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FEDERAL
RESERVE
BANK OF
ATLANTA
VOLUME
_,
15,
NUMBER
1,
2005
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Identity Violations
Spur Changes to
Fair Credit
Reporting Act
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
Check 21: A
Step on the
Path to
Electronic
Banking
Condo
Conversions:
Gauging the
Impact on
Affordable
Housing
2004 Highlights
for Community
Affairs
partners
in community and economic development
FEATURES
PA G E
7
Identity Violations Spur Changes
to Fair Credit Reporting Act
Recent changes to the Fair Credit Reporting Act (FCRA)
in response to increasing incid ents of id entity theft
will provide lenders, consumers, and law enforce ment
agencies with a new arsenal to combat fraud .
PAGE
10
Check 21: A Step on the
Path to Electronic Banking
The Check Clearing for the 21st Century Act, known
as Chec k 21, rep resents a significant step in the evolutio n toward e lec tronically processed payme nts in
the U.S.
PA G E
2
Coping with Identity Theft
PAGE
13
Millions of consumers have experienced the
Condo Conversions: Gauging
the Impact on Affordable Housing
devastating impact of identity theft in which
Condo conversions are taking place at a feverish pace in
someone uses personal information surrep-
certain markets in the Sixth District. Careful considera-
titious ly to commit fraud or other crimes.
tion of both opportunities and concerns connected v.rith
these deals can help co nversion projects become part
The FTC's identity theft program conducts
of the soluti on to the afforda bility gap in competitive
outreach to both consumers and businesses
housing markets.
about how to stymie the high incidence of
this crime.
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
PAGE
15
2004 Highlights for
Community Affairs
This special feature highlights significant accomp lishments fo r th e Atlanta Fed's Commu nity Affairs s taff
in 2004.
In Step with the
Changing Marketplace
A the nation's central bank, the Feel is n•sponsib le
In thr Sixth District,".<'
fort hrre main functions that llC'lp C'nsure economic
ha,·e already adclc-cl posi-
stability: morlC'tary policy, suprnision and regulation,
tions clerntecl to tlw dC'li,·-
an d pay ments system SC't-Yic-C's. As I not rel in the las t
e1y of Pfkc-1i\•p economic-
issue of Parl11ffs, tllC' nation's ,·olume of paper checks
education programs in kry
continues to clrc-l inr as dectronic paymen ts increase.
brandws. A lthough these
This shift in payments practices has brrn rr inforc-rd by
posit ions do not report to
T hr Check Cleari ng for the :21st Ce ntury Act (Check
Commu nity AJfairs, th ey
:21). Hrcentl y passed by Congress, the new legislat ion
pr m ·icl<' a great complP-
allo\l·s an dcC'lronic- image to S<'IYC' as a substitute fo r
ment to existing Community Affairs programs.
the 01iginal paper i.nstn.1ment.
Since :2001, ,,.<' hm·p clesignatecl a HPgional Community
In rcsponS(' to thi s changing markrtpl ac-c, I hr Fcclr ral
Deve lop ment l\1anage r in eac h of FH B At lant a's six
HC'se r-ve Systrm has stream l irwcl it s opera ti ons an cl
local ions lo mPrl local needs more em•ctiw ly. While
c-onso liclalrcl its functions to rnhanc-r C'fTicienc-y. As a
these positions focus mainly on firnmcial and regulatory
result , many of our branch oflic-es have rrcl ucecl sta ff
issues specific- to lo w- ancl moclerate-inc-ome families
and overhead. Several Feel branc::lws thro ughout t he
and markets, they also present many opport unities
Sys t em have also rr loc-atecl to small er fac i l i ties and
t o co ll aborate wi th comm unity leaclPrs on a n1riety
are c-onsiclrring sdl ing or subleasing existing builclings.
of projects.
E,·en though thr F'rcl has downsized its physical opPr-
No one can predict the futu re. l l(J\\'C'\"er. I can say with
at ions l o remai n in step with tlw ma r kPtp lac-<', bra nch
confi dence that c·ven lhough the Feel remains corn mitt ecl
o lTi ('('S w i ll contin ue to play a vi tal ro le in th eir com-
to adapt ive change in fulfi ll ing its mission, strong local
munities. Loe-al boards of di recto rs iclrnlify, int('rprrl ,
commun ity involvement will always remain significant
and add ress reg ional C'conomic issues, ancl th us arr a
in ensuring a safe and sound banking system.
crucial soun·p of valuable' information for I lw Dist r"ic-t 's
board and presi<k nt.
Recognizing nr\l· opport unit irs to innPase pffpc-tin'rwss , many lksen•p Banks are' now expa nding tlw
ro le of th P bra nches in communi ty outrPac h, financ ial
lil Prac-y, ancl Pc-onomic- rcl ucalion training. Such ini t iati,·C's not only irnpron' consumer a\\·,:1rrnPss ancl inform
.J uan C. Sanchez
tllC' public about thr Feel, but tlwy also prPsPnl the Feel
Community Affairs Of'fker
with aclclitional insights into local ec-onom iPs.
FEDERAL
RESERVE
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
BANK
OF
ATLAN T A
one
Coping With Identity Theft
IMAGINE DISCOVERING THAT SOMEONE HAS OPENED CREDIT CARD ACCOUNTS
OR SECURED A HOME EQUITY OR CAR LOAN UNDER AN ASSUMED NAME: YOURS.
CONSIDER RECEIVING AN IRS W-2 FORM REPORTING WAGES EARNED BY SOMEONE ELSE WHO HAS USED YOUR NAME AND SOCIAL SECURITY NUMBER.
U nfo rtu n ate ly, in ci de nt s just lik e I hese happ en
pC'l'sonal in f'ormati on to open new credit card account s.
to co nsum er s- now id en tit y th eft v icti ms- all o ver
Even if the thi ef is apprehended and conv icted, he or she
th e co untry, eve ry cl ay. A 2003 st ud y co mmi ss ioned
may have sold th e v icti m's inform ation. T hen another
by t he Federa l Traci e Co m m issi on ( FT C) fo und t hat
thi ef uses the victim 's in f'o1rnation, and the cycle of fraud
i dent it y th eft a ffect ed a lm ost 10 m illi on co ns um ers
begins again .
in 2002.
Vi cti ms o ft en need help dea l i ng w i t h th e recurri ng
l"al lo ut o f t hi s cri me eac h tim e t hey di spu t e a new
ID theft can be devastating and recurring
T he init ial impac t of id entity the n can be devastat-
fraudul ent t rad eli ne on a cr edit repor t o r tak e a call
from a debl collector f'or debts in cu rred by the identi ty
i ng, in part b ecause i t 's a cri me t hat can r ev isit the
thi ef. Fortunately they can turn to ind ustry, law enforce-
vi ct im again and again , t ak in g th e same or d ifferen t
ment organi zations, and regul atory agenc ies for mea n-
for ms. An id en tity thief may fi rst use a consum er 's
ingf ul assistan ce.
twFRASER
o
Digitized for
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
VOLUME
15 , NUMBER
1
FTC's identity theft program
Financial institution and business
In 1998, wl1Pn Congress passed th e II) T heft Act, it
resources to help combat identity theft
c1iminalizC'cl identity theft and clirf'CtC'cl the F1'C' to estab-
Financial instit utions can also direct \'ictims to the
lish a national program to central izf' complaints a.ncl pro-
PTC"s ed ucationa l resources and SC' lf-hC'lp materials ,
vide education for vict ims of ID Th eft. In r esponse to
including the FTC's
ff) Th('.f/ A.ff'idanit.
Victims can usC'
the mandat<' , the FTC establislwd th e Id ent ity Theft
this document to dispute mu ltiple fraudulent accounts
Data ClearinghousC'-tl1<' nation's centralized repository
opened in their names by tlw ID thief ratlwr than f1lling
of consumer complaints i1wohing identity thf'ft -which
out a separate form for each creditor. The A.f/'ida1·it is
today houses about 750,000 iclent ity theft complaints.
ava ilable at th e ID tlw f't websit<' and is also includ ed
The FTC's II) Theft Program is designed to hC'lp con-
at the bac k o f bo th th e Engl ish an d Spanish editions
sunwrs on three fronts by: 1) coordinat ing ID theft
of the ID theft book, Tak(' C11w:qe: Fighting B(l('k A,1;ai11st
\·ictim assistance and education efforts, :2) facilitating
Iden tity 771 ej/.
information sharing and outreach training for law
enforcement , and :3) promoting pre\'cntion elTorts and
Tlw FTC has also prC'pared a guide for businessPs to
use in the wakP o f an in formation securit y breach. Tlw
best prac ti ces throu gh industry outl'(•ach. Through tlw
11)
Theft Program ,
• \'ictims can file ID theft compla int s with the PTC
online at www.consumer.gov/idtheft or by contact-
VICTIMS FILING IDENTITY THEFT
COMPLAINTS WITH THE FTC MOST
ing the t oll -free hotl ine I -877-IDTI IEPT. Wh etlwr
liling online or by phone, \ictims are introduced to
COMMONLY REPORT CREDIT CARD
resources that explain what steps to take to recm·er
FRAUD, UTILITIES OR TELEPHONE
from identity theft and how to minimize th e risk of
FRAUD, AND BANK FRAUD.
its occurrf'nce.
• Law enforcement officers can use the comp laints
filed with Uw FTC lo im·estigate ca<,es. Each complaint
FTC"s !11formatio11 Compromise and the Risk r//'fde11 tity
entered into the FTC's clataba'ie can be retrie\·('(I by
Th e_/ /: Guicla11t(' for Vour Busill ('SS, an1ilable at the
any of the I , 100 law enforcC'mC'nt agencies aut hor-
Wf'bsite , pro\·idcs ad\·ic·p on contacting consum0rs,
izecl to access th e I[) theft data through the PTC's
law rnforce nwnt agencies, ancl nf'cl it bureaus. It also
includes information about how to contact thr FTC' for
Consumer SentinC'l Network.
• Pinancial inst itutions can help consunwrs by promoting policies and busi,wss practices designed to
a'>sist,mcr and elq)lains what inclivicluals nrrcl to know to
protcC'l themselves.
thwart this crime , and by pro\'iding assistance t o
\ict ims oncC' it happens. I3usinessC's should cons ider
f1\'e key steps:
Victims filing iclC'ntity theft comp laints with the FTC
I. l\lirrimizc risk of fraud through responsibl<'
information-handling practices;
techniques for kerping information saf e;
:3. l ' tilizc proper mNhocls to dispos<' of customer
information;
and hav<' Iwrsonncl in place; m1cl
accounts as wC'll as electron.ic [LU1cl transfers (sec graphs
on pag<' "1 ).
work to c!C',u· their financial records.
BANK
OF
tech means. Low-tech methods include st<'aling mail or
ril'ling thro ugh garbage for bank sta tements ancl other
5. Provide p<'rsonnel trainC'd to assist vict ims as they
RESERVE
ancl bank fraucl , w hi ch invo lves deposit and savings
ID theft can b<' perpetrated through lm1·-tech or high-
"1. Instil utf' measurf's to rf'sponcl to secu rity breaches
FEDERAL
most commonly repoIi credit card fraud. utilit ics or tclcphone rra ucl (especially involving cell phonr accounts),
:2. Train front -Lilw staff regarding src-urit y goals a.nd
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
ID theft: many forms, many faces
ATLANTA
inform ation that enables the thil'f to obtai n credit in
somC'onf' else's name.
three
OnC' high-tPch way of st C'a ling pPrsonal data is online
"phishing." A fra udster uses spam C'-mail or an l nt Prnet
pop-up lllC'SsagC' IO I ri c k consum prs in t O di sc-los ing a
c-rNlit card accou nt number, Social SPc-u rit y numlJC'r,
Jm<;swonl, or other sensitive personal info rm ati on .
Fraudulent Use of Personal Information
I
I i('r\''s how it works. You rec-C' iVC' an C'-mai l that claims
to bC' l"rom you r bank, Int erne t SC'1v icP proviclrr (IS P) or
Credit card , loan, and bank fraud as a percent of
sonlP ot lw r org,rnizat ion . The mC'ssagC' typically tells you
identity theft complaints, 2002-2004 1
th at you 1wrcl to update yow- account information and
may inc-ludr a warnin g th at somr l hing undrsirablP will
happen if you don't rrspond. The nwssage d.irrc-ts you to
Credit Card Fraud
a websitC' that looks likr U1e legitimalC' si te. llowe\'er, thr
24.4
■
New Accounts
■
Existing Account
■
Unspecified
11.1
5.4
2002
41%
that th e prrpr trators can steal your identil y and ru n up
19.3
11.0
1.4
2003
32%
16.5
11.9
bil ls in your nanw.
For morr in for m al ion abo ut how p hi shing wo rk s,
see fi rm· No t To Get lfooked by o -P//ishi11g ' Srn111, at
0.1
2004
28%
www.rtc.gov.
Legislative changes: the FACT Act
Loan Fraud
Import ant nrw rights and renwd iC's arr a\'ailabiC' to ID
1.7
■
sitC' is bogus, designed t o ··phish" yo ur information so
Bu sin ess / Personal /
Stu dent Loan
■
Auto Loan / Lease
■
Rea l Estate Loan
1.1
0.9
0.5
2002
6%
t hert v ic t im s thro ugh th e Fair Crrdit lkporting Ac-I
( F'C'RA) , w hi ch was rC' cen tly amenckd by th e Fair and
1.3
2.0
1.0 0.3
2003
5%
Unspecified
1.6
1.9
N(' \1· laws took d Tec- t in 200°1 to lwlp \"ictims ren1Pdy
the PfTec ts of id entit y theft. Now, whe n ID tlwft \'ic-
0.1
1.1
Accura te' Credit Transactions ( PACT ) Ac t.
2004
5%
t ims contac t any o nP of the thre e natio n wid e nc•dit
rc•porting agrnc-ies ( Equifax , Ex pPrian , Trans lf nion ),
Bank Fraud
t lw aw·nc-irs must prm·id e t hr m with a summary o f
2
their 11C'W identit y lhert r ights. Th esP new r ights incl uciC'
8.1
■
Existing Accounts
■
Electronic Fund
Transfer
■
New Accounts
3.1
3.7
1.0
2002
16%
c-rPdit reports and to obtain transaction rC'corcls rP latPcl
8.3
4.8
18
0.5
2003
to ID tlwft ( uc- h as th e thi ef's fraudui(' nt credit ap pli-
17%
Unspecified
8.5
2004
1
2
th l' v ic tim 's ability to b lock fraudul C' nt t radelinrs on
6.6
16
ca ti on ) from thP b usin ess tha t extencled crC'dit to
the impostor.
0.1
18%
Otlwr right s inc-ludr th e abi lity to stop th osr fu rni shing information to consumer rC'po rt ing agrne irs from
Percenta ges are ba sed on the total number of complaints in
the Identi ty Th eft Data Clearinghouse for ea ch calendar yea r:
pro vidin g in acc ura tr i nforma tion rC'su ll ing fro m II)
CY 2002 = 161 ,896; CY 2003 = 215,093; CY 2004 = 246,570.
t llC' f"t t o t he c r ed it b u reaus, alo ng wit h lh e righ t l o
1ncl udes fraud involving checking and sa vings accoun ts and
electronic fund transfers.
obtain fraud alC'rts and se\·era l frrr crr dit reports.
Th e new law makC's police rpport s more im portant
than P\'C' r as a tool to help \i ctims rec-O\'C'r. 1any of th e
new FCRA I D th r ft ri ghts an d rl'n l<'ci iPS arr ava ilabl e
only if tlw victim provides appropriatr docunwntation ,
Source: Federal Trade Commission
f o uFRASER
r
Digitized for
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
in c luding a law r nforc-C'm ent rr port. Fo r m or P in formal ion on th Pse new ri ghts and n ' m('(Jies, rra cl the
VOLUME
15,
NUMBER
1
two-pagr s ummary en till rcl Re111cclyi11.IJ Ilic t;_ff'cc/s
or with businPssrs that P:-.1Pncl r cl c-rrclil to a s usp<'C'I who
of lde11/ il.lJ Tlt ej/ at www.consLmwr.gO\'/idllwf't.
usPd the ,·ictim's name. Thrsr matPl'ials- an1ilablr in
both English and Spanish- arr fr<'C' al www.consumer.
FTC consumer resources
FTC n'SOLll'c·rs can hPlp l'0nsLu1wrs learn how 10 mini-
gov/ idthrfl. Victi ms withouL web access can obtain
thrsr mal<'tials by calling the F'TC's ID Thrft I lotlinr at
mize Ihr ir risk of' bPcomi ng an idrntil y theft vicl irn and
1-877-1DTII EFT, Monday-Frid ay, bet wt'rn Da m an d
explain what s tpps lo lakP to undo the r ffrcts of this
8pm , EaslPrn Ti mr . ♦
crimr. 'l\vo F'TC publications arr kry rrsou rc-rs f'or cons um r rs: Tak e Clw1:r1c: Figl11i11g Ha ck Ayai 11 sl lde11 lil .lJ
Tlu'. ft , and //J Tlt e,/L \Vital '.~ It All A/Jou/ , a lon g with
thr JD T!t cjl A,[l'idal'il .
T his ai1ic·IC' \\'a-; \\'l'i ll C'll by Moniqu(' F. Einhorn, alto nlC'y with
tlw lclC'11ti1y Tlwf'I Progr,m1 al llw FPcleral Track C'o 111miss io11.
T lw \'ipws c•xprPSSPci in this arti c- lP ai·p my 0\\'11 and do no t
11ec·pss,uily refl PC'l thost• of' the Commission or ;m y incli,·idual
( 'ommissio1wr.
Vic-ti ms can USC' Ihe A.ff'i<la 1•il when disp ul ing fraudulent accounts with nationwid r crrdit rC'port ing agr ncirs
Phishing - Consumers Beware!
"Phlshing" is a growing Internet scam in which criminals
use fraudulent e-mails and websites to retrieve
pe1 onal finan cial information such as acco unt
a virus or "eavesdropping" software program on your
computer to capture personal infonnation.
• Alert the bank or business being used as a front for
numbers, passwords, or social secmity numbers. This
the scan1 about the phlshi.ng e-mail. Make the contact
onfidentiaJ information i then used to steal money
yolll'self using an established phone nwnber or Inte1°
from yom checking acco unt or to run up charges on
net address for the business.
yom credit cards.
If you are an identity theft victim as the result of a phlsh-
E-mails that appear to be from banks or other financial
ing cam, contact the following groups:
institutions requesting personal information are likely to
• Bank or business of the a count;
be fraudulent Financial institutions typically do not con-
• Local police department;
tact customers via e-mail to verify personal information
• Federal Trade Commission's Identity Theft Clearing-
or reque t it online. The best protection is not to respond
house (www.consumer.gov/idtheft), which contains
to these e-mails.
instru tions to help repott identity theft;
• Credit bur aus, to pla e a fraud alert on yom credit
What if you receive a phishing e-mail?
A brochme released by federal bank, thrift, and credit
report and obtain a copy of your credit report
for review.
♦
mlion agencies offers the following infonnation to help
consun1ers identify and combat phlslling schemes.
If you receive a phlshi.ng e-mail:
• Do not respond to the e-mail.
For more information, an interagency brochure
on phishing is available at http://www.occ.gov/
consum er/phishing. htm. Additional consumer
infom1ation an be accessed on tl1e AntiPhishing Work Group's website at
http://www.antiphishing.or?f.
• Do not open the link located in the e-mail. The link
connects to a false website or form, and it may install
FEDERAL
RESERVE BANK OF ATLANTA
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
fi ve
Identity Theft: A Case History
On July 15, 2004, I received a call from a frantic county
the victims also worked. This information resulted in
resident. She had just learned, to her surprise, that she
new arrest and search warrants for the suspect.
had recently secured a personal loan for $7,999 from
CitiFinancial Services. A woman using her name and
ll1vestigations over the next several months traced more
Social Security number had picked up the check the
than $50,000 in additional credit card fraud to multiple
week before and deposited it at the local Teachers Credit
victims' accounts. The suspect was purchasing airline
Union. When credit union secwity personnel pulled all
tickets with stolen credit card numbers, traveling, and
the paperwork for the account, sure enough- the photo
selling tickets. She was indicted on 12 felony charges and
on the driver's license used by the suspect was not the
another an·est warrant was issued.
victim's, though the address listed by the impostor was
just down the street from the victim's residence.
On November 23, 2004, I located a rental car being operated by the suspect, and I arrested her once more dming
On a hunch I drove to the victim's treet. I found the sus-
a stakeout of the auto. A search of the car identifi ed
pect standing in a doorway three houses away from
another 25 victims. In the back seat were packets from
the victim, placed her under arrest for identity theft, and
a local tax preparation service and mortgage docwnents
conducted a routine search of her residence. Little did I
from several refinance packages. Investigation into these
know I would soon find the "jackpot."
docmnents led to another apparent accomplice, one of
the suspect's girlfriends who had recently worked at
ll1side the residence a team of ten agents located per-
both businesses. The suspect was again taken into cus-
sonal inforn1ation, names, social secmity nmnbers, credit
tody and in front of the court, but once more released-
card nun1bers, and home addresses for approxirnately
innocent until proven guilty.
150 different individuals. The suspect had worked for a
limousine service that catered to business travelers, and
As I prepare for the upcoming trial, the suspect is out
she had combed the contracts for personal information.
and roaming, who knows where. I have worked with
We found multiple additional accom1ts opened in the vic-
many other identity theft cases that fit the same pattern
tin1's name, along with the victim's stolen mail . The sus-
during this time period. Investigating these cases takes
pect appeared to be breaking into her neighbor's mailbox
an enonnous amount of time and effort. I don't expect
and stealing her bank and credit card statements, many
the work to slow down any time soon.
♦
of which contained personal infonnation. I also recovered
several credit reports issued to a nearby mortgage
Detective Scott G. WY11e
company on different victims, including one for the
Montgomery County Police/ Fraud Section
original victim.
Rockville, Maryland
The suspect was charged with multiple offenses but
released from custody, innocent until proven guilty. Over
the next several weeks, I tracked down multiple victin1S,
fraudulent credit cards, orders, and stolen property totaling more than $150,000 in fraud generated by this single
suspect. I also uncovered apparent accomplices, including a girlfriend who worked at the mortgage company.
Another of the suspect's girlfriends worked in the personnel department of a YMCA branch where several of
Digitized for
si xFRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
VOLUME
15, NUMBER
1
Identity Violations Spur Changes
to Fair Credit Reporting Act
LARGE-SCALE THEFTS OF SOCIAL SECURITY NUMBERS AND CREDIT REPORT
DATA HAVE BEEN MAKING THE NATIONAL NEWS LATELY AS IDENTITY CROOKS
BECOME MORE SOPHISTICATED AND EXPANSIVE IN THEIR TARGETS .
Why steal one identity at a t ime when you can steal
thousan ds by posin g as a l egiti mate small
busi ness·7
Rece nt changes to t he Fair Cr edit Re por tin g Act
( FCRA) in respo nse to incr easing incidents of id enti ty
of' a deta il ed fra ud , p erpetrat ed through organized
cri me. As a resu lt, perso nal informal ion was r el eased
fo r nearly l 45,000 people.
A cco rd ing to Cho iccPo in t's we b site , the expose d
th eft wi ll provide lenders, consumers, an d law enforce-
fil es included indivi duals' nam es, adclrC'sscs, soc ial
mcnt age ncies with a new arse nal to combat fra ud.
securit y numbers, cred it information , and other mat -
Enacted in 2003, the Pair and Acc urate Cr edi t Transac-
t ers of publ ic reco rd, suc h as bankrupt cies, liens, pro-
ti ons Ac t (FACT Act ) afford s consumers more pro tcc-
f ess iona l li censes, and real propert y data. An art icle
ti ons th an ever bdorc.
in th e Los Angeles Tim es on March 2, 2005 r epo rt C' d
Identity theft case affects thousands
Po i nt su ffered a si m i l ar in c id ent o f f ra ud i n Feb-
th at, acco rdin g to Ca lifo rn ia cou rt reco rd s, Cho ice-
Large-scale icl cntity theft can have widespread con-
ru ary 2002. Cons um ers arc cl early beco m ing more
seque nces. In February 2005, Cho ice Po int In c., a data
v ul n erab le t o ide n t it y th e ft as crimin als become
aggrcgat i on co mpany, ann ounced it was th e v i cti m
m ore rc'so urce ful.
FEDERAL
RESERVE
BANK
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
OF
ATLANTA
seve n
How can the Fair and Accurate
pay me nt s, missed payments, partial pay nwn ts, or
Credit Transactions Act help?
any otlwr form or default on th e account ).
The Federal Tracie Comm ission ( FTC) estimates th at
• Proh ibi ts consu mer reporting agenc ies from report-
approx im atC'ly JO mi ll ion indi viduals were victim s of
ing I he name, address, and telephone num ber or any
iden l il y I hef'I in 2002. The inc reasing nuntl>C'r o f cases
med ical creditor unless th e informal ion is provided
was on(' or th e catalysts for th e Fair and Accurate Credit
in codes I hat do not identify or infer I he provi der o f
Transacti ons (FACT) Act am endments to the FCRA. The
care or th e ind ividual's med ical condit ion.
legislati o n not only aims to prevent identit y t heft but
• Allows consumers to obtain one free annual repo rt
also prov ides reco urse for id enti ty th ef'I victim s and
from " nat ionw icl e speci alty co nsu mer report in g
addresses pri vacy concerns.
agencies" I hat issue non-credi t rcpor1s, if tlw report
The FACT Act acid s new prot ee l io ns I o I he FCRA
I hrough I he fo llo v.ring measures:
• A ll ows consumers to ob tain one rree credit report
relates to t he fo llowing informal ion: medical records
or payments; residential or tenant history; clwc k writing history; employment history; or insurwwe elaims.
annually fro m each of th e three main credi t reporting agencies.
• A llows consumers to place fraud alerts ,rnd militaiy
acti ve duty ale1ts on their credit reports.
• Mw1dates the trun cation of card information, accmmt
nu mbers, and social secLu·ity numbers on receipts.
• All ows identity theft victims to obtain copies or th e
impost or's account app lication and I ransac t ions.
Credit counseling agency gives high
marks for greater access to credit reports
Accord ing to Suzanne Boas, president o r Consu mer
Cr edit Co un se lin g Serv i ce (CCCS) of A tl anta In c.,
unsecu red debt has become mu ch more w idely ava ilable during I he 12 yea rs she has directed I he nonpro nt
age ncy. She states I hat since credit scores arc I he prin-
• Requires collection agencies to inform credi tors if a
cipal de term ining factor in approv ing cre dit card s, it is
debt is I he result of identity th eft w1d restricts crecli-
"tim ely t hat changes be made to give consumers better
tors rrom selling or placing such debt for collection.
access to the in formati on they need ."
• Req uires finai1 cial institutions to adopt proced ures
designed to spot and "red nag'' event s usually associatcd w ith iden tity theft.
CCCS has been edu ca tin g co nsume rs for yea rs to
requ est their credit reports. Ms. Boas secs the changes to
the FCRA as especially significai1t for res id ents outs ide
• Requ ires consumer repmiing agencies and any busi-
th e seven states th at already req uire free credit rcports-
nesscs th at use consume r reports lo adopt proce-
Colorado, Georgia, Main e, Maryland, Ma'isachusctts, New
du rcs ror their proper disposal.
Jersey, and Verm ont.
• Requires that identity theft victims receive a notice
of rights from credit report ing agencies.
Reactions from credit reporting agencies and lenders
• Allows co11Sw11ers to req uest their credit scores along
Cred it reporting agencies ha,·e made adj ustm ents to
w ith the factors that went int o comput ing the scores.
comply w ith new stipu lations that man cla t c free credi t
• Requires lenders to reveal a customer's credit score
report s fo r al l co nsumers. In sta t es lik e Geo rgia, how-
w1 d provide four reasons fo r the score wh en the cus-
ever, res ident s arc alread y entitled tot wo free credit
t orn cr applies for credit.
reports annua lly. To o ffset th e additi onal costs of issuing
• Requires lenders who receive not ice o f a disp ut e to
free yearly credit repo rts to consum ers w ho app ly for
invest igatc th e cl aim and pro vide not ice to cred it
them , t he credit burea us have recent ly increased th e
reporting agencies that the negative in formati on is
pri ce of report s fo r finan cial instit utions , I hus shift ing
bring disputed.
pa.ii o f the FACT Ac t compUance costs ont o lcnclcrs, the
• Requires creditors to send customers a not ice before
or no later than 30 clays after negati ve in fo rm ation
is fu rn ished to a credit bureau (fo r (' Xamp le, late
ei gh t
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
prirna1y purch,t<;crs o f credit reports.
Lenders too have th eir fair shw·e of wo tri cs w1d compli ance burden s. Fo r example, t hro ugh t lw FACT Ac t
VOLU M E
15,
NUMBER
1
co nsumrrs havc- th e ri ghl l o di spute crc- clil rc-po rti ng
Be proactive about identity theft
Rc-cc- nl data lossc-s by Choice Po inl , Bank o f Am e1ica,
c- r ro rs clir('c tl y w i th t hc- l('ncl er in qu es l io n. A sc- n ior
attornc-y al lhc- Am e1ica.n Bankc-rs Assoc iati on states th at
ancl olher maj or compani es highlighl l he reaso ns w hy
"everyone in the banking commun ity is an ti cipating that
th e FC' RA, lc-gislali on lhal addresses a convc- rgence o f
tlwre w ill be more [creclil -repo1i ing] clispul c-s."
con ce rn s about p r ivacy and identit y th0f"t , was recent ly
Tl10 impacl of these dispul c-s wi ll not be fully fdt until
arn c-n ck d. II is safe l o say that all organizati ons retai ning
th e fa ll of 2OOG when frc-e n ecl it rc-ports lw con10 avail-
sensili w consun10r in formation w i ll be held to a highe r
able nali onwicl0. Eligi bility for free reports w il l be phased
sl ancl arcl in th e yea rs t o co m e. Pri vacy ad vocates are
i.n , cl0p0ndi ng on th e consumer's state o f residence (see
already pushing for a nati onal securil y
cha.i.1 below) .
to <lle11 affected cusl on10rs when a company expe1iences
Su nTru st Bank 's co rpo ra l e p r iva cy o fficN, Cli ff
110 1ifi cal ion
law
a I l10f'I o f paper fi l0s and/or electro ni c securil y breach.
Bui don't wai t fo r a nolice in your mailbox inf'o1111ing
Bussard, is generally upbeal w ith resp0cl to l he FACT
Act amendments to the FC' HA. I le states I hal SunTrust
you I hal your identity has been stolen. For more inf'o r-
has alrc-ady imp lemented many o f lh e FACT Ac t pro-
mat io n on how to obl ain yo ur free n ed il report , see
visions, such as truncating accounl nw11bers on receipts.
the we bsit e al www.annu alcred itreport .c·o rn o r ca ll
Furl hc-rm ore, hc- is pleased I hat more consurner-s w ill be
877-:322-8228. ♦
tracki ng I heir credit repoIis. I !is ptimmy conce rn at this
stage is I he uncertainty of some o ft he rul es that havc- yet
Thi s art iclP was wrill Pn by .JoC' Cassar, sp ni or (·o nsu mC'r
affairs rxaminC'l" al lh(' Atlanta Feel.
l o be limdized and implemented.
When are free credit reports available in my state?
D
Western States
December 1, 2004
Midwest States
March 1, 2005
El
Southern States
June 1, 2005
[I
Eastern States & all
U.S. Territories
September 1, 2005
L
FEDERAL
RESERVE
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
BANK
OF
ATLANTA
ni ne
Check 21: AStep On the
Path to Electronic Banking
THE FED ENVISIONS A U.S. PAYMENTS SYSTEM THAT IS MORE RELIABLE, FASTER, AND
LESS EXPENSIVE AS CHECK PROCESSING BECOMES PRIMARILY ELECTRONIC, DISPLACING TODAY'S METHODS OF PROCESSING PAPER CHECKS. "CHECK 21 " IS HELPING TO
PAVE THE WAY.
Check 21 takes effect
The purpose of Check 21
The Check Clear ing for th e 2 1st Century Act , known
Check 21 makes it possible for banks to collect checks
as Check 21, became effective October 28, 200'-I, conclud-
by exchanging electro nic images or checks instead of the
ing a year of intense preparal ion by everyone in I he check
ori gin al paper documents, if I hey choose Io clo so. The
business. Check 2 l permits ban ks to create and exchange
new law not only permits a ban k l o prin t ancl use a sub-
a new ki ne! or paper document, the su bstitute check.
s! itute check in place or th e original, bu t it also requ ires
Through the new law, a properly crea ted substitut e
check becomes th e legal equ i\·alent of an original check.
other part ies to accept a prope r ly c-real eel subs titut e
check as if it were an ori gina l.
In simple terms, a substitute check is a digital image of
Pri or to Check 2 1, a bank could insist on recehing
an original check reprinted using a spec ifi c formal that
paper checks and thus fore<: other banks to d<:mancl ori-
can be processed the same way as the original on th e
ginal paper checks from its depositors. Now that Check 21
backroom systems of banks.
has taken effect, a bank that takes in "electron ic chec ks"
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
by agreement will be abl e to prese nt substitute chec ks,
eve n to i nsti t uti ons th at do no t agree to accept "electron ic chec ks. "
The Federal Reserve's role in Check 21
For F<:dera l Reserve Banks, th e y ear between the
enactnwnt o f Check 21 and its C'fTcctive elate was one of
int ense activity.
To inform th e pub li c, Rese rve Banks d istri b uted
information, cond ucted sem in ars, an cl cl evelopecl
I oo ls to he lp banks prepare fo r Check 2 1. Behind th e
scenes, hu nclrecls of Feel emp loyees across th e System
relookcl virtually every aspect or our check processing
operations w ith new hard wa r e' ancl sort ware. They
clC'vC'l opC'cl new procedures, co nclu ctecl sta ff training,
program med and tested new sys t ems , and rewrote
VOLUME
15 ,
NUMBER
1
our Operati ng Ci r cular No. 3, " Co l lec ti on o r Cash
Rese1ve st ucly in 2004, 36. 7 billion checks were pro-
Items and Rc lurn ed Checks. "
cessed in 2003, down from 41.9 billion in 2000. Increas-
On Oclobcr 28, Reserve Bru1ks declru·ed "all systems
ingly, consumers arc payi ng for goods and se rvi ces by
go" and brought Lo mar ket the new services enabled by
cr edit card , deb it card, and automated clearin ghouse
Check 21. It was Lhc beginn ing of a new era in payments.
(or ACll) transactions.
Debit card transact ions increased from 8.3 bi lli on in
2000 to 15.6 billion in 2003. In addition, payme nts that
A smooth transition
No one was sure exac tl y how th e lra nsiti o n to
start out as chec ks arc being converted into electronics
Check 21 wou ld play out. After all Lh e pub l icily and
for collect ion. Check-to-A CH lransaclions, in which a
hard work surrounding i mpl ementatio n of th e new
consumer writ es a check and the payee collects th e pay-
legislati on , perhaps the most stri king thing, now that
menl electronically through an automaled cleari nghouse,
several months have passed , is how smoo th the trans-
were in trod uced be fore Check 21 and have been growing
ili on has been.
rapidly. I n the second quru1er of 2002, 5.3 mil lion checks
Prior to th e Lransition, approx imately 60 percent of
consumers already had accounls thal clicln't return canceled checks. For them, th e change has not been noti ceable. Among the remain ing 40 pcrcenl w ho are used to
gettin g canceled checks, a number have begun to receive
a mix of can celed checks ru1d canceled substi tute checks.
THE NEW LAW IS A BRIDGE BETWEEN
THE OLD-FASHIONED PAPER CHECK
THAT WE USE TO PAY A MERCHANT
Contrary to so me predicti ons, there has been no fi rc-
AND THE WIDESPREAD ADOPTION
storn1 th us far.
In actuality, mosl checks ru·c being col lcclcd today the
OF ELECTRONIC TECHNOLOGIES TO
sam e way they were before Chec k 21 became effective.
Reserve Banks estimate th ey w ill be produc ing appro x-
COLLECT THAT CHECK.
imately 2 million substitute checks per clay by the second half o f 2005. But this figure still rep resents only 5 or
6 percent of Lola! check processing each clay.
Although Check 21 makes it possible for banks Lo col!eel check s using electroni c exchanges instead of Lraditional paper processing, th e new law does not force
were scnl Lo Iockboxes and converted into AC! I items.
By th e fo urth quarter of 2004, th is number grew t o
266.2 mi llion items.
Chec k-to-AC II conversion does nol work fo r eve ry
k in d of check, un like Check 21, wh i ch app lies Lo all
them Lo make th is switch.
k inds of checks.
Payment trends
Th e 36.7 billio n chec ks tha t A m eri cans wrote in
Sin ce the introduction of computers, people have been
2003 mak e il clear Lh al we are far from becoming a
predicting thal the U.S. would abandon paper payments
"checklcss " society. As long as we cli ng lo th e cleep ly-
a.ncl turn Lo electronic conu11erce. In October 1975, Clwng-
rooted A merican habil of paying for many t hings by
irlg 1'hnes magazine advised Arne1i ca.ns to "get ready for
wTiting checks, Check 21 does important work. Th e new
cashl ess, checkless living." In 1983, the Federal Reserve
law is a bridge bet ween the old-fashioned pa.per chec k
Bank of Atlanta predi cted that the use of checks would
that we use l o pay a merchru1t ru1cl the widespread adop-
pla.Lcau between 1987 and 1989 and then begin to declin e.
tion of clcclronic Lechnologi es to collect that check.
Though A meri cans ar e much fonder o f cas h and
checks th an th e pundits und erstood , in Lh c past few
yeru-s, Lhc long-ru1ticipated shift from paper payments to
eleclro ni cs has fin ally begun. Acc ording to a Federal
FEDERAL
RESERVE
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
B A NK
OF
ATLANTA
Technology drives changes
A pleasant surp ri se in Lhe new era of Check 2 1 has
been the in trodu ction of new serv ices fo r depositors.
ele ve n
Within t lw com ing year, some
banks w ill begin to roll out
im age-e nabl ed ATMs. These
'"01 1500120"
01/04/2002
8587408979
Tt1,s la ~ LEGAL COPY of
yovr check You can us~ ,t
tho S111no w.iy you wou ld USO
tho original check
th at inc ludes a photocopy o f
eac h deposi ted item. Th is
~
CV)
e
CO
q"
,.- q-
00>
~"'
cx,O
"'
"'
ATMs wi ll be able to provide
the deposit or wi th a receipt
N
O
I ]Ill'
,,• 00 0001g 51, 5 ,•'
pro cess w ill provi de much
more use ful r ec ords th an
th ose most depositors
receive today.
Banks arc aJso beginning to
introd uce retail businesses to
th e ab ilit y l o deposit chec ks
at the business site by imagin g the m and then transmittin g t he im ages to the
4-0o not eroorte or 'M'kebelowtis line. 4,
Exampl e of t he front and back of a substitute check.
r et ail er 's bank.
Looking ahead
Federal Reserve Banks w ill use Che c k 2 1-enab lecl
backroo m process ing to enco urage mo re and mo re
banks to shirt to el ectroni c-based c heck co llec ti on.
Today, w hil e we con tinue to operate our tradi ti onal
paper-based cheek processing systems, Check 2 1 makes
it possible for Reserve Banks to send and accept checks
in electronic f'orm to and from banks that have adopted
th e new technology, to transport the data electron icaJ ly,
and to print and present substitute chec ks.
Over tim e, as more banks adopt U1e technology Lo process checks electronically, they will deposit an increasing
proportion of their checks in electroni c form. Simul taneo usly, Reserve Banks w ill be ab le to prese nt an
in creasing proportion of chec ks to paying banks el ectronically rather than printing substil ulc cheeks.
Despite the pub li city that surrounded Check 2 l , the
new law has not caused a revolution. Nonetheless,
Check 2 1 represe nts a si gnifi cant step i n evo luti on
toward electronically processed payments in the U.S.
For more information, please access the Co 11s11111i'/' Guide 011
Check 2 1 011d Substitute Checks at http://www.fecl eralreserve.
go\'/pubs/c hec k2 l/consumer~guicle. hlm
Thi s arti c lP was wri tten by Richard FraJwr, ass istant gcnrral
co unse l at Lhc At Ian la Feel.
I we IV e
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
VOLUME
15,
NUMBER
1
Condo Conversions: Gauging the
Impact on Affordable Housing
Condominium conversions have emerged as a hot, new
trend in high-priced , high-growth real es tate markets.
Fueled by strong rcsiclential demand and relatively low
interest rales, developers and investors across the country arc in a fre nzied search for ren tal propcrl ies they can
purchase and I ransform into proli tablc condomin iu ms.
Th e downside is th at speculative condo pu rchases arc
on the 1isc and renters a.re being displacccl.
Deals attract both developers
and property owners
For deve lopers, condo conversions rep resent a lowcost, quick alternati ve to new consl ru cl io n. Th e developer makes an offer to th e property owne r based on
an esl ima.te o r th e market price or th e fin ished un its,
minus the cosl o f necessary upgrades. Bui ldings with
solid rental revenue can offer ongoing income as unit
remodeling is phased in. Because con\'crsion may take
only ha.If th e time of new construction, unit s are on th e
market more qui ckly, before de mand o r absorp ti o n
caught on with developers w ho app ly for Low In come
rates drop.
llousing Tax Credi ts as we l l. Although lw has not y<:'t
The prospect or conversion to condom iniu ms is enti c-
fi nanced a low-income conversion project, he says I hey
ing to many mu ll ifamily property owners as well. Th ey
make sense for developers on tight budgets raced wil h
a.re able to sell when the market wi ll suppor1 the highest
increasing land and construction costs.
pri c<:' possible. For some, the sale is much more attracti,·c than tlw continu<:'d fl ow of rental income.
Conversions most common near pricier homes
Increasing land and construction
where t hey offer an affordab le altcrn ati\'c to highe r-
costs drive conversions
priced homes and luxmy condos. ln\'cstors mostly seek
Com·ersion arc most common in neighborhoods
In mark ets li ke Miami, where specu lative land purchases have peaked, existing multifamily properties can
be less expensive than vacant land. When th e 1ising cost
Class A properties- buildings with higher-end units and
amenities in neighborhoods with strong demand.
However, as more developers converge on I hcsc pro fi l-
or construction is added to the equation- up 10 to 15 per-
ab le markets , even Class B and Class C bu ildings arc
cent in the past two yea.rs- the argunwnt for conversions
being targeted. In neighborhoods targeted for rcvitaliza-
becomcs quite convincing.
lion, a Class B conversion can enhance its marketabi lity
Peter l\lcDougal , with Citigro up's Ce nt er for Community Development Enterp1ise, says conversions have
FEDERAL
RESERVE
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
BANK
O F ATLANTA
tlu·ough the improved infrastructure and higher propcIty
values that accompany new constrnction proj ecls.
thirte en
Market indicators reveal a slow down in conversions
Some signs indicate th at the con version gold rush may
bc los ing a bit of steam . Acc ording to Rob ert Von w ith
become condo buyers. This approach would both increase
homeown ershi p ancl fo restall th e inconvenience and diJficult ics o f' disp lacement.
Real vest Appraisal Serv ices, developers th at got in early
Wit.h regard Io those not eligible for o w nership, advo-
on co nversions made lots o f m oney. But lw says prop-
eatcs unclcrlinc the im portance of pro tec ting low-income
ert y owners a.re catchin g on now and settin g higher sell-
famil ies, sen iors, and the disabled by ensuring th at adc-
ing p rices, th us eating into the profits proj ec ted f'or th e
quate ho using alternat ives ar e r eadily avail abl e.
conversion. For th e affordab le housing dcvrloper, higher
acquisition costs w ill increase fun ding needs ancl lessen
con version benefi ts.
New construction projects have become more compel -
Speculative investors drive housing prices higher
The h igh proportio n of spec ulati ve invr st ment now
driving p ro pe rty sal es in competitive markets is a cause
iti vc w ith con versions by improving amenities ancl adding
fo r concern . Many ar c buying condominiu ms and homes
upgra.cl cs, th ereby forcing converte rs to in ves t more in
w i th the int ent ion of sell ing th em imm ccli at cl y f'o r a
ca.ch unit to maintain the p roj ect's marketabi lit y.
p rofit in cncrgizccl markets. New constru ct ion contracts
Ultimately, be tLer (and cos tlier) ameni ti es a.re drivin g m edi an ho m e pri ces h igher th us p ush i ng th e
p rices of condomin iums beyond the reac h of median
in co m e fam ili es .
are oft en so ld t wo or more ti m es befo re th e un its arc
actu ally complctccl.
"Flipp ing'' is highly speculative and lea\·rs purchasers
exp osed to shi rt s in market demand. When th ese investm ent purchases sl op trading hands, industry experts pre-
Impact of conversions on housing affordability
The Nat iona.l Association of Realt ors' study on housing
afford ab il ity f'or 2004 sho w ed th e lowest affo rcl ab ili ty
diet many oft he units will end up as rental propc11jcs. The
result ing fl ood of unplanned rental vacan cies could aJ'fcet
mun icipal planning and market pricing in a commun ity.
rate in fo ur years. Despi te low mortgage rates, th e average household needed 132.6 per cent or its income to purchase a ho me. I n hi gh-priced mark ets llw pressure on
mocl cra tc-incomc famil ies is even stro nger.
Whil c stati sti cs show that 10 to 20 percent of existing
Balancing benefits and costs of conversion activity
Co nve rsio n ac t iv ily is pre dic ted to remai n stron g
in 2005. T hr benefit s of conversi ons, w hi ch w ill ce rtainly at tra ct more developer s, can be used to persuade
rent ers w il l pu rc hase convert.eel un i l s in I heir bu ilding,
cl evcl opc rs t o co nside r m or e ch all enging p rop ert ies
lhe remaini ng 80 percent w i ll be clisp lacccl.
in rn ocl c rate-i nco rne com muni ti es. Th ey also p rov id e
Tracy Petrrs , managin g director w ith th e Reel Capital
Group in Ohio, says t.hat co nve rsi ons cl o not see m to
be d irec tl y a ffec t in g th e affo rcl ablc ho using m ar ket
no np ro f'it cl c vc lopers wi th an altern ati ve t o hi gh land
and const ru e- I ion c osts.
Quest ions remain about how w ell muni cipaliti es w il l
yet, but he believes the impact will become more appar-
manage th e im pact of rental p roperty conversions. l nclus-
cnt as market dynamics change. Dan I logan, also wi th
t ry ex perts scr m t o ag ree t hat helping m o rr renters
Red Capital, says creatin g in ce nti ves and in creasin g
realize homeownership and protecti ng aJTo rcl ablc rental
subsidies th at suppor t th e clcvc lopmcn t o f affordabiC'
stock must be considered as seriously as in creasing th e
housing stock , alo ng with assisti ng low-inco me f'am-
tax basr and at t.rac ting p ri vate in vestm ent.
ili cs t o beco m e h o mebuye rs , can p ro t ec t co rn mu ni ti cs w lw rc housing prices contin ue lo ri se.
Car efu l co nsicl c ra ti on of bo th oppo r tun iti es and
c on cerns can help conver si on proj ec ts becom e part
of th e so lut ion to th e af for dability gap in com pet it ivc
Affordable housing advocates propose strategies
housing markets.
♦
A fforcl ab lc housing advocates, already aware o f th e
potential im pact or conversions on housing stoc k, recom-
Th is article' was w rit tC' n by Ana Cruz-Taurn , rC'g irnml com munity
clcVC' lopmC'n t cl irl'('l or in l hP A tlanta F'C'cl 's M iam i 13ra nch.
mend st ratrgics that would al low more rent al tenant s to
r teen
Digitized fou
for FRASER
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
VOLUME
15 ,
NUMBER
1
AftANfA
•
s;1V11NGt1AIVI
https://fraser.stlouisfed.org
Federal Reserve Bank of St. Louis
Synonymous with th e Deep South , crad le of the Civil
ru1d fot profit organiza tions for a two-clay conference on
0
Rights moveme nt , and home to 14 llisto ri cally Black
Faith and Commu nit y Based D eve l op ment. Nea rl y
Colleges and Un ivers ities (HBC Us), A labama's history
300 people from Alabama attended the even t, which took
and ide ntit y is travers ed by a com mon thread: the
place at the Montgo mery Civic Center in October 2004.
richness of its fa ith community across all ra cial and
economic- st rat.a.
Long be fore the Community Reinvestment. Act o f 1977,
The confer0nce feat m ed keynote remru·ks by Alabama's
governor, the I l onorabl e Bob Riley. Nationally known
speakers inclu ded Dr. Tony Evans o r Oak Cliff Bib le
commun it y deve lopment organizations 0xisted in the
Fellowsh ip Church, Dallas, Texas; Rev. Mark Whitlock II ,
state. Lending and in vestment progra ms have become
executive directo r of FAME Renaissance, Los Angeles,
familia r to banke rs, govern ment , int0rmecliaries, inves-
Californ ia; Robert Woodson, president an d founde r of
tors, benefactors, and other practitioners. But only in
the Nat ional C'ent0r for Neighborhood Enterprise, Wash-
re cen t years have churches seen op port uniti es to build
ington, DC; and Chery l Appline, national program dir-
affordab le housing that both se rves the needy and helps
ector f or I IUD's faith-based initiatives.
uplift enti re eonm1unities.
Empahs izin g "how-to" workshops, the conference
Wh il e t his movem ent has gained mo mentu m and
o ffered sessions for begi..Imers, those with modest exper-
impressiv0 fin ancial capacity, professional guidance has
ience, and those we ll-seasoned in com munit y develop-
been lacking. As the Fed's Regional C'ornrnw1ity Develop-
m ent work . On the second clay, A labama community
ment Director for Alabama, Michael Mi lner devoted signif-
deve lopmen t practi tioners from around the st.ate shared
icant attenti on i..!1 2004 to nwturing faiU1-ba5ed comrnwlity
success stories.
and economic development.
In Dece mber 2003, Milner organized an exp loratory
summ it at. th e Birmingham Branch ro r fa ith-based org-
Parti c ipant evaluations showed that. thi s event, wi th
its emphasis on hands-on guidance, tru ly made a difference. Strong support from high-profil e leaders de mon-
anizat.ions and finan cial institutions. The group met to
strated both comm itment and hope. A critical mass of
discuss the poten ti al role of faith-based organizations in
parlicipru1 ls facilitated significant networking, especially
stimulati ng econonlic devel opment acti vities in th ei..I· sur-
between bankers and church l eaders interested i n
rmmdin g commu nities.
fundin g so urces.
Partic ipru1ts agreed tJ1at commw1ity development activ-
In light o f th e eonJerence's success, the plrurning com-
iti es we re consiste nt with - and eve n vita l to- the
mittee is developing a follow-up event. Re lati ve ly f ew
mission of th eir organizations, particu larl y for th ose
faith-based organizations in AJaba.ma have experience in
chu rc hes in eco no mi cally d istressed commun iti es.
mru1aging community development nlinistries, so there's
Th e gro up recognized that many faith -based organiza-
great opportunity to provide additional trai ning.
tions were already i..Iwolvecl i..!1 daycare and basic literacy
An initiative like th is doesn't happen automatically:
programs. But to have a greater economi c impact on
It takes pe rsonal commi tment from employees like
their co mrnurlities, they saw the neecl for more afford-
Mike Mil ner to buil d th e bridges.
♦
able housing and decent jobs.
To help these organizations obtain the tools to engage
in effecti ve co mm unity development , M ilner gathered
20 l"mru1eial institutions, government agencies, nonprofits,
sixteen
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Federal Reserve Bank of St. Louis
VOLUME
15, NUMBER
1
Tlw Jacksonville Branch's Regional Community Devel-
\·olunH' of returns filed in 2004 rose by
->8 pNcent OH'r
opnlC'nt Manager, Janet Ilamer, was busy in 2004 working
the 200:l ta x seaso n, and returns qualifying for EITC'
with financial ed ucation initiatives, regional prosperity
were up by 176 percent.
campaigns in north and central Florida, and seve ral
statPwicle coal itions.
r:
O,w of llarner's prQjccts has been continuing to partner
ll anwr also spo nsorrd meetin gs oft wo regional
with the FDIC's Communjty Affairs staff, providing "train-
Bankers Ho undtab les. The Bay Arca Bankrrs Rouncl -
t hP-t rai ncr" one-clay workshops to vari ous commu nity
lablr (S(' Jv ing the Ta mpa Bay area) ancl 1hr Nor1hras t
groups in Florida. The workshops certified a tota l of
Florida Ba nkers Roundtable convene d quarterly last
l:l:l Money Smart teache rs in Tam pa Bay, Jacksonvi ll e,
year lo provid e local bankrrs with informa tion
011
M,matcc Coun ty, Lakeland, Orlando .mcl Daytona Beach.
community development opp01tuni tirs in their markets.
As a result of thjs training, ongoing Money Sman classes
The Roundtables also introduce \·arious commL111ity
arc now m·ailablc in all of these ,u-c,Ls.
partnC'J"s and resources to assist banks in tlwir com -
In add ition , she conti nues to se rve on the board of
munit y development efforts.
dirPctors of the Florida Jump$tart Coalition. Hamer is a
founding member of this statewici(' c-oalition, which pro-
Boosting community and economic
\·idcs teacher training and other financial education
oppo11unilies for children and you ng adults.
Fac-ilitat ing new statewide pa.tinerships of c-onummity
and cc·onomic development organizations is another goal
Promoting financial education
suppo11cd by I Jame r's work with the .Jae ksom·ille Bnmch ·s
a
Community Affairs program. Last year she organized
During 2004, ll anwr worked c·losely with prosperity
three quarterly meetings of the newly formed Florida
campa igns in No ri hcasl Florida (S(' rvin g th e Jackson-
Associat ion of Nonprofit Developers. F'ormal ion of I his
\illP metropolitan area) , llillsborough/ Pinellas Count y,
organization is a.ti impm1rn1l step for the mrn1y nonprofit
and Polk County, using the Money Sma11. curri cu lum to
cle\·clopns in Florida. The orga.ilization will provide tec-h -
cont inur provid ing financial educ-a t ion classes for low-
nkal m;sist ance to various housing nonprofits as well as
and moderate-in come in cli vicluals.
faci lital l' part ncrsl1ips of orgrn1i zations Io prod uce afford-
The I hrce areas have cxpericncrcl an increase in I he
numbN of eligibl e fami li es and indi vidua ls filing for
able housing units in Florida.
In acid it ion, I lrn11er stays involYed \.Vil h other statewide
thr Earned [ncomc Tax Credit ( EITC' ), a federal income
commun it y dpvelopmcnl organizat ions, inc-lucling the
tax credit refunded to eligible low-income working indi-
recentl y rormed Florida Association or Co mmunit y
viduals and fanliUcs who apply and qualify for the benefit.
DevclopnH'nt Corporal ions, the Florida Community
l 'sr of free income lax preparation senices increased at
Dc\·elopment Association , and the Florida Suppo11in'
neighborhood VITA (Volunteer Income Tax Assistance)
Housing Coalition.
♦
sit rs ,LS well.
The Jacksom·illc campaign saw a pm·ticularly sign ificant increase in the number of ta.,x rPt urns prrpared at
VITA sites. [n the Jacksomille mrt ropolitan area, t hr
FEDERAL RESERVE BANK OF ATLANTA
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Federal Reserve Bank of St. Louis
seventeen
The Mi ami Branch 's Regi on al Co mmunil y Developm en t Director, A na Cru z-Taura, pa1tnc rcd o n t wo
Research on immigrants and remittances
Th e Atlm1t a Fed 's Community Affairs progrm11 coll a-
major proj ects in 2004 to improve financial education
bo rated w ith th e Rescm-ch Depait ment oft he Federal
and sc1v ices lo low- and moderate-income a11d immi-
Reserve Board lo study the remittance market among
gran t pop ulations: the Greater Miam i Prosperity Camp-
immigrants in the Sixth Dist1ict.
aign and a researc h proje ct on immi grants' use of
remittance services.
Th e research shows that finan cial inst ii uti ons have
capt1.u-ed only a small percentage of Llw rem it lance market, which represented over $100 billion sent by immj-
Greater Miami Prosperity Campaign
Miam i 's di ve rse social and econo mi c iss ues pose
grai1ts back l o their home coL1J1tries in 2004. Eai·ly last
yeai·, th e Federal Reserve introduced its FcclACil lnt.er-
chal lenges for communjty devclopmcnl inil ialives. The
nation al"' Se rv i ces product wh i ch allows m ember
2000 Census revealed that Miam i is the poorest or Flor-
fi nanc ial inst it ut ions t o send f un ds al lower cos ts t o
ida's 100 lm·gest cities, with pove rty ral cs for children
Canada, Mex ico, and tJu·oughout the Transallanlic region.
and I he elderly ranking m110ng th e highest in the state.
The city's co mmuni ty developme nt challenges arc
Foc usin g on Mex ican immigrants, who send the
lai·gcsl numbers or remittances, the rescai·ch explored
not limilcd to depressed income leve ls, however. As a
how dec isions about remjttance services affect use of
"gateway" l o Ll1ousands of mjgran ts and immigrants each
eitJ1er majnstrcarn or alternative fin ancial service pro-
year, the city faces complex issues rclal cd to workforce
vid ers. Researchers conducted smveys and focus group
trainin g, cul tural diversity, affordable housing, trans-
meetings in Dalton, Ga., Miai1u, Fla., ai1cl Nashvill e, Tenn.
port ation, economic developmen t, m1cl education.
Recognizing the need for a co mprehensive approach
Comm unit y-based organizations in each marketThe Georgia Project, Everglades Com munit y Assoc ia-
to economi c we ll-being, the Human Serv ices Coaliti on
tion, and Concxj6n A me1ica.s-a.ssisted w itJ1 th e rcseaid1
(IISC), a social se rvice i nternwdiary serving M iam i-
by providing access to inilividua.ls and offerin g insight
Dacie Co unty, launched the Greate r M iami Prosperity
on th e finan c ial servi ces environment in th eir respec-
Campaign in 2002 to coo rd in ate o u treach to l ow-
tive commun ities.
inco me co mmunit i es.
Financial education, access to ma.inst reai11 fin ancial
The Prosperity Campai gn helps low-wage workers
servi ces, and consum er protec tion were cited as prior-
access econom ic benefi ts progran1s such as lhe Earned
i ties amo ng th e imm igr an t parti ci pants in the foc us
In co me Tax Credit (EITC) and Ch ildcare Tax Cred it.
groups. Research r es ults, w hi c h were presented at
Sin ce its inception, Cru z-Tau ra has worked w ith I-ISC
the 2005 Federal Reserve System Research Con feren ce
by providing research, reso urces, and best prac tices
in April , w ill be addressed l ater in the year at work-
i nrormal ion abo ut reaching min oril y and low-income
shops ai1d sym posiums throughout the Six th District to
com mun iti es through EITC outreac h, fin anc ial edu-
consider the implications for south eastern comm wuties
cati on, credit co unse l ing, and homeo wn ersh ip co un-
with !ugh imm igrant popu lations.
♦
seling progran1s.
In 2004, the camprugn was expanded beyond the City
of Mia.m i to include all of Mim11i-Dade County, bri nging
additional public and ptiva.te support for the progrm11.
eighteen
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VOLUME
15,
NUMBER
1
Regio nal Co mmunit y Deve lo p ment Ma nager Siby l
Sin ce i ts in cP plion in :2002, thl' progra m has he ld
II 01\·ell loggPd in many miles in :200-l t ran• li ng ac ross
-1 88 fin ancial C'ducation workshops se 1Ying "1,000 stu-
(;eorgia to suppor1 !imrneial educa ti on prqjPcts, wPalth-
dents, 1,067 o f w hom wen• low- ancl moclerat(•-in come.
building initiati ves, and slate alliances. Slw lllade nearly
A to tal o f GG7 bank accoun ts w ere opened as a rl'sult
100 tec hniC'a l assistance and ou t rPaeh ca ll s l o co nsu lt
or t ht' workshops.
with co mmunit y devC'lopment pa rtn ershi ps, rin anc- ial
T hl' De Kalb F'irst Accou nts initiati ve was cit<'d in testi -
institutions, and nonpro fit organi zations. T he Mayors
mony before tl H' S(•nale Banking and Fi nanc(' Committ ee
Forum, First Acco unt s, and Geo rgia Projt'ct are typi cal
as a unique Wl'alt h-builcling coll abo rat i1·e that in l"(J ll't'd
or th e programs th at I l owell fostt'rs.
ba n kin g r egul at o ry agenc it's, the
ms, th e (·oopt'rati vc'
ex tt'nsion sP 1YicP, local govt' rnm t' nt , fin anc ial institu-
Mayors Forum addresses
tions, an cl ot lwr comnnmit y pai1Iwrs.
The en tin' state of Georgia, much like At l,mta, is t'X pt'ri ('ncing rapid populat io n growth th at has out pact'd tlw
p
Many ai·eas t hrnughout the count ry-both urban and
produ c t ion o r suffi c ient affo rdab le hous in g, pa rt ic-
r ura l- have t'XpC' ri encecl de mograp hi c sh irt s clu t' to
u larly in ar eas com ·t'n it' nl to jobs. Tlw l\ l ayors Foru m
growing llispanic .mcl immigrant popu lations. Tlw rmal
engaged mayo rs from across t he state in di sc uss ion
co nrn1unity of Dalton , Georgia has rt'spondecl lo t his
about th ese issues and fac il itatt'd collabo r ati o n about
cha.ng(' with an inno1·ati1'(' prograin Io m('et t ht' ll('('cis o f
possible so lutions.
its cli n•rse popu lati on.
llostt'd by tl1t' Fed t'ral Rese1V(' Bank of Atl ant a in con -
T lw Georgia Prqjl'ct, a nonpro!it o rganiza tio 11 formecl
junc-tion wi th Atlan ta Nt'ighborhood Developn1ent Pai11w r-
in response to a significan t incr ea.-;e in Spai1ish-speaking
ship, Inc-. (ANDP) ai1d the Georgia Municipal A'isociati on ,
stucl t'n ts in Dalt on schoo ls and throughout nort Invest
llw fo rum present ed "Making Tlw Case ror Mixed l nco n1t'
Georgia, assists w ith tlw acaclemi c and social ll l'('dS o r
and Mixed l 1st' Communities: A n Execut in' Summary"
La ti no st uclt'nt s. Workin g i n co ll abo r ati on wi th the
by Da\icl Goldber g of SmartGrowthArneric-a. Commis-
Cni1·ersity of Mont errey in Mexico, the projt'c t prmicles
sioned by AN D P's Mixed ln comt' Commun it it's Initial ivt'
prof('ssiona l cl<•ve lopment for bilingual teac hers ancl
( 1IC l), I he rPport exami nes t lw gro11·ing challenge Io
scho larships ror bilingua l high schoo l gracluatl's w ho
housing affordabilit y and qualit y o r life in nI PI ro A t Ian ta.
pla11 to matriculat(' at Dalton State Coll('ge as l<'ad1t'rs.
To suppoI1 I lwir effo11s, tlw Atlai1ta Feel pa.11m·n•cl with
DeKalb County program expands
tlw F('cit'ra l DC'pos it In surance Co rporati o n to hos t a
Money Smart "trai n-th e-I rai1wr" wo rkshop in Spani sh ror
Furt heri ng an i mpo rt ant goa l o r th e Six th Distric t's
Geo rgia Proj('CI teach ers and other Da lton empl oyees.
Community A ffairs program- imp rovi ng acc ess t o
Parti cipant s W('r<' certi!i ecl to teach th t' Money Smart
bai1king- l lowell has bet'n an integral part o r th e De Kalb
ct11ri cu lw11 to Latino families in Dalton-Whitfielcl County.
First Accounts Program , which connec ts unbank ed
Tlw t'1·ent was sponsored by AmSou th Bank ,me! Dalton-
low- and moderatt'-income incliviclu als thr oughout
Whi t field Count y Government.
♦
nwtro At lanta and South De Kalb County l o traditiona l
fin anc ial inst itutions.
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nineteen
Supporting U1e Sixt11 Distri ct 's Conrnmnity N Tairs pro-
program has trai ned 165 parti cipants r eprese ntin g
gram in m eeting its goals, Region al Comm unity Devel-
60 organ izati ons throughout M ississ ippi and some
opment Manage r Nancy Mo ntoya at th e New Orl eans
nei ghborin g markets in Lou isiana.
Branch assumed a k ey co llaborative ro le on several
projects in 2004 th at i ncrease th e capacity and efficiency of comm unjty a.net economic development (CED)
Jump$tart coalitions in Louisiana and Mississippi
Montoya continued to work with Louisiana. and M is-
sta.ke ho l ders. T hro ugh h er work w ith a variety of
sissippi Jump$tart coali tions to im prove the persona.I
organizati ons, Mo ntoya helped devel op substanti ve
financial li teracy o f yOLmg adults. Last year , the M iss is-
training a.net networking oppo rtun ities for local CED
si ppi Sec r et ary o f St ate 's O ffi ce an d M i ssissipp i
partners, i nclud ing bankers and nonprofi ts.
Jum p$ta.rt sp onsored "Money Matters" seminars that
reached over 2,000 students and 100 teachers.
CED training for bankers
In response to bankers' conti nulng demand for com-
Louisiana. Jump$ta.rt, in partnership with the LSU
AgCenter, comp leted t wo years of "train-th e-teac her "
m Lmity development finance trai ning programs created
workshops to prepare free enterpri se teachers to m eet
by Community Nfa.irs, Montoya worked with the Bir-
new curric ul ar re qu i remen t s th at in c lud e pe rso nal
mingha.m Branch to provide t ra.in.ing for 20 ban kers in
finance lnstruction. By th e encl o f th e year, 407 teachers
the Gulf Coast area of Alabama and Mississippi.
from 191 schools ha.cl attendee! th e training. They w i ll
She al so cond ucted a tra ining sessi on for 55 non-
reach 35,000 students throughout 6 1 Loujsiana. pa.ii shes.
profit or ganization s, deve lo pers, rea l esta.tP a.ge n ts ,
and bankers as part of M iss iss i ppi H orne Co rporaI.i on's Annual llousing Conference.
Roundtables for New Orleans area bankers
Th e New Orlea ns branch host ed fo ur Interage ncy
Quarterly Banke1s Roun clta.b les during 2004 to disperse
Post-purchase homebuyer education curriculum
Several orga.i1izations co llaborated to lmmch "llome-
information on community development topics.
Th e 2004 forums in c luded presen tations on I-Jom e
wis e," a compreh ensive post-purch ase home bu yer
Mortgage Disclosur e Act (HMDA) reporting cha.i1ges, a
education curric ul um that alerts new homeow n er s
co mm unity deve lop men t indu stry outl ook, and infor-
ab ou t task s an d expenses th at co me with ow ning a
mati on about banking and fina.i1cial services for women.
home-both predictable a.i1d Lmexpected.
\,\Then th e new progra.111 was wweiled to housing cow1se Io rs at Mississ ippi Home Corporation 's ( M I-I C's)
Wealth-building conference
A widely r ecogn ized speaker on wealth-building stra-
Annual Housing Conference in January 2004, Montoya
tegies, Montoya parti cipated sign i fi cantly in a maj or
presented inJom1a.t:ion on pr edatory leniling a.ncl related
conference on lndividual devel opment accmmts (lDAs)
consumer concerns.
sponsored by CFED in New Orlea.i1s. She served on th e
Working togeth er on "I-Iome w ise" a.i·e MllC, th e Mis-
host committee as well as contri buted Lo an IDA fi eld
siss ippi Housing I nitiative (M ill), Con sumer Cr ed i t
strat egy pap er presented at th e conference. In add ition,
Counseling Service (CCCS) o f Greater New Orl pans,
she took pa.rt in a panel that disc ussed ca.pa.ciLy chal-
th e U.S. Department of Ho using a.net U rban Deve lop-
lenges faced by both financial institutions and nonp rofit
ment (HUD), and Fa.imie Mae. Since i ts in ception, th e
partne1s in deliverin g IDAs.
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♦
VOLUME
15,
NUMBER
1
200--1 marked a year of new pa.itnerships in Tennessee.
Work ing with traditi onal and non-tradi tional partners,
Jessi ca Le Veen Farr at the Nashv ill e Bra nc h formed
promote free tax assistance and inform eligi ble taxpayers about the Ea.i-ned Income Ta,\'. Credit (EITC).
Th e NWBA foresees a comprehe nsi\·e wealth -build-
local, regional, and statewide coalitions lo acl va.i1ce a.fforcl-
ing initiati ve th at builds on free tax assista nce an d
ab le housing, wealth-building, an d related community
extends to include credit counseling, financ ial plan-
development init iatives.
ning, ind iv idu al deve lop ment acco unt s, and homeowner ship counse ling.
s· g
i ·o
.a
Some of NWBA's lead partners in addit io n to the
A statewide conference in Aptil 2004 organ ized by th e
Feel arc Co ngr ess man Ji m Cooper , U ni ted Way of
Tenn essee Ilousing Development Agency (THDA) se t
M etrop olit an Nashvill e, St. Th omas Il ealt h Services,
the stage for boosting the capacity of th e stat e's nonpro-
Community Impac t, and the Metropolitan De\·elopment
fit housing organizations. Th e event not only provided
Housing Agency.
traini ng but also an opportunity for nonp rofit s to network with their peers from across th e state.
Conference parti cipants created a LI STSERV ' to facilitate regu la.i- communj cation a.i11ong nonpro[its, fu nders,
Middle Tennessee Hispanic
Cn
Tennessee has been home to one of th e past decade's
a.i1cl other resource providers. They also fo rmed a com-
fastest growing Ilispa.i1k popul ations i..11 th e country, and
mittee to exp lore th e deve lopment of a sta tewid e non-
many of the new imrnigra.i1ts a.i·e settlmg in the Middl e
profit housing association.
Tennessee region. The Middle Tenn essee Hispan ic Con-
Community Housing Developers Associati on of Ten-
smtiurn connects commw1j ty-basecl orga.iuzations, banks,
nessee (CIIDAT) will offer traitung a.i1cl networking oppor-
real estate agents, and governmental agencies that pro-
twuties. It will also create a unillecl voice for nonprofi ts
mote access to fina.i1cial servi ces and homeownersh ip
in housing and commwuty development.
for the flispa.i1ic commuruty.
CHDAT's m ission is to build better co m muniti es in
Form ed aft.er a statewide confer en ce in Ap ril 2003,
Tennessee by stren gthenin g its m embe rs' capac i ty
"New Neighbors- Opening Your Doors to the llispa.i1 ic
to deve lop an d pro vide access to sa f e, good qual it y,
Communit y," th e conso rtium has continued meetin g to
affordable hous in g.
discuss new programs for th e Hispani c com munity. Th e
group is focusing on promoting "ITIN" mortgages that
use individual taxpayer identification numbers for undoc-
Over 100 pa.itners representing business, commun ity,
umented im migra.i1ts as well as increasing the number
government , and faith-based organ izatio ns j oined last
of Hispanic homeowners a.i1cl improving Hispani c access
year to form the Nashvi ll e Wealth-Bu ild ing Allian ce
to fmancial services.
(NWBA). Th e NWBA links pmtner orga.iuzati ons that pro-
A Money Smart "train-the-trainer" workshop in Spa.i1-
vide services to help Nash\ill e res idents ac hi eve se lf-
ish for Georgia Proj ect teachers a.i1cl other Dallon employ-
sustaitung fina.ii cial independence.
ees certified partic ipants lo teach th e Money Smart
Focusing i.Jutia!Jy on the "Earn It, Keep It, Save It " ca.in-
cw·1i culum to Latino fa.irulies i.Jl Dalton-Wrutlield County.
paign, the NWBA will work through commu nity orga.i1i-
Th e event was sponsored by AmSouth Ba.i1k and Dalton-
zatio ns, social se rv i ce pro vide rs , and emp loyers to
Whitfi eld Co unty Govern ment.
FEDERAL
RESERVE
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Federal Reserve Bank of St. Louis
BANK
OF
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♦
twenty - one
FEDERAL RESERVE
B ANK
O F ATLANTA
COMMUN I TY AFFA IR S DEPA R TMENT
1000 PEACHTREE
STREET , N . E .
ATLANTA , GEORGIA 30309 - 4470
CHAN G E SER VICE R E QUES TED
STAFF
VICE PRESIDENT
Sl <'V<' Fo i<'Y
COMMUNITY AFFAIRS OFFICER
.Juan ('_ San ('h<'z
COMMUNITY AFFAIRS DIRECTOR
Wayn<' Smith
EDITOR
.knnir<'r Cri<'r
PRODUCTION MANAGER
llarri <'II<' (:rissom
STAFF WRITERS
Ana ( 'n 1z-Taura
.Jessica Ll'V<'<' n Fa rr
.Ja1wt I la nH'r
Sibyl I low<'II
lik<' i\ liln<'r
Nancy i\ l o nl oya
CONTRIBUTING WRITERS
.Joe Cassa r
i\loniqu<' l~inho rn
Ri chard Frah pr
Scott (:. Wy 1w
DESIGNERS
l'etn l lan1ilt on
Odi<' Swa npgan
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copi<'s ar<' an1ilable upon 1w 1u<'st
by mail al tlw Co mmuni ty AHairs
Depart lll('llt adclrPss abo\'e , o r
('-mai l us at l'a/'/J1('1·s(aa //..fi'/J .O l:<J,
o r ca ll ,J(),J/,108-7287; FAX
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C'XJll'<'ssed ar<' not necessa rily
t hos<' o r th <' Fcdt'ral Resen·c
Bank or A t Jania or the Federal
H<'S<'IY<' SystPm. i\laterial may b<'
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