The Board has reviewed the examination records of Applicants, Union Bank, Pacific Capital, and SBBT, including assessments of their management, risk-management systems, and operations.
The Board has considered all the facts of record, including reports of examination of the CRA performance records of Union Bank and SBBT, data reported by Union Bank and SBBT under the CRA and the Home Mortgage Disclosure Act ("HMDA"), (28) other information provided by Applicants, confidential supervisory information, and public comments received on the proposal.
SBBT received an overall "outstanding" rating at its most recent CRA performance evaluation by the OCC, as of September 11, 2007 ("SBBT Evaluation").
The Board has considered the records of Union Bank and SBBT in complying with fair lending and other consumer protection laws.
Convenience and Needs of the Communities Served by SBBT
Applicants represent that the proposal will benefit the convenience and needs of the communities currently served by SBBT in several ways.
2) After the transaction, Applicants plan to merge SBBT with and into UnionBanCal's only subsidiary depository institution, Union Bank N.
An unpaid RAL is not reported by SBBT as a delinquent account on national credit reports and does not negatively impact consumer credit scores.
As a nationally chartered bank, SBBT and its RAL lending business are regulated by the Office of the Comptroller of the Currency, an agency of the U.