Exhibit B to Bill No Wells Fargo Bank, N.A Fair Lending Plan As Required by City Ordinance No June, 2011

Transcription

1 Exhibit B t Bill N Wells Farg Bank, N.A Fair Lending Plan As Required by City Ordinance N June, 2011 Wells Farg is pleased t respnd t the Annual Lending Study cmmissined by the City f Philadelphia examining the Lending Practices f Depsitry Banks. Backgrund: Bill N states that "the prpsed recipient submits a fair lending plan that respnds t the latest annual lending disparity study r studies cmmissined by the City relating t the perfrmance f the prpsed recipient and the perfrmance f any ther bank r ther institutin that the prpsed recipient has acquired and such plan is attached as an exhibit t the rdinance apprving the cntract". CORPORATE VALUES & VISION STATEMENT Cmmunity Develpment: Wells Farg s cmmitment t cmmunity develpment has cnsistently earned the Bank an Outstanding rating frm the Office f the Cmptrller f the Currency (OCC) wh mnitrs and evaluates the Bank s cmpliance with the Cmmunity Reinvestment Act. At Wells Farg, we want t satisfy all f ur custmers needs and help them succeed financially. We ll prmte the ecnmic advancement f everyne in ur cmmunities including thse nt yet ecnmically self-sufficient, wh have yet t share fully in the prsperity f ur extrardinary cuntry. We expect ur team members t be cmmunity leaders. Wells Farg cntinues t prvide access t lending and investment prducts thrugh: Strng relatinships t ensure impactful cmmunity develpment perfrmance Tailred investments with flexible ptins Imprved access t capital in lw-mderate incme cmmunities LENDING RESULTS HOME PURCHASE Per the 2009 Ecnsult Lending Study Wells Farg received the highest hme purchase lending cmpsite scre amng all f the ranked depsitries, exceeding the next highest ranked lender by nearly nine pints, indicating significantly better perfrmance than thse lenders and lenders in the city as a whle. Wells Farg was by far the largest mrtgage lender in the city f Philadelphia in 2009 riginating 3,665 prime lans and was respnsible fr 46% f all prime lans made by city depsitries, 42% f prime hme purchase lans and 49% f prime refinance lans. Overall, the study shws we riginated were mre than twice as many lans in the city as the next largest lender. The number f lan applicatins increased by 55.6% and denials decreased by 18.8% in 2009.

2 All Lan Originatin Units ,000 4,000 6,000 WELLS FARGO BANK OF AMERICA CHASE CITIGROUP CITIZENS FINANCIAL GMAC PNC POLICE AND FIRE FEDERAL CU SOVEREIGN BANK TD BANK, N.A. TRIDENT MORTGAGE COMPANY Prime 1-4 Family Other Hme Lans Frm , Wells Farg/Wachvia s riginatins rebunded significantly frm lending declines experienced by Wachvia in ,800 Wachvia Philadelphia Cunty Originatin Units 1,600 1,400 1,200 1, Orig Units 2009 Orig Units 2009 Includes WFC January February March April May June July August September Octber Nvember December Cmpared with 2008, Wells Farg psted a substantial 141% gain in prime hme lending in the city f Philadelphia in 2009, with grwth cncentrated in the hme purchase segment, far utpacing lending grwth at ther city depsitries. Wells Farg s prime hme purchase lending grew by 169% and Wells Farg s ur prime refinance units grew by 105%. Wells Farg prime hme lending t African American and Hispanic brrwers in the city increased, while city depsitries as a grup saw lending t these grups decline. All Prime, Single Family Lans, Philadelphia Prime Lans Originated Lans t African Americans Lans t Hispanics 2009 Wells Farg 2008 Wachvia Wells Farg YOY % Increase 2009 Ttal Other Depsitries 2008 Ttal Other Depsitries Other Depsitries YOY % Increase % % % % % % Lans t Asians % % Lans Minrity % % Tracts

3 Lans LMI Brrwers Lans LMI Tracts % % % % Wells Farg met r exceeded City benchmark percentage f lans t Hispanics, Asian and female brrwers. In 2008, Wells Farg/Wachvia ranked last in percentage f prime lans t female brrwers. While Wells Farg did nt meet r exceed City averages in percent f lans t African American, minrity tract, LMI brrwer and LMI tract brrwers; hwever, penetratin rates fr lending t African Americans, LMI brrwers and minrity tracts increased significantly frm Penetratin rates were lwer than ther City Depsitries as a whle. Hme Purchase Lans, Philadelphia Lans t African Americans 2009 Wells Farg Penetratin % 2008 Wachvia Penetratin % 2009 All Depsitries Penetratin % 2008 All Depsitries Penetratin % Lans t Hispanics Lans Minrity Tracts Lans LMI Brrwers Lans LMI Tracts Achieving higher penetratin rates is very difficult given Wells Farg s significantly higher lan vlume. Nnetheless, we cntinue t partner with ur cmmunity-based nnprfit partners, husing cunseling partners and minrity realtr grups t increase fair and respnsible lending pprtunities fr hmewners in the Philadelphia cmmunities. Fr 2009, Wells Farg s LMI neighbrhd lending gal was 2323 units. Wells Farg was able t reach 95% f the established target by making 2,206 hme lans in thse neighbrhds and mre than dubled lending there despite a 14% decline in mrtgage lending in Philadelphia. Denial disparity ratis fr Wells Farg were in-line with the ther depsitries and in mst cases were better than the ther depsitries as a whle. Denial Ratis All Prime African American Hispanic Asian Minrity Tract Wells Farg Wachvia All Depsitries All Depsitries Denial Ratis Hme Purchase African American Hispanic Asian Minrity Tract Wells Farg Wachvia All Depsitries All Depsitries

4 Denial Ratis Refinance African American Hispanic Asian Minrity Tract Wells Farg Wachvia All Depsitries All Depsitries Higher denial rates fr minrity brrwers reflect differences in credit and transactin risk. As authrs f the Ecnsult reprt themselves pints ut and the Federal Reserve has repeatedly emphasized, HMDA data alne cannt be used t shw racial discriminatin. Certain risk factrs, such as credit scres, the lan-t-value rati and type f prperty are nt included in the data. Fr Wells Farg, these factrs help explain ur lan apprval decisins. Wells Farg s cmmitment t fair and respnsible lending is reflected in the reprt s findings, which cite the cmpany as a natinal industry leader n anti-predatry issues. HOME REFINANCE In 2009, Wells Farg ranked 1st in the number f lans riginated amng all City Depsitries. Wells Farg issued 2,145 prime hme refinance lans in 2009 which was mre than twice the 1,045 refinance lans issued in Mrever, in 2009, Wells Farg met r exceeded all city benchmarks fr lending t African American, Hispanic and Asian brrwers. Frm 2008 t 2009, hme refinance lan applicatins (amng peer City depsitries) increased by 8.9% and lan riginatins increased by 51%. Wells Farg s applicatins increased 11% and lan riginatins in this categry were mre than duble thse in Our lan decisins are based n risk, including credit, lan-t-value and debt-t-incme. T the extent there are differences amng varius grups, they are due t differences in credit risk. Met r exceeded City benchmarks fr percentage f lans t African American, Hispanic and Asian brrwers. Ranked 8 th in percent f lans t LMI brrwers in Ranked 1 st in denial rati f Hispanic t white brrwers and met r exceeded City benchmarks fr the ther three denial categries. Hme Purchase and Refinance Strategy: Understand and act n effrts t stabilize Philadelphia s current husing situatin and build a strng cmmunity fr the future. T imprve access t financing fr lw-mderate incme hmebuyers, Wells Farg will execute the fllwing strategy. Wrk with HUD apprved nn-prfit Hmebuyer cunseling agencies and cnduct First-Time Hmebuyer wrkshps. Hst and participate in First-Time Hmebuyer Fairs and prvide technical assistance t LMI participants n the mrtgage prcess and prducts. Financial Literacy

5 , Our Hands n Banking nline prgram prvides the basics in mney management. This infrmatin is als available in Spanish. Wells Farg is als wrking with lcal schl districts t make the prgram part f their curriculum. Wells Farg will hst financial literacy sessins in lcal bank branches t advance financial literacy in the cmmunity and will prvide the materials and resurces fr the event, templates, and resurces fr prmting the events thrugh cmmunity frums, lcal newspapers and nt-fr prfits. Wells Farg will make its Steps t Success Training Meeting-in-a-Bx and webinar prgram available t Philadelphia husing agencies and nt-fr-prfits. Steps T Success is a prgram designed t help new hmewners, r hmewners with past difficulties, achieve and sustain successful hmewnership, thrugh educatin, tls and resurces Spnsr cnferences and Partner with Minrity Realtr Grups; Natinal Assciatin f Real Estate Brkers (NAREB), Natinal Assciatin f Hispanic Real Estate Prfessinals (NAHREP) and Asian Real Estate Assciatin f America (AREAA). Wrk with Realtrs wh serve lw and mderate-incme cmmunities - CineMeeting simulcasts are held fr real estate and mrtgage prfessinals fcused n serving the needs f first-time hmebuyers, lw and mderate-incme and diverse custmers. Wells Farg is cmmitted t reaching ut t LMI brrwers utilizing Wells Farg s suite f mrtgage prducts that include lw dwn payments with cmpetitive interest rates. Prvide Hme Mrtgage Cnsultants with n-ging training/develpment t ensure expertise in CRA prducts By supprting ur Nn-Prfit Husing Partners, Wells Farg will cntinue t prvide financial and vlunteer supprt t activities in Philadelphia that supprt the vitality f neighbrhds, with a special emphasis n neighbrhd nn-prfit develpers. The Wells Farg Fundatin has cntributed $19 millin frm 2008 t present in Philadelphia, with $12.5 millin f that ttal dedicated t LMI cmmunities. The Wachvia Reginal Fundatin has als prvided an additinal $3.1 Millin in LMI cmmunities. Cntributins thrugh 2011 are anticipated t be $24 millin assuming cntinuatin f the ecnmic recvery. FORECLOSURE PREVENTION Wells Farg is implementing a strategy t minimize freclsures and partner with the City f Philadelphia and lcal nnprfit rganizatins t implement their $16.8 millin NSPI and $43.9 millin NSPII grants increasing the effrts t get vacant prperties ccupied again and strengthen neighbrhds in the City f Philadelphia, which is an imprtant cmmunity fr Wells Farg, its custmers, and team members. Wells Farg currently participates in the Philadelphia FIRST LOOK prgram and will wrk with the City Attrney, designated City fficials (City f Philadelphia Redevelpment Authrity, Office f Husing & Cmmunity Develpment), and nn prfit husing fficials t identify prperties Wells Farg wns r services fr anther wner in the City f Philadelphia

6 that may be available fr sale, dnatin, r discunt in neighbrhds identified as a lcal pririty. In markets hit hard by freclsures, we have accelerated ur mdificatin effrts by hsting large-scale Hme Preservatin Events. Fr Wells Farg Hme Mrtgage custmers wh attend, many receive mdificatins n the spt r within a shrt perid after the event. A Hme Preservatin Event tk place n September 11 & 12, 2010 at the Pennsylvania Cnventin Center: Mre than 14,000 Wells Farg & Wachvia custmers in the Philadelphia area were invited We had a ttal f 542 appintments during the tw day event. Wrkut results fr lans reviewed at the event as f 05/20/ % have received a final decisin 70% have been apprved fr sme kind f a wrkut ptin 90% f thse were mdificatins 30% were denied r cancelled by the brrwer A secnd Hme Preservatin event is tentatively scheduled t be held at the Philadelphia Cnventin Center Octber 5 & 6, 2011; Wells Farg is cmmitted t wrk with the City f Philadelphia t reach as many f its custmers as we can t prvide guidance fr staying in their hmes We have instituted a 1:1 custmer wnership mdel where ur brrwers are assigned a direct cntact (agent), wh will wrk with them n identifying what ptins are available t stay in their hme. It is a natinal mdel/best practice and is nw being implemented thrughut the industry. We cntinue t wrk with trusted 3rd parties in the cmmunity t wrk with ur custmers in mrtgage distress. This includes nn-prfit husing cunselrs, faith-based leaders including the NAACP, the Philadelphia Black Clergy and the Hispanic Clergy f Philadelphia, fficials frm the city's mediatin & diversin prgram, and elected fficials. Wells Farg wrks with the Urban Affairs Calitin (UAC) thrugh the Freclsure Preventin Task Frce t create the Freclsure Preventin Resurce Guide a hw t guide fr husing prfessinals, hmewners and thers wh are faced with ptential freclsure issues. The guide is free and it is available nline at r t receive a free hard cpy, freclsureguide@gpuac.rg Wells Farg has als wrked with the Natinal Urban League t c-spnsr a new editin f The Freclsure Wrkbk: The Cmplete Guide t Understanding Freclsure and Saving Yur Hme by authr Carla Duglin. The bk is available free-f-charge t hmewners acrss the natin wh are experiencing challenges making their mrtgage payments and wh may face ptential freclsure. HOME IMPROVEMENT LOANS In 2009, Wells Farg ranked 1 st in the number f lans riginated amng all City Depsitries. The Bank met r exceeded City averages fr lans t Hispanic, Asian minrity tract and LMI tract brrwers and was 1 st in percentage f lans t Hispanic brrwers fr the secnd year in a rw.

7 Frm 2008 t 2009, hme imprvement lan applicatins (amng peer City depsitries) decreased by 36% and lan riginatins decreased 38%. Wells Farg issued 101 Hme Imprvement Lans in 2009, mre than tw times the number f lans issued in While Wells Farg did nt meet r exceed the City averages fr any f the denial rati categries, ur lan decisins are always based n risk, including credit, lan-t-value and debt-t-incme. T the extent there are differences amng varius grups, they are due t differences in credit risk. Strategy: T recver, rebuild and sustain hmewnership, including ffering assistance and guidance t cmmunities t plan their use f available Husing Ecnmic Recvery Act dllars. Thrugh the Renew, Restre, Rebuild Prgram, Wells Farg prvides educatin, guidance and gvernment-backed renvatin lan prducts t include: Financing ptins fr purchase and renvatin f residential prperties using gvernment-backed FHA renvatin financing, FHA 203k Streamline renvatin lan and Standard FHA 203k renvatin lan. Our plan fr 2011 and beynd is t cntinue t lend respnsibly t all cnsumer grups, partner with nnprfits and City Gvernment t supprt city-wide lending initiatives and identify prducts that meet cmmunity needs. SMALL BUSINESS LENDING Wells Farg advanced frm 6 th place t 3 rd frm 2008 t 2009 ut f ten banks verall in small business lending. Wells Farg extended 719 small business lans in Philadelphia Cunty in 2009 with 389 (54%) in LMI census tracts. Strategy: T supprt small business develpment thrugh identificatin f capital and technical assistance resurces in rder t increase emplyment and expand small business pprtunities in the City f Philadelphia. Wells Farg Bank emplys apprximately 200 small business, business banking and retail banking specialists dedicated t prviding financial services t businesses in the City f Philadelphia. Many f these bankers are lcated in Wells Farg stres, the majrity f which are lcated in LMI neighbrhds and minrity areas. Wells Farg Small Business Lending includes: Credit amunts as lw as $5,000 n business lans Investments in Philadelphia Cmmunity Develpment Financial Institutins (CDFIs) Business credit cards and Lines f Credit Wells Farg has a cmprehensive suite f prducts t help businesses grw and manage cash flw. Wells Farg Advantage Business Service Package is a flexible, full-featured business banking accunt, designed t help minimize fees. A business can chse at least three f the fllwing accunts and services t cmplete yur package: Wells Farg Business Platinum Debit Card Wells Farg Business Online Free Business Bill Pay

8 Free Business Spending Reprt Any Business Savings Accunt Earn a bnus interest rate n a Business Market Rate Savings accunt Wells Farg Business Platinum Credit Cards (subject t credit apprval) Wells Farg Business Card Rewards Prgram - New custmers get DOUBLE pints fr the first 6 mnths and first year prgram fee waived Business Lans r Lines f Credit (subject t credit apprval) Wells Farg BusinessLine Line f Credit Wells Farg BusinessLan Term Lan Wells Farg Equipment Express Lan Wells Farg Business Real Estate Financing Wells Farg Express Equity Lan Wells Farg Express Refi Lan Wells Farg Small Business Advantage Line f Credit Wells Farg SBA Lans and Lines f Credit Other business lans and lines f credit Direct Pay thrugh Wells Farg Business Online Business Time Accunts (Certificates f Depsits r CDs) Wells Farg Merchant Services Wells Farg Business Payrll Services COMMUNITY PARTNERSHIPS SUPPORTING SMALL and MICRO BUSINESS Wells Farg prvided the fllwing grants and investments during fiscal year fiscal year 2011 applicatins have been submitted and are currently under review fr apprval. Greater Hispanic Chamber f Cmmerce Wells Farg prvided a $50,000 grant t supprt peratins and prgrams. The funding will prvide resurces t help individuals start new businesses and adpt best practices; facilitate access fr their members t lcal, reginal, natinal and internatinal pprtunities t grw their businesses. With the help f Wells Farg, the Chamber will cntribute t a healthy business envirnment and imprve the quality f life fr the Greater Philadelphia Hispanic cmmunity. During 2011, Wells Farg will hst several small business netwrking activities and seminars addressing small business financing and expansin.

9 Cperative Business Assistance Crpratin (CBAC) Wells Farg prvided CBAC with a $1.2 millin equity equivalent investment t supprt capital access fr small and micr lending in the Philadelphia business cmmunity. CBAC will prvide lans and technical assistance t small businesses lcated in lw and mderate-incme census tracts and minrity census tracts in Philadelphia neighbrhds. The intent is t increase the impact in distressed neighbrhds, create new emplyment pprtunities and increase access t capital and technical assistance. During 2011, Wells Farg will be wrking with CBAC t prvide small and micr lending seminars fcusing n business finance and technical assistance. African-American Chamber f Cmmerce The Chamber received a $50,000 grant t help the rganizatin expand their technical assistance prgram fr new and existing small businesses. Wells Farg wrks with the Chamber will prvide educatin, supprt, and marketing fr individuals in lwmderate incme cmmunities seeking t build and grw prfitable businesses. At Wells Farg, we believe strngly that the best way t revitalize lw t mderate incme cmmunities is t develp ecnmic slutins fr the residents. With tday's ecnmic cntractin hitting large cmpanies especially hard, mst financial experts believe that small business will lead the way frward fr ur ecnmy including mst jb grwth. As we grw business and persnal incme, we will help t transfrm cmmunities and lives. Wells Farg will hst several wrkshps and netwrking mixers thrughut the City f Philadelphia. Urban Affairs Calitin (UAC) UAC received a $100,000 grant that will be used t supprt a variety f small business and ecnmic develpment initiatives. Wells Farg cntinues t play an active rle n the rganizatins Small Business Lending Capacity building Cmmittee and the Bard f Directrs. Currently, the Small Business Lending Cmmittee is creating a multi-bank, multi-year supprt system fr Cmmunity Develpment Finance Institutins (CDFI s) t increase their lending capacity. Wells Farg will prvide lan capital, peratinal funds and technical assistance t selected CDFI s. Wells Farg will cntinue t prvide financial educatin seminars fr existing and new small business wners. Philadelphia Chinatwn Develpment Crpratin In 2010, PCDC cmpleted a fur year implementatin grant f $434,000 frm the Wells Farg Reginal Fundatin. The grant supprts cmmunity utreach, husing cunseling, cmmunity services prgrams and develpment f a Business Imprvement District. Als, the grant enabled PCDC t leverage additinal resurces that facilitated ecnmic develpment prjects and the hiring f a Main Street Manager t rganize lcal business wners. Wells Farg wrks with the Main Street Prgram t prvide technical assistance and access t capital fr small businesses in Chinatwn. NEIGHBORHOOD ANALYSIS The hme and business lending practices in nine City neighbrhds were examined. These neighbrhds cntain census tracts classified as minrity and lw-t-mderate-incme (LMI). All nine neighbrhds are lcated in areas where cmmunity develpment crpratins and empwerment znes have been established. Wells Farg made 114 lans within the nine neighbrhds, the mst lans f any city depsitry.

10 Wells Farg made 3% f all its City lans in thse nine areas. Its market share in the neighbrhds was 11.5%. Its market share in all f Philadelphia was 14.5%. The largest number f lans by Wells Farg was made in the OARC neighbrhd (62 lans), where Wells Farg had a market share f 10.7% BRANCH ANALYSIS Sixty-five percent f census tracts in the City are LMI tracts. Wells Farg surpassed the Citywide benchmark fr branches lcated in LMI areas. 66% f Wachvia s branches were lcated in LMI areas. Als, Wells Farg exceeded the Citywide 23% benchmark fr branches lcated in minrity areas.