June16,1998

Board of Governors Federal Reserve System NW 20551 201h and C Streets Washington, D.C.

Dear Boardmembers: On BankAmerica . Our for your behalf of the 9 counties I am writing and NationsBank. Association testifying recently convened a regional to us. hearing Our on the impact of the merger; but we have enclosed can be own concerns and 97 cities to submit that are members our comments of the Association merger of of

Bay Area Governments,

on the proposed

many of those review summarized Job Losses particularly Francisco notice

you are hearin g from on a separate basis, testimony submitted

any written

as follows: We are concerned concerned but throughout layofis, about the large number of jobs being eliminated, not just in San receive reasonable to job training and and

l

about the number the Bay Area. the new and that

that Lvill be eliminated, We ask that employees

ofany

bank make a commitment

placement. Community development various states, to provide concerned demand Area. Consumer availability consumers bank will /rometown Protection and ATM who will have $570 customers? -We are concerned dollars about branch closures, commttments by 1999, tvili to current we can only announcement maintain iee increases, customers. boasted that ATM Development “commitment” regions specific about - We are concerned that fails to provide to minorities oi BoirZ’ s rvith about the recent community specifics about distribution to “small populations. developers throughout business” fails We are in the Bay reference

l

and communities.

In addition, community

commitments the preservation

and low income non-profit housing

development

bank, and

that the new bank not compete

fees, and honoring feel the impact. biiiion in asse[s;

If the new the new to the

bank plans to save over a billion

suspect that it is the its connection

The merger horn

this giant

Federal June 16,

Reserve 1998

Page Two Fairness state. .Asian will to Minority (Our Association population no longer with will population to deal with reports will and Low Income Populations lending”_ It has been stated that and California in regional in 1990 is a a generic the the in 2020; is not We are to households, down minority with demographics:

l

NationsBank

has a reputation grow

for “generic from 16%

has forecast grow from at 47%.)

significant 14%

changes

of the population to 24%; We are concerned

to 20%

Hispanic prepared concerned minorities

by 2020,

the Caucasian that NationsBank

population

be a majority,

the diversity

in Caliiornia lending

and especially only 6.3% similar

the Bay Area.

that NationsBank populations, to minorities.

has a very poor record of lending to low income must performance The new bank

and low income percentages lending will standards

and even lower by the poor .and low income

nof be dragged

ejtablished

by NationsBank-

not pas5 muster oi 6oiA’ s North

in the 6ay Area.
San

We are concerned transfer milesOur Francisco; concerned of decisionmaking and light years

about the closure to Charlotte. away, we believe,

Francisco
is a

headquarters way from

and the Californiain

Carolina

long

in attitude. that global operations west to the Paciiic wll be based in San not be

concerns

are not relieved will

by word

such operations

be lookins

Rim and will

about jobs and customer we are concerned mergers free ATILl:,

relations

in the rest oi the Bay Area. oi competition banks, who in this merger,

IMore generally, as well to offer free checking, Before hearings, personally public and given NationsBank Mergers customers Sincerely,

about the reduction Vv’ fewer irh

as other proposed

in banking.

&vi// be compelled

and true customer

service? Reserve McCoII analysis convene and Mr. regional

any decisions including

are made, we ask that the Federal We ask that Mr. respond relevant every and personally until

one in the Bay Area. be extended reviebx,. ior public

Coulter

attend the hearings, period time for thorough be released

to questions.

We ask that the cases against

comment

has been made public

We also ask that current reviebv.

discrimination

don’ tend to iavor consumers, t are our constituents.

and don’ tend to favor small t

businesses.

BofA

and we \,oice our concerns

on their behali.

ABAC

President County

and Supervisor

Alameda