Dear Chairman Tanoue, Director Seidman, Comptroller Hawke and Chairman Greenspan:

Dear Chairman Greenspan, Comptroller Hawke, Director Seidman, Chairperson Tanoue, Chairman Pitofsky and Secretary Summers:

Today's Wall Street Journal described Bank of America's leadership effort to move the unbanked into banking and to minimize the pitfalls of the present ChexSystems, a system that has, in effect, prevented five million or more former bank customers from joining the banking system. (article attached)

We strongly applaud Bank of America's clear leadership. They have set a standard that no regulator could possibly set even if it had clear jurisdiction. Greenlining and other community members are also gratified to learn at our meeting of September 28th¹ (co-hosted with the Federal Reserve) that the nation's largest thrift, Washington Mutual, and California's second largest bank, Wells Fargo², intend to follow Bank of America's lead. Similarly, a number of the other nine banks that attended this meeting, such as U.S. Bancorp, Bank of the West and Sanwa, indicated that they were likely to soon do the same.

As OTS and the Federal Reserve remarked at our meeting, this was an excellent example of the effectiveness of financial institutions, regulators and community groups working together, even when there is no clear regulatory framework, to achieve a common goal that makes good business sense. We strongly concur and welcome the opportunity to replicate this informal procedure as it relates to community reinvestment, predatory lending and other issues of common concern.

Our next scheduled meeting, which will be co-hosted by the Federal Reserve, is set for December 5th. Subsequent to that meeting and prior to the end of the year, we hope to provide a joint report to all of you on the initial results of this joint effort to modify the counterproductive aspects of ChexSystems.

Third, do these bans have an unintended discriminatory impact on the poor, inner city residents and minorities, as the NAACP contends?1

Fourth, do these bans unintentionally help create a strong multi-billion dollar predatory "check cashing store" economy since these bans directly drive millions of poor Americans from regulated banks to some of the leading predatory lenders?

Five, are second chance and other flexible methods, such as developed by Union Bank, an effective alternative that, in effect, causes the automatic ban to be unnecessarily discriminatory and counterproductive to safe and sound banking practices?

Six, if, as we believe, there is a clear distinction between fraudulent check writers and destitute families whose loss of a job prevents them from covering a check, should banks develop an alternative to ChexSystems, a national database to which 80% of bank branches subscribe? Suggested Action

We urge that the four primary federal bank regulators call for an immediate Six Month Moratorium on automatic bans. In the interim, we urge that an investigation be conducted as to the impact of ChexSystems on a.) the banking system, b.) low-income, minority and inner city residents, c.) the government's electronic banking efforts; and d.) driving the poor out of the regulated banking system and into the hands of predatory lenders.

Leaders of The National Black Chamber of Commerce will be having their national convention in D.C. from August 17th to 20th. Perhaps we could meet during this time?

In addition, Greenlining and its members (including The National Black Chamber of Commerce, California Hispanic Chamber of Commerce and The National Asian Business Association) will seek to set up a meeting on August 14th in San Francisco with ten major banks² to discuss interim solutions to this banking crisis. We respectfully request your assistance in ensuring that your top officials attend this meeting.³

We look forward to your early advice and action.