrepreneurs. United Way is
pursuing every means possible to support
and build the capacity of neighborhood-based
leadership and organizations.

4

nt Provides HOPE in Memphis
2. Build Community Capacity by
Leveraging Resources. United Way uses a
variety of means to provide people and
neighborhood-based organizations with the
tools and resources needed to implement
neighborhood-driven housing and economic
development programs. For example, while
renovating the HUD houses, United Housing
realized recently that there is a problem

with lead-based paint in the homes. As a
result, United Housing applied for and
secured a $500,000 grant from the U.S.
Department of Health and Human Services
to train and pay welfare recipients to
remove the lead-based paint.
3. Promote Collaboration and
Partnership. United Way’s communitybuilding efforts have stimulated collaboration among donors and CDCs. The
program established around HOPE III has
become a collaborative process that uses
the particular strengths of the public,
private and nonprofit sectors. United
Way has combined various grants and
loans from public and private funders to
make financing work for low- to moderate-income home buyers. HOPE III finds
those who might be a higher risk without
help. It reduces the risk to private financial institutions by providing financial
assistance, training and packaging for
their mortgages.

4. Enhance Corporate Relationships.
HOPE III strengthens United Way’s workplace connections. For example, many
employees working for major corporations
in Memphis are long-time United Way
donors and may actually qualify for HOPE
III homes. In addition, HOPE III’s use of
private lending institutions builds yet
another connection to United Way. When

Bolding made his presentation to the management at NationsBank for the annual
campaign, he reminded them that the bank
had already originated three mortgages for
HOPE III low-income home buyers with
more buyers on the way.
HOPE III is the most ambitious aspect
of United Way’s community-building and
affordable housing efforts to date. Although
affordable housing is a new area for United
Way, it is recognized as a key to stabilizing
families and neighborhoods. The momentum generated from the first grant has fostered a partnership between United Way
and Shelby County’s Housing Department to
apply for a second round of funding.

United Way of the Mid-South is making homeownership dreams come true through its HOPE III grant.
Shown here is the dedication of the 40th home rehabbed in Memphis. Pictured from right are: Harry Shaw,
director of United Way of the Mid-South; Rosemary Hill, homeowner; Benjamin Davis, director of the
Memphis HUD office;Tim Bolding, HOPE III director; the Rev. Kenneth Robinson, HOPE III board member;
and Karl Birkholz, United Way board member.

5

CRA
continued from p. 2

fully considered and that the comments
did affect the outcome. The major issues
were discussed at length by the Board.
We tried to strike a balance between the
need to reduce cost and paperwork burdens in the application process and the
need to continue to ensure adequate public access to the process.
First, we retained the full 30-day public comment period from the date of public notice in a newspaper or in the Federal
Register. In response to public comments,
the new rule will require a holding company to publish its notice no earlier than
15 days before its full application is actually
filed with the Federal Reserve. Moreover,
the Board modified the proposal to require
the applicant to discuss how the transaction will meet the convenience and needs
of the communities to be served and the
steps that will be undertaken to improve
any deficient CRA record.
Second, the Board will publish a new
expanded list of applications on a weekly
basis and will expedite distribution of this
information (see Resources on p.8).
Third, to protect the public’s capacity
to develop substantive comments where
warranted, the Board provided that under
certain circumstances, the public comment period would be extended for up to
15 days to assure access to the application.
Moreover, the public has means
other than the application process to
raise concerns about CRA performance.
The Board and the other agencies have
made improvements in the way they publish CRA examination schedules so that
the public and community organizations
can contribute information to the agencies to be considered when examinations
are done. The examination time is an
important moment to raise issues with
the institutions themselves.
While I understand that many of you
think that your only leverage is at application time, I would encourage you to
discuss your concerns with institutions
and their regulators at any time.

Addressing Lender Risks on Brownfields
Glenn P. Harris, Trial Attorney
U.S. Small Business Administration
In response to the interest in brownfields generated by our December 1996 Community Affairs
newsletter, Mr. Harris was invited to address
financing issues during a Lenders’ Forum held at
our Louisville Branch earlier this year. He is an
advisor on environmental matters for the SBA.
Increasingly, lenders are encountering
requests to provide financing despite the
presence of environmental contamination at
property that the prospective borrower is
offering as collateral. Despite recent legislative and regulatory changes that extend the
safe harbor for lenders from liability for
cleanup costs under federal laws, lenders still
face varying liability under state laws. This
risk often deters lenders from extending
financing if collateral is subject to contamination, as do other practical considerations, such
as the questionable value of such property in
the event of a borrower’s default.
One action that will limit a lender’s
risk on a loan that involves the sale of
property subject to environmental contamination is to obtain indemnification from
the seller. If indemnification is not possible,
it often will be necessary to scrutinize the
individual circumstances of the contamination at the site. First, it is important to
obtain a thorough, current environmental
site assessment, preferably from a company
that has performed satisfactory work in the
past. After obtaining the report from this
investigation, issues to consider include
the following:
1. What is the status of cleanup efforts
at the site; i.e., has a party begun to perform
remediation and is it close to projected completion? If not complete, how much is the
cleanup expected to cost, and what is the
level of certainty about the estimate?
Generally, contamination of an underground

6

water system will be considerably more
expensive than contamination of soil only.
2. Is the borrower or another party
going to perform the remaining remediation
at the site, and what are the financial
resources of the party performing the
cleanup?
3. Is there a state cleanup fund that may
be available to reimburse a borrower’s remediation costs? If so, what is the likelihood of
such reimbursement, and when is payment
likely to occur?
4. Does the contamination consist of
petroleum or man-made chemicals? If the
contamination consists of petroleum, a number of states have adopted “risk-based corrective action” programs that impose less stringent cleanup standards or, in some cases,
allow it to remain in the ground if it does not
pose a threat to a drinking water supply.
5. Can the borrower pledge alternative
collateral to secure the loan that might offset
any losses to the lender either from not being
able to foreclose on the property after default
(to avoid environmental liability) or if it was
unable to sell the property without paying for
extensive cleanup costs?
6. Is the state or local environmental
agency willing to issue a letter confirming the
extent of remediation that would be necessary at
the site? Although no agency will issue such a
letter in absolute terms, even some degree of
assurance as to the scope of remaining work at
the site may provide a sufficient identification of
risk so as to allow disbursement.
There are a number of factors that
lenders may consider in attempting to quantify and offset the risk arising from a loan
involving a brownfield property. Although
it is impossible to obtain a risk-free position, even through indemnification, often it
is possible to limit the scope of risk to a reasonable level, thereby allowing loan disbursement to occur.

fields

SBA LOANS FIGHT BACK AGAINST MOTHER NATURE
The Small Business Administration (SBA) is offering 4 percent economic injury loans to small
Midwestern and Southern businesses affected by the recent natural disasters. These loans provide
working capital to small businesses and small agricultural cooperatives to help them recover.
This aid is available only to applicants with no credit available elsewhere; that is, if the
922'
business and its owners cannot provide for their own recovery from nongovernment
(394.72m)
sources. Businesses in the following Eighth District counties are eligible:
Arkansas: Ashley, Bradley, Calhoun, Chicot, Clark, Cleburne, Cleveland, Columbia,
Conway, Craighead, Cross, Dallas, Desha, Drew, Faulkner, Grant, Greene,
Hempstead, Hot Springs, Independence, Jackson, Jefferson, Lafayette, Lawrence,
Lincoln, Lonoke, Mississippi, Nevada, Ouachita, Poinsett, Pope, Prairie, Pulaski,
Saline, Sharp, Union, White and Woodruff
Illinois: Alexander, Gallatin, Hamilton, Hardin, Johnson, Massac, Pope, Pulaski,
Saline, Union, White and Williamson
Indiana: 87 counties statewide
1000'
Kentucky: 90 counties statewide
(304.80m)
Mississippi: Benton, Lafayette, Lee, Marshall, Pontotoc, Prentiss, Tippah, and Union
Missouri: Cape Girardeau, Lincoln, Mississippi, Pike, St. Charles and Scott
Tennessee: 44 counties statewide
For further information on Arkansas or Missouri, contact SBA at (800) 366-6303.
Information on Illinois, Indiana, Kentucky, Mississippi and Tennessee is available by
calling (800) 359-2227.

800'
(304.80m)

FANNIE MAE COMES TO MISSISSIPPI
Fannie Mae is opening a statewide Partnership Office in
Jackson and is targeting $2.5 billion in single-family and
multifamily financing to assist more than 30,000 families in
Mississippi over the next five years.
Fannie Mae has partnered with the state of Mississippi,
local mortgage lenders and housing partners to increase
homeownership opportunities. Through the HouseMississippi
investment strategy, below-market
interest rate mortgages
922'

with little or no down payment will be provided. In addition,
the Mississippi Rural Housing Experiment pilot program allows
buyers to use the equity in inherited land as the down payment.
Other elements of HouseMississippi include homebuyer
education and counseling, mortgage revenue bonds,
employer-assisted housing, multifamily tax exempt bonds,
and rehabilitation and home improvement lending.
For more information, call 1-800-FANNIE.

(394.72m)

NEW FUNDING FOR ARKANSAS ENTREPRENEURS
The Central Arkansas Entrepreneurship Training Program
(CAETP) held its first class May 12 with 20 potential entrepreneurs
attending. The training is targeted to low- and moderate-income individuals and areas in Pulaski County. Executive Director Pamela Petty
says the program’s importance will increase as the new welfare reform
provisions come into effect.
922'
(394.72m)

Partnerships with existing organizations will be key to the program’s success. According to Petty, current partners include Arkansas
Human Development Corp., Main Street ARGENTA, and InAffordable Housing.
For more information, call Pamela Petty at (501) 372-5110.

7

The Federal Reserve Board
recently announced the publication of H.2A, a new weekly listing
of applications and notices that
have been filed under the Bank
Holding Company Act or the
Change in Bank Control Act. The
publication lists applications and
notices alphabetically by applicant, together with the appropriate Federal Reserve Bank where
comments may be filed and whom
to contact to receive the public
portion of an application. The
H.2A is available in three forms:

• Through

a fax-on-demand
call-in facility available 24
hours a day, seven days a
week. The system automatically will fax the most recent
copy of the publication to the
caller. The call-in number is
(202) 452-3655.

•

On the Board’s Internet Home
Page at www.bog.frb.fed.us

• By mail, by contacting the

Board’s Publication Services
at (202) 452-3245 or by writing

to Publications Services, MS127, Federal Reserve Board,
Washington, D.C., 20551.
Community-Based Development—
An Idea Whose Time Has Come—
An April 1997 report from the
Federal Reserve Bank of
Richmond that describes the evolution of community-based development and the ways in which it
gradually acquired a supportive
political and financial structure.
Copies are available from the
Richmond Fed, (804) 697-8109.

calendar
Symposium of Microlending—San Antonio
Sponsor: Federal Reserve Bank of Dallas,
(800) 333-4460, ext. 5276

JULY

21-25 Neighborhood Reinvestment Training

29

Institute—Chicago
Sponsor: Neighborhood Reinvestment Corporation,
(800) 438-5547 or (202) 376-2642
Community Affairs Lenders’ Forum—Little Rock
Sponsor: Federal Reserve Bank of St. Louis,
(501) 324-8251

10-14 1997 National Community

AUGUST

23

Development Lending School—Seattle
Sponsor: University of Washington

13-15 Linking Community Strengths—
Jefferson City, Mo.
Sponsor: Pathways from Poverty;
Contact Missouri Valley
Human Resource CAA, (816) 886-7476

Breaking Ground: A Beginner’s
Guide for Nonprofit Developers—
A publication produced by the
Federal Reserve Bank of Dallas
to help nonprofits, lenders and
other individuals who are interested in learning about nonprofits as affordable housing
developers.
To obtain a copy, call Judy
Armstrong of the St. Louis Fed’s
Community Affairs Office,
(314) 444-8646.

SEPTEMBER

Resources

3-5

Brownfields ‘97 Conference—
Kansas City, Mo.
Sponsor: U.S. Environmental
Protection Agency,
(888) 795-4684

11-12 Fair Lending Conference—
Arlington, Va.
Sponsor: Consumer Bankers
Association,
(703) 276-1750

FIRST CLASS MAIL
U.S. POSTAGE

PAID
Post Office Box 442
St. Louis, Missouri 63166

Contributors: Judy Armstrong, Matthew Ashby, Kim
Bowlin, Diana Judge, Tamme Mattingly Tannehill,
Keith Turbett and Glenda Wilson. Bridges is published
by the Community Affairs Office of the Federal
Reserve Bank of St. Louis. Please direct any questions
to Glenda Wilson at (314) 444-8317.
Bridges also is available on the Internet at
www.stls.frb.org.

ST. LOUIS, MO
PERMIT NO. 444