The Federal Reserve Bank of San Francisco, the Federal Reserve Bank of New York, and the NYSBD
executed a Written Agreement with Mitsubishi UFJ Financial Group Inc., Tokyo, Japan; its subsidiary bank, The Bank of Tokyo-Mitsubishi UFJ Ltd., Tokyo, Japan; and the bank's branch in New York, New York.
Citigroup proposed the Initiatives to the OCC, FDIC, and New York State Banking Department ("NYSBD
"), and adopted them in connection with its acquisition of Associates in November 2000.
The Board notes that the FDIC and the NYBSD have evaluated North Fork Bank's policies and procedures, and the Board has consulted with the FDIC and the NYSBD about the adequacy of these policies and procedures.
On October 11, 2001, the Federal Deposit Insurance Corporation ("FDIC") and the New York State Banking Department ("NYSBD") approved applications by North Fork Bank in connection with this transaction.
Some commenters also noted that the New York State Banking Department ("NYSBD") and Citigroup entered into a letter agreement executed on June 25, 2001 ("June 2001 Agreement"), that stated two affiliates of Associates submitted erroneous 1999 and 2000 HMDA data.
(59.) Commenters also asserted that Citigroup relied on home improvement loans with low principal amounts, resulting in Citigroup's alleged failure to meet lending projections made by Citicorp a July 1998 letter agreement with the NYSBD in connection with the merger of Travelers and Citicorp.
(24.) ICP also notes that the NYSBD
rated QCSB "low satisfactory" under the lending test and "needs to improve" under the investment test portion at its last examination ("State Examination"), as of June 30, 1998, which evaluated its performance in meeting the credit needs of its entire community pursuant to New York law.
As of June 1999, the NYSBD rated North Fork Bank's performance "outstanding" in helping to meet the credit needs of its entire community pursuant to New York law.(63) Because Fleet would not control North Fork as a result of this proposal, Fleet would not be able to influence the CRA policies of North Fork.
As of June 1999, the NYSBD rated North Fork Bank's performance "outstanding" in helping to meet the credit needs of its entire community pursuant to New York law ("State Examination").(23) Dime Savings also received an overall rating of "outstanding" from its primary federal supervisor, the Office of Thrift Supervision, at its most recent evaluation for CRA performance, as of November 1999.
The Board also has considered the quarterly reports concerning the lending activity of North Fork Bank during 1998 and the first quarter of 1999 that were submitted by North Fork to the Federal Reserve Bank of New York as required in the New York Bancorp Order, and confidential information provided by the FDIC and the NYSBD concerning North Fork Bank's lending activities.
(13.) In the New York Bancorp Order, the Board stated that it expected North Fork to address the lending areas criticized by the NYSBD in the State Examination, and that the Board would consider North Fork's progress in this regard when considering future applications by North Fork.
The 1998 NYSBD
examination of Citibank NYS concluded that the geographic distribution of the bank's loans reflected good penetration throughout its assessment area and among customers of different income levels.