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CSascade
A newsletter from the Philadelphia Federal Reserve Bank about consumer c red it and community reinves t ment

Volume 1, Number 1
June 1984

7o Our Rea<Jer :::;:
Cascade is a periodic newsletter
designed to facilitate the flow of
in format ion on issues of concern to
bankers and their custor.iers in
Pennsy lvania , Delaware, and Southern New Jersey. Cascade is received
by community groups , consumer
advocates , government agencies ,
and all types of financial institutions .
Cascade takes its name from the
Alexander Calder mob ile - the
world 's largest mobile - that the
Ph iladelphia Fed commissioned as
part of the City of Ph iladelphi a's
public art program.

In this Issue:
Notes from Around
the District . ...... . ... .. . . .. Page 2
PA Homeowners ' Emergency
Mortgage Assistance .. ... . Page 2
Delayed Funds
Ava il ab ility .. . .......... . .. Page 3
Phila. Fed holds
Conference ... .. . ...... .. .. Page 3
Guest Column - Ph il Farley,
Regulations Assistance Manager,
The Federal Reserve Bank
of Philadelphia .. . . .. ..... . Page 3
Three Community Housing
Projects . .. . ........... .. .. Page 4

The interests of the Federal Reserve Bank of Ph ila delphia in consumer credit and community revitalization are strong and varied. We 're
pleased, with this first issue of Cascade , to illustrate how these interests
relate to issues that are of benefit to you.
Cascade will appear at periodic intervals to inform you of important
developments in consumer banking
and community reinvestment. Cascade
will identify subjects which consumers feel strongly about and some
interesting initiatives in retail credit.
It will give special coverage to programs that exemplify public/private
partnerships in urban revitalization
and distinctive efforts by neighborhood organizations to enhance their
communities.
This all comes in the course of the
Philadelphia Fed's community outreach and consumer relations work.
We hope that many of you will have
the opportunity to meet our staff in
one context or another. A full range of
their activities is described in this
issue.
We welcome your input to strengthen our consumer affairs and community reinvestment work. If you have
questions or comments about consumer and community banking, one
of our specialists will be pleased to talk with you.
Community Affairs Officer-Fred Manning-5 74-6482
Regulations Assistance Manager-Phil Farley-5 74-6458
Public Services and Consumer Affairs Manag er-Jim Dygert-5 746112

Cascade Editor-Patrick Bond-5 74-6407
Sincerely,

The Role of the
Philadelphia Fed . . . .. ... . . Page 5
Interview - Evers ley Vaughn ,
Pres ident, PCNO ... .. ..... Page 6

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Federal Reserve Bank of St. Louis

Edward G. Boehne
President

2

Notes From Around the
District
Federal Reserve District Three includes most of Pennsylvania (east of
Pittsburgh), Southern New Jersey,
and Delaware. We 're pleased to briefly describe any community development efforts within the district, particularly where financial institutions
may play a role. Contact Patrick Bond
- (215) 574-6407 - with news from
your area.

Bucks County Bank and
Trust Finances Plant
Renovation
Eas tern Ceram ics , in Morrisville, PA,
is th e benefi c iary of $2 .2 million in
finan c ing from Bucks County Bank
and Trust. The funds will be used to
acquire, rehabilitate, and reactivate
a vacant til e manufacturing plant. In
the process , 1 20 new jobs wil l be
c reate d . A $775 ,000 Urban Developm ent Action Grant is also be ing
us ed to get the plant restarted .

Banker Chairs Trenton
NHS Fundraising Effort
The Neighborhood Housing Servic es ofTrenton , Inc. was aided in its
most re c ent fundraising drive by
John Walther, the Chairman of the
Board of New Jersey National Bank.
Accord ing to Barry Black ofTrenton
N HS , th e organ ization raised enough
money to produce a small surplus
over an operating budget of
$133,000 . This came as a resu lt of
Wal ther's efforts to pub licize Trenton
N HS , his personal contacts in the
business community , and New
Jersey National 's doubling of their
N HS co ntribution of $10 ,000 .

Aetna Contributes to
Kensington Revitalization
After being contacted by Nationa l
Peopl es Action in Chicago and by
Phil ad elph ia's Kensington Action
Now (KAN) several years ago , Aetna
Life and Casualty Company made a
commitment of $2,000 ,000 to the
Kens ington Area Revital ization
Proj ect (KARP) .Aetna found it possible to alter their underwriting policies
in Kens ington as well and , as part of
KAN 's Insurance Program , Aetna
Digitized forag
FRASER
reed to provide an insurance
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

hot line, arson prevention consultation , and written adverse action
notices to those residents turned
down for insurance coverage. A
meeting with Aetna on May 3 reconfirmed their interest in the area.
According to Debbie Fischetti of
KARP, the revitalization funding partly grants but mainly financing
for otherwise unbankable projects
- is very important. "Two million
dollars is flowing through the com munity now, and that's what we
need ."

struct benches and other needed
items at a Senior Citizen Park in
West Philadelphia. PN B Vice President Tom Patterson visualized the
work opportunity as an extension of
the bank's Operation Prepare (begun
in 1967), a program for 40 high
school juniors and seniors. Besides
creating much-needed summer jobs
for youths , PN B is providing a valuable community service to elderly
residents of Ph iladelphia.

Bank of Mid-Jersey
Convenes Consumer
PNB Hires Youths for
Summer Community Work Advisory Board
A total of 76 young Philadelphians
wi ll be hired this summer by Philadelphia National Bank, and their
work for the bank will have a very
positive effect on some Philadelphia
neighborhoods . In addition to light
maintenance duties at PN B's
branches , the crews of ten young
adults will cooperate with Philade lphia Neighborhood Housing Services efforts to install smoke detectors in the homes of 600 senior
cit izens . They'll also work with the
Greater Philadelphia Karate Institute,
a youth development group, to con-

The Bank of Mid-Jersey in Bordentown is util izing the knowledge of
several local residents to help the
bank assess its communities ' credit
needs . Eight community representatives meet quarterly with the bank's
leading officers and lenders to review
policies , observe branch procedures , and offer adv ice to the bank
about what kind of impact they can
have in their trade area. The bank
also meets with local township officials and encourages their branch
managers to p lay an active role in
the communities they serve .

PA Housing Finance Agency
Begins Homeowners' Emergency Mortagage
Assistance
Last
December,
Pennsylvania
Governor Dick Thornburgh signed
House Bill 500 into law, thereby
plac ing a hold on many mortgage
foreclosure actions that were occurring as a consequence of the
Commonwealth 's economic problems . Since then , the economy has
improved markedly, the ban on foreclosures was lifted (on March 24) ,
and , as stipulated by the law, the
Pennsylvania Housing Finance
Agency began its program of provid ing emergency loans to homeowners in danger of foreclosure.
The program was designed for those
Pennsylvania residents who are 60
days in arrears on conventional
mortgages for one- or two-family
owner-occupied dwellings . The
home must be the principal residence and the homeowner must
show that the financial hardship was
beyond his or her contro l.

By late May, 1000 people had filed
applications to the program , according to Ph il Friday of the Housing
Finance Agency. Friday believes
there to be as many as 10,000 more
homeowners who may be eligible
for the emergency loans . The State
House and Senate wi ll soon complete the allocat ion of $26 million for
the program , wh ich will essentially
take over the burden of carrying the
homeowner's mortgage for up to
three years .
The procedure for taking advantage
of the funds is as follows : 1) When a
financial institution sends out its
required Notice of Foreclosure (Act
91 Notice) to a homeowner, it must
include information about the program and the name of a qualified
consumer credit counseling agency.
2) The homeowner must meet with
the agency or the bank within one
(Continued on page 7)

3

Fed Addresses Delays on Checking Funds Availability
Early this spring, the Federal Reserve
Board, the Federal Deposit Insurance Corporation, the Federal Home
Loan Bank Board , and the Office of
the Comptroller of the Currency
issued a joint policy statement that
encourages financial institutions to
voluntarily review and disclose to
depositors the institution's policies
on delayed availability of funds. In
addition, institutions are urged to
consider whether delay periods can
be reduced , to refrain from imposing
unnecessary delays on government
checks that are deposited to established accounts, and to consider
giving depositors some means to
request an exception to the standard
hold policy.
The four agencies strongly believe
that voluntary action rather than
mandatory requirements represents
the best solution to the delayed funds
problem. However, if voluntary action
appears inadequate, the agencies
will consider further action.
According to the joint policy statement, the longstanding practice of
delaying a customer's withdrawal of

funds that have been deposited by
check has recently attracted increased interest at both the state
and federal level. Delays in availability of funds have been used by
financial institutions to reduce their
risk of loss when deposited checks
are returned unpaid . However,
recent studies have revealed that
only a small percentage (about one
percent) of the checks that are returned unpaid have resulted in
actual losses to financial institutions . Although the low frequency of
losses may be directly attributed to
the delayed availability policies, the
agencies feel that imposing delays
on all checks (especially social
security or other government checks)
deposited to established accounts
does not apear to be justified by the
risk of loss .
The policy statement asks financial
institutions to review their funds
availability policy and to consider
such factois as the age of the account, past experience with the
depositor, type of check , and location of the payor depository institution when assessing whether a given

GUEST COLUMN
Phil Farley, Regulations Assistance Manager,
The Federal Reserve Bank of Philadelphia
The number and complexity of bank
regulations , particularly in the area
of consumer protection , creates a
problem for many lenders who find it
difficult to keep up with regulatory
changes and to learn enough about
the regulations to comply with them
readily.
To help ease this burden , the Philadelphia Fed stands ready to provide
assistance and information to those
who are obligated to comply with the
regulations and interpretations
issued by the Federal Reserve Board
and its staff.
In 'keeping with this objective, our
Reserve Bank maintains a regulatory
hotline (215-57 4-6458) during business hours which interested parties
can call to obtain up-to-date information on any aspect of Federal
Reserve regulations. In addition, from
time to time the regulatory assistance

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Federal Reserve Bank of St. Louis

staff of this Bank conducts or participates in regulations workshops
throughout the Third Federal Reserve
District.
In many cases we have found the
most effective way to help is through
personal consultations . On-site ,
personal visits by our staff members
offer several advantages. Our people
are able to discuss particular problems or questions in greater detail
and offer guidance. They can review
and help develop the policies , procedures and forms needed to implement consumer protection requirements. They can even help train the
personnel who have to deal with the
rules every working day.
Regulatory assistance of any kind
can be obtained readily by calling
the above-mentioned hotline number.

situation presents a risk of loss that
justifies a delay in availability of
funds. As part of their review, institutions also should consider provid ing
depositors with a way to request an
exception to the standard hold policy.
Institutions should also inform depositors of that possibility.

Philadelphia Fed
Consu mer Atta! rs
Conference

Holds

On June 1, a conference emphasizing bank compliance with the large
body of consumer protection law
was hosted by the Federal Reserve
Bank of Philadelph ia. Speakers
included Griff Garwood , Director of
the Division of Consumer and
Community Affairs at the Fed eral
Reserve Board in Washington ;
JoAnn Barefoot, a bank consultant
from Columbus , Ohio; Victor Crans(Continued on page 7)

4

Three Housing Proje cts Meet With Success
When other approaches fail , the job
of rehabilitating the housing stock
of a neighborhood often falls into
the hands of grassroots self-help organizations . In three depressed
areas near Philadelphia, housing
rehab efforts are being spurred by
co mmunity-based groups .
Chester, PA is one of the five poorest
ci tie s in the nation . A quarter of the
hom es are abandoned and in recent
years thousands of residents have
los t their jobs . Yet one small group,
led by Rev . Wallace-Smith , Pastor of
Ca lvary Baptist Church , has not given
up hope for its low-income neighbo rhood.
·

housing efforts have failed in
Chester, CCI P is proving that a
community-based approach without
government restrictions and with
sensible private-sector involvement
can be successful .
In Bristol Township, Bucks County,
PA , Better Homes, Incorporated
(B HI) is using some government
funds and some foundation grants
to help finance an active housing
development plan. Since its inception in 1975, BH I has worked to
bring decent housing to the blighted
Kingswood neighborhood . B H l's
rehabilitated homes sell for an
average of $25 ,000; the average
family income of the recipients is
$17 ,000 .
BH I was aided with funding from the
Pennsylvania Department of Community Affairs , the Neighborhood
Self Help Development Program ,
Bristol Township, United Presbyterian Church, and the William Penn
Foundation . But it was for its public/
private partnership qualities in
housing finance that BHI was
awarded a Certificate of National
Merit by the U.S. Department of
Housing and Urban Development in
1982.

Rev . Wal lace Smith o f CC IP

Smith 's group, the Chester Community Improvement Project
(CC IP), lost its VISTA funding in 1981 ,
but throug h the participation of local
res idents and student volunteers , is
now expanding the housing rehab
proiec ts that have already made it a
unique Chester resource . Abandoned homes are located , title research is conducted , the homes are
pu rchased , and a team of workers
moves in to fully rehabilitate them .
Counseli ng is provided for the potential owners . Yet the price of the
finished product remains Chester's
best bargain at under $10 ,000 .
Staff from CCI Pis currently securing
mortgage agreements from local institutions . This has been one of their
biggest challenges , as many lenders
find it hard to believe that so much
can be done for so little. While even
Digitized for many
FRASERc ity and state-sponsored
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

As BH I President Joe Watts tells it,
" It is our job to take abandoned
dilapidated houses and make them
into good homes , and it is our job to
help lower income families become
capable homeowners. First Federal
S&L provided the first mortgages.
They believed in us before we had
proven ourselves. Pete Farmer, Ed
Grubbs , and Bill Ba iley of Trevose
Federal S&L have helped us with
below-market mortgages when mortgage money was scarce and high
interest mortgages could have killed
our program ." The fact that only one
foreclosure has occurred on a BHI

B HI before and after.

-

Vol unteers at work on a CCI P project.

home in the last decade indicates
the quality of Watts ' credit counseling
staff.
Also among the nation 's five poorest
cities is Camden , New Jersey. The
South Broadway Revitalization Project-under the auspices of Jaycee
Housing Counseling, lnc.-in the
Fillmore neighborhood received
original construction financing from
the City of Camden 's Community
Development Block Grant funds .
But Frank DiVenanzo, the Executive
Director of the Project, was able to
raise another $420 ,000 in grants and
loans from the private sector to rehabili tate a three b lock strip .
While the South Broadway Revitalization Project already has 28 Section
8 (subsidized housing) apartment
units and 1 4 rehabbed homes to its
credit, it was also for the small bus iness assistance it was able to provide in Camden that it received a

5

HUD Certificate of National Merit.
DiVenanzo described the organization 's main problem as the low appraisals they're getting on the housing, but with continued successes
in revitalizing the South Broadway
area, he hopes more funds for mortgages and small business loans will
become available.
CCI P contact: Salem Shuchman
21 5-876-8663
B HI contact: Joe Watts 21 5-7850649
Camden Jaycees contact: Frank
DiVenanzo 609-541-1 000

The Philadelphia FedOur Role in Consumer Banking and Community
Reinvestment
Through functions in six different
areas, staffers at the Federal Reserve
Bank of Philadelphia are contributing to strengthening local economies
and ensuring fair consumer banking practices .
The Community Affairs Unit,-t,ttff
of the Philadelphia Feei'~ Oef'0r1ffiOFtt
Qf ~eipeFoisirn I a, ,el FlO§Jl::JleJ.tial"I , visits
bankers, community groups , business persons, government officials,
and other civic leaders in Federal
Reserve DistrictThree. Over time, we
hope to acquire a better perspective
on the credit needs of communities
and to publicize how some financial
institutions are using innovative strategies to help meet these needs.
Cascade will highlight examples of
useful community revitalization programs and Financing Alternatives, a
resource directory currently in production, will list specific government
programs that can help financial institutions become more involved .

In Camden , a house on South Broadway before .. .

and after rehabilitation .

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Federal Reserve Bank of St. Louis

Elsewhere in the Philadelphia Fed ,
economists in the urban/regional
studies section of our Economic
Research Department are often
called on for advice on economic
development matters . Their reports
can be found in the bi-monthly publication, Business Review.
The Regulations Assistance Staff
in the Department of Supervision and
Regulation interprets and explains
the fifteen consumer protection laws ,
including the Truth in Lending Act

Community Affairs Offi ce r Fred
Manning .

and the Equa l Credit Opportunity
Act . Every month , two hundred inquiries are received by the staff.
They also conduct seminars and
workshops with bank compliance
officers and have published A Guide
to the Consumer Banking Regulations of the Federal Reserve System.
This book aids bankers in understanding detailed provisions of the
laws .
A group of consumer affairs examiners, also in the Department of Supervision and Regulation , regularly
goes to banks to verify compliance .
If a customer has a particular problem
with a bank , he or she can receive
(Continued on page 7)

Reserve Bank staffers with responsibilities in Consumer and Community Affairs .

6

INTERVIEW
Eversley Vaughan, President
Philadelphia Council of Neighborhood Organizations (PCNO)
to get binding written agreements .
•

To work with area banks in
developing a below marketrate small business pool for
new and expanding businesses .

•

To continue to advocate for
the acceptance of certain
branch closing criteria.

•

Va ugh an, left , with PCNO members .

As President of PCNO , a coalition of
140 community groups in the City of
Ph il adelphia , Eversley Vaughan has
taken a lead role in the reinvestment
movement. A founding member of
East Mt.Airy Neighbors and of PCNO,
Vaughan has received numerous
public service awards . Last month ,
PCNOwas recognized by the Urban
Bankers Association for its distinguished contributions to community
involvement in Philadelphia .
PCNO has in the past utilized a forma l protest mechanism available to
the pub li c through the Community
Reinvestment Act (CRA) . When a financial institution files an application
with its Federal regulator to merge
with or acquire another institution , to
open a new branch , or to change its
charter, its record of meeting its community's credit needs is carefully
analyzed . Community groups have
submitted CRA protests on app lications when they feel the credit
needs have not been met, often , as
Vaughan points out , to allow the
groups some leverage in negotiating
with banks. The regulators, including
the Philadelphia Fed, serve as intermediary if a protest arises .
PCNO's Annual Convention in October, 1 983 produced the following
resolutions on banking issues :
•

To continue to monitor and
negotiate with banks regarding reinvestment efforts in
our neighborhoods using
CRA and other available tools

https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis

•

•

To continue to encourage
community credit unions and
assist them in getting the financial and technical assistance they need .
To begin to do community
outreach to educate neighborhoods about the importance of banking institutions
and their operations as well
as how to monitor the ir actions .
To continue to support and
promote the Philadelphia
Mortgage Plan , the Philadelphia Rehabilitation Plan and
the Action Loan Program
· through advocating the affirmative marketing of these
programs at all area financial
institutions .

Recently, Community Affairs Representatives Michael Collins and
Patrick Bond spoke with Vaughan at
PCNO's Girard Avenue headquarters.

Our new strategy (negotiating formal agreements with banks) evolved
because we found we could use
CRA more effectively, thanks to a
new State banking law. That law
opened up greater opportunities for
banks to merge and so more applications became subject to CRA approval by the regulators .
CASCADE: The Community Resource
Center helped you put the initial
CRA protest together.
VAUGHAN: They still are helping us
research . We depend on the Resource Center but we have volunteers on our Banking and ReinvestmentTask Force who help with community credit unions and business
strips .
CASCADE: What kind of things do
you do for community development
credit unions?
VAUGHAN: We built them into our
agreements with the banks . We got
one bank to give a $5 ,000 grant to
two credit unions plus they agreed
to include credit unions in their
teller-trainee courses .
And we passed legislation in City
Council last year allowing city funds
to be deposited in community credit
unions .
CASCADE: What are some other results of the negotiated agreements?
VAUGHAN: Well, with just one of the
three banks we've talked to, we've
seen a ten-fold increase in their
Philadelphia Mortgage Plan lending
and they're now the second or third
top Philadelphia Rehabilitation Plan
Lender. They've improved their inhouse training . And , instead of working on just two commercial strips,
which was in the agreement, they're
doing three: 28th and Girard , Point
Breeze and Germantown .

CASCADE: PCNO was organized in
the mid-seventies. When did the
group first become interested in
banking issues?
VAUGHAN: In May, 1981 when a
large bank downsized their branch
at 22nd and Indiana. That was our
first battle.
The last round started with another
bank's branch closing in Germantown . What really ticked us off was
that they closed their branch and
there was a domino effect, and we're
just beginning to come out of that.

CASCADE: So small businesses are
becoming a major concern of
PCNO?

CASCADE: How has your strategy
for dealing with the banks changed
since 1980?
VAUGHAN: The Community Reinvestment Act was very new when we
took on the first bank. We used demonstration tactics a lot more.

VAUGHAN: Oh , yes. We're working
now on raising a million dollars for a
Small Business Capital Note. The
Commerce Department just committed a quarter million . We're going to
ask Greater Philadelphia First Corporation for a quarter million and

7

we're hoping the eight big banks will
chip in two or three hundred thousand. The last quarter million we
hope to get from foundations .
We've worked with Philadelphia
Citywide Development Corporation
and we're shepherding eleven CDCs
(Community Development Corporations) to the banks we have agreements with .
And we're getting interested in
business incubators .

the banks , " Put it on hold until we
can work out some kind of full-service
activity."
a bill in City Council to give more lead
time before a branch closing.

CASCADE: How do you feel about
the branch closings issue now?

CASCADE: And your other lobbying
in City Council?

VAUGHAN: We're saying , " Let us

VAUGHAN: We're more interested

know in time so we can work out
things with people in the neighborhood ." You see , the banks that got
out first had it easy. Now the others
are a little more cautious about
closing a branch .
We're also aware of increasing
automat ion being used to replace
these tellers . We 've been saying to

now in linked deposits (i .e., linking
the city's tu nds that are deposited at
a bank to that bank's Community
Reinvestment Act performance) .
Also , on these new development
projects in Center City, if one percent has to go to art, then at least that
much should go to the community. It
happens in other cities.

Emergency Mortgage
Assistance
(Continued from page 2)

CASCADE: And last year, you pushed

VAUGHAN: Yes , but that was tabled

because of voluntary arrangements
to the same effect. But we were told
that they'll pull it out again for a vote
if we need it.

month of receipt of the notice. 3) An
application is then filed with the
Housing Finance Agency. The
Agency has two months to act on the
application. If it's approved , the
Agency will " cure" the delinquency
and cover the monthly mortgage
payments . 4) The homeowner works
out a system of repaying to the
Agency what is in effect an interestfree loan. Repayment usually will
begin after the original mortgage is
paid off entirely. Interest of 9% per
year on the outstanding debt to the
Agency will be charged when the
payments have started.
Homeowners can find out more
about the program by dialing the
Housing Finance Agency's toll -free
hotline: 1-800-342-2397 .

Philadelphia Fed Holds Consumer Affairs Conference
(Continued from page 3)

ton , the Director of Compliance at
New Jersey's largest bank , First
National State Bank; Professor Jean
Kinsey, a consumer economist at
the University of Minnesota; Raoul
Edwards , the Editor of United States
Banker; Steven Smith of the Criminal
Investigation Division of the U.S.
Treasury Department; and Peter
Kinzler, the Minority counsel for the
U.S. Senate Committee on Banking ,

Housing , and Urban Affairs .
In the next issue of Cascade, excerpts
from the Conference will be printed
and some of the more stimulating
issues will be followed up on.
Look also for stories on Fannie Mae
programs. reverse equity mortgages,
and community development credit
unions in the next Cascade. If you
have news or information to pass on
to Federal Reserve District Three
bankers , government redevelopment officials , or consumer and

community groups , please write to
us :
Editor
Cascade
The Federal Reserve Bank
of Philadelphia
Ten Independence Mall
Philadelphia , PA 19106
The material in Cascade should not
necessarily be interpreted as the
official policy or endorsement of the
Federal Reserve Bank of Philadelphia.

The Philadelphia Fed
Our Role in Consumer Banking and Community Reinvestment
(Continued from page 5)

next Cascade.

help from our consumer complaint
specialists, part of our Public Services and Consumer Affairs Department. Around forty complaints are
handled each month .

The economic education staff,
also in Public Services, conducts a
number of activities aimed at broadening the public's awareness and understanding of economic issues.
Programs are being undertaken to
teach basic economic principles in
local elementary and secondary
schools. The staff's newsletter,
Money Matters, contributes to these
goals.

A variety of pamphlets addressing
consumer banking issues has been
published by Public Services and is
available upon request. A complete
Digitized for listing
FRASER will be offered in the
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Federal Reserve Bank of St. Louis

This year, staff from the six areas will
convene two major public conferences on consumer banking and
community reinvestment, hold dozens
of seminars and workshops on the
subjects , and make hundreds of
personal contacts with individuals
and groups . Through Cascade and
our other publications , we'll try to
keep the public well-informed about
banking and redevelopment issues
of interest to us all.

~
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Federal Reserve Bank of St. Louis

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