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Demand Change from Bank of America Comment Period Extended til 5/23/09

By       Message Stella Adams     Permalink
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Keep those comments coming the Federal Reserve has extended the deadline until 5/23/09 !!! Click here: FR Doc E9-9181

Here is a sample letter please feel free to include your specific issues of concern BOFA and their products or services please include your mailing address so that you can receive a response from the FED.  please copy and paste and Fax or email TODAY!!!   ACT NOW!!!!

Fax: (804)697-4021
EMAIL COMMENTS TO  regs.comments@federalreserve.gov  Adam M. Drimer
Assistant Vice President
Federal Reserve Bank of Richmond
P. 0. Box 27622
Richmond, VA 23261
RE:   Bank of America Corporation, Charlotte, North Carolina, and NB
Holdings Corporation, Charlotte, North Carolina; to acquire 100 percent
of the voting shares and thereby indirectly acquire Bank of America
North Carolina, National Association, Charlotte, North Carolina (in
organization).
Dear Mr. Drimer,
This letter is to comment on the proposed reorganization of Bank of America and to request an extension of time so that we can understand the purpose of this reorganization.  I represent (INSERT NAME OF ORGANIZATION AND DESCRIPTION HERE)

As Bank of America seeks internal reorganization it is out hope that this will facilitate better relationships with it customers and the communities and neighborhoods impacted by its decisions. I have a number of concerns related to Bank of America's business practices that we feel should be addressed before this reorganization is approved.   Bank of America fared poorly on the recent stress test.  We feel this will result in unnecessary and unwarranted reduction of credit to small businesses across the country and will contribute to increased unemployment throughout the country, leading to increased foreclosures. 

Bank of America has cut off lines of credit to small business owners who have not defaulted on their payments who have excellent credit but serve tough markets.  We have seen a number of small locally based homebuilders who could benefit from the ARRA but who need that line of credit to pay employees until the contracts are signed and payment for the work comes in. 

I are concerned that this "reorganization" does not address the performance of Bank of America, Countrywide, First Franklin, Home Service Loans and Wilshire as it related to home retention and loan modifications.  There are clear inefficiencies and we believe intentional efforts to stall home retention efforts for borrowers who are trying to avoid foreclosure.  It takes 10-30 days to get information that has been faxed to these divisions of BOFA into the system.  This delays the ability of housing counselors to keep delinquencies and retention costs manageable for their clients and to ensure that a SUSTAINABLE workout option is available. 
I want to know how this "reorganization" will address the following questions:

How will this restructuring of Bank of America ensure fair and equitable capital flows to low-to-mod and communities of color?

How will this restructuring of Bank of America address sustainable homeownership for low-to-mod and communities of color?

How can we ensure that Bank of America develops models for pricing, securitizations, and regulatory/economic capital that considers on the front-end the impact on low-to-mod and communities of color and that efforts are recorded to show they mitigated any disproportionate impact on these communities?

Thank you for your consideration of this comment.

 

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Stella Adams is the founder and CEO of S J Adams Consulting which performs research and policy development in the areas of fair housing, and fair lending. Ms. Adams served on the Federal Reserve Board Consumer Advisory Council (1/05-12/07), which (more...)
 

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Demand Change from Bank of America Comment Period Extended til 5/23/09