Service Members Deserve More Transparency From On-Base Banks, Credit Unions

New research from Pew on banks at military bases and how well information is disclosed to servicemembers.  As a reminder, you can also check out our report from earlier this summer that we conducted with our partners in North Carolina, New York, Illinois, and California: HOW BANKS SELL OVERDRAFT: RESULTS OF OVERDRAFT MYSTERY SHOPPING IN FOUR KEY STATES

Consumerist

(Hammerin Man) (Hammerin Man)

The Military Lending Act attempts to shield military personnel and their families from some predatory lending practices, but a new report from the Pew Charitable Trusts claims that some traditional banks on military bases are nickel-and-diming members of the armed forces with excess overdraft fees, and a general lack of transparency.

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Celebrate Sacramento 2014 a Success!

CRC Reinvestment Sacramento

Last week, California Reinvestment Coalition members and friends gathered to celebrate Sacramento Reinvestment.

A big “THANK YOU” to all of our Celebrate Sacramento sponsors, Honorary Host Committee Members, and guests, and a “CONGRATS” to our honorees, Cathy Creswell and Christine Thien.

Paulina Christine Clarence

Paulina Gonzalez, Christine Thien, and Clarence Williams

Christine was introduced by CRC Board Member Clarence Williams, and was honored for her extensive efforts with Building Healthy Communities South Sacramento.

Cathy Paulina Paul

Cathy Creswell, Paulina Gonzalez, and Paul Ainger

CRC Board Member Paul Ainger introduced Cathy, who was honored for her career-long commitment to affordable housing advocacy.

Paul, Paulina, Bill and Clarence

From left to right: Paul Ainger, CRC Board Member, Paulina Gonzalez, CRC Executive Director, Bill Powers, Founding Member of CRC, and Clarence Williams, CRC Board Member

To stay up to date on financial justice issues in California, especially as they relate to low income communities, and communities of color, you can follow the California Reinvestment Coalition on our Facebook page, via TwitterGoogle+, watch our movies on our YouTube Channelsign up to receive our newsletter and action alerts, and of course, visit our website.

California Reinvestment Coalition Asks Regulators “Is There Community Benefit in Too Big To Fail Merger of OneWest and CIT Group?

OneWest Bank MergerCapping a five-day awareness public awareness campaign, the California Reinvestment Coalition focused on the community benefits (or lack thereof) of a merger between OneWest Bank (former IndyMac) and CIT Group.

Both banks have already received considerable financial support and subsidy from taxpayers and bank regulators. Under the Bank Holding Company Act, regulators are required to consider the public benefit of a proposed bank merger.
CIT Group Merger

One way regulators can measure public benefit is through a bank’s Community Reinvestment Act (CRA) Plan,  a written commitment outlining how the bank will serve the community in the future.

Thus far, the draft plan offered by the leadership at CIT Group and OneWest appears to have been created without community input, commiting the bank to very little in the way of reinvesting in California communities.

CRC, and 37 other organizations have sent letters to bank regulators, opposing the merger in its current form.

According to Kevin Stein, associate director at the California Reinvestment Coalition, the community benefit is lacking from the proposed merger: “Right now, this merger doesn’t pass muster. Investors and the CEOs will benefit greatly, but what about California communities, especially those that were already harmed by OneWest through thousands of foreclosures and inadequate reinvestment? This merger will create the newest Too Big To Fail Bank, facilitate investor and bank officer windfalls, and provide for ongoing public subsidy. Yet the merger offers no public or community benefit. The regulators should reject this merger until a strong public benefit is guaranteed through a Community Reinvestment Plan to ensure communities don’t lose out again.”

CIT Group Merger with OneWest Bank

Roberto Barragan, president of Valley Economic Development Corporation, comments: “Here’s two banks that wouldn’t be alive without the support of taxpayers and bank regulators, and yet, they’re not willing to outline a strong plan of reinvesting in the communities where they do business? Until they are willing to come to the table with the community, this is a no-brainer for regulators. No public benefit means no merger approval.”

Regulators can also assess whether a bank is meeting the community’s credit needs by examining a bank’s history of reinvestment in the community. 

OneWest’s Community Reinvestment Record:

1) Bank Branches: 15% of OneWest’s branches are located in low and moderate-income census tracts, as compared to a statewide average of 30% of bank branches being located in LMI tracts.  Only two of the bank’s 73 branches are located in low-income tracts, according to research by the LA Local Development Corporation.

2) Small Business Lending: The majority of “small-business” loans originated by OneWest bank are to businesses with revenue of over $1 million, leaving smaller businesses behind.

3) Foreclosures: 35,000 Californians have lost their homes due to foreclosures by OneWest and its subsidiary, Financial Freedom.

4) CRA Grades: The Bank earned a “Low Satisfactory” on its last Performance Evaluation for its investments in the community

5) Contracting with MWDBE: The Bank hesitates in setting goals to hire businesses owned by Minorities, Women, and Disabled Persons (MWDBE).

6) Philanthropy: It appears OneWest’s historical charitable contributions are below the level of its peers.

7) Reinvesting Consumer Deposits: The Bank currently takes $14 billion in deposits via the Internet from throughout the country, but only reinvests these deposits back into its Salt Lake City assessment area, frustrating the purposes of the Community Reinvestment Act. It has no meaningful plans to reinvest Internet deposits back into communities where its Internet customers reside.

Additional Background on other Banks Creating Community Benefit and Reinvestment Plans as Part of Mergers
There is a precedent for banks committing to the communities they serve through the development of Community Benefit and Reinvestment Plan. Recent examples include:

1) Banc of California: After opposition from the California Reinvestment Coalition and 46 other organizations, in September 2014, leadership at Banc of California negotiated a five-year, public Community Benefit and Reinvestment Plan as part of its acquisition of 20 Banco Popular branches. Under the plan, Banc of California (which about one-tenth the size of the proposed CIT/OneWest merger) is devoting an amount equal to or greater than 20% of its annual deposits to community reinvestment activities.

2) Pacific Western Bank acquired CapitalSource, which was also opposed by the California Reinvestment Coalition, citing a record of “low satisfactory” CRA ratings and a lack of a public CRA plan. After an FDIC-facilitated meeting with CRC and the Greenlining Institute, PacWest Bank agreed to develop a CRA plan with input from the community.

3) Umpqua Bank applied to purchase Sterling Bank, but did not have a CRA plan. CRC opposed the merger, and the Federal Reserve later made its approval of the merger contingent on Umpqua developing a CRA plan.

To see the previous four issues highlighted in this week’s campaign:

Day 1: Bank Merger Would Benefit Investors, But What About Communities?

Day 2: Advocates Question If FDIC Loss-Share Agreements Should Continue As Part of Bank Merger

Day 3: Community Groups Question OneWest’s Foreclosure Record

Day 4: How Much Government Welfare Can One Bank Accept?

CRC’s detailed letter to the Federal Reserve Bank of New York includes an analysis of the merger and a long list of concerns and unanswered questions about the proposed merger.

How Much Corporate Welfare Have CIT Group and OneWest Bank Received?

corporate-welfare-piggy-bank

POSSIBLE BANK MERGER BREAKS NEW GROUND IN CORPORATE WELFARE

As part of a five-day public awareness campaign, Californians are asking bank regulators, including the FDIC, the Federal Reserve Bank of New York, the Federal Reserve, the Office of the Comptroller of the Currency, and the Consumer Financial Protection Bureau, questions about the possible negative impacts of a Too Big To Fail Bank merger that would combine CIT Group and OneWest Bank.

CIT Group Corporate WelfareThe questions on the fourth day focus on the subsidies both banks have already received from taxpayers in the form of TARP money and tax breaks the newly merged bank plans to use after the merger. These subsidies are in addition to the ongoing support OneWest investors are probably still receiving under the FDIC’s shared loss agreements.  In response, community groups are asking how much government welfare one bank can receive.

CIT Group unpaid TARP $2.3 billionDespite these government handouts, the bank plans big payouts to investors, executives, and shareholders, while only offering a meager community benefit and reinvestment plan as part of the merger, and zero plans to repay the $2.3 billion it received from taxpayers under TARP. Ironially, the LA Times reports that OneWest bank has paid out $2.3 billion in dividends as of June 30- the exact same amount of money that CIT Group never repaid to the US Government.

“Once again, we see there are two sets of rules for Wall Street and Main Street,” commented California Reinvestment Coalition Executive Director Paulina Gonzalez. “Bank CEOs and investors will potentially ‘earn’ millions from this merger, despite no clear community benefits from the merger, and despite the fact this merger dramatically increases risks for the US financial system. Americans who are working two or three jobs to keep their head above water will have a hard time understanding how bank regulators would approve a merger that includes a plan for exorbitant executive salaries and planned corporate tax breaks and no guarantees of a clear public benefit.”

Leadership of CIT Group and OneWest Bank refused to tell CRC members how much money they have received from the FDIC (via the Shared Loss agreement), so CRC submitted a FOIA request to the FDIC. Thus far, the FDIC has denied CRC’s FOIA fee waiver request, informing CRC that “The subject matter of your request is not now of interest to the general public.”

FOIA fee waiver denial for OneWest BankThis shocking response from the FDIC flies in the face of intense public interest in the recent This American Life/Propublica story about bank regulators coddling Goldman Sachs and the considerable interest generated by the recent AIG trial about the government bailout of AIG.

Kevin Stein, associate director at the California Reinvestment Coalition, comments: “CIT wants regulatory approval to buy OneWest, which will bring expected corporate profits, billions for investors, and millions for bank executives. It also wants: to not to have to pay back $2.3 billion in TARP money it received from the US Government; to take advantage of merger’s expected profits and use tax gimmicks to lower its IRS bill; to have the FDIC agree to cover certain future losses; and to not offer a meaningful plan to serve and reinvest in the community. Has a merger ever had so much public subsidy, so much private gain, and so little public and community benefit?”

Under the merger application, the CEO of the newly merged bank will receive a $4.5 million annual salary plus over $12 million in stock options, for a potential total of $26 million over the course of three years. Meanwhile, the chair of the merged institution may earn $4.5 million annually working for the bank, though his offer letter allows him to retain his other job of running a private equity fund at the same time.

CRC’s questions for regulators include:

1) Is there a contradiction between a bank arguing that its strong enough to become the first SIFI created, while at the same time holding out its hand for subsidies from the FDIC via the Shared Loss Agreement?

2) Are regulators concerned about the outsized compensation for bank executives under this merger, especially in light of the miserly goals the bank’s leadership has created in regards to community reinvestment activities?

Today is the fourth of five days of questions for regulators about this merger, to review previous questions for regulators, visit these links:

Day 1: Bank Merger Would Benefit Investors, But What About Communities?

Day 2: Advocates Question If FDIC Loss-Share Agreements Should Continue As Part of Bank Merger

Day 3: Community Groups Question OneWest’s Foreclosure Record

Tomorrow’s release will focus on Community Benefit and Reinvestment Plans and how CIT Group and OneWest can improve their current plan.

CRC’s detailed letter to the Federal Reserve Bank of New York includes an analysis of the merger and a long list of concerns and unanswered questions about the proposed merger.

OneWest Foreclosure Record Questioned By Advocates as Part of Too Big To Fail Bank Merger with CIT Group

OneWest Foreclosures

Photo credit: Walt Mancin/Pasadena Star-News, featured in BusinessWeek article: From IndyMac to OneWest: Steven Mnuchin’s Big Score

As part of a five-day awareness campaign about the potential impacts of a new, Too Big To Fail bank merger, The California Reinvestment Coalition  raised questions today about OneWest’s track record with distressed homeowners.  OneWest is the name given to the former IndyMac bank, which made toxic mortgages that eventually caused the bank’s collapse.

The FDIC granted the investors who bought IndyMac Bank  a Shared Loss Agreement as part of the purchase.  The Shared Loss agreement obligates OneWest to work with homeowners to avoid foreclosure where possible in exchange for the FDIC committing to cover losses on soured mortgages once certain thresholds were reached.

Now advocates are asking regulators to investigate whether OneWest bank complied with this stipulation of the loss share agreement.

Kevin Stein, associate director of CRC, suggests the regulators take a closer look at OneWest’s foreclosure record: “Thousands of seniors and other homeowners have been hurt by OneWest, and counselors throughout California have rated it as one of the worst servicers in the state. This merger is an opportunity for regulators to review the bank’s record, audit their practices, and ensure that additional homeowners weren’t harmed by practices inconsistent with their loss share commitments.”

Daniel Rodriguez, director of the community wealth department at East LA Community Corporation explains: “Regulators missed their opportunity to prevent banks like IndyMac from making predatory mortgages, and communities throughout Los Angeles were destabilized as a result. The regulators have an important opportunity with this merger to protect homeowners from further preventable foreclosures.”

On Day Three, CRC is asking regulators the following questions:

  1. Do the regulators believe the 35,000 foreclosures by OneWest Bank aligns with the bank’s obligations to modify mortgages whenever feasible as part of the FDIC loss-share agreement?
  2. Given OneWest’s checkered foreclosure history, will the FDIC commit to an outside audit of the bank’s loss mitigation practices before considering whether or not to let the benefits of the shared loss agreement transfer to CIT?
  3. Will the CFPB and OCC audit Financial Freedom, a subsidiary of OneWest Bank, which has been the target of numerous complaints for how it treats widows and other surviving spouses after the death of a loved one? Financial Freedom does not meaningfully allow for surviving spouses not listed on the loan to remain in the home. According to Realtytrac data, it has foreclosed on over 2,200 homeowners in California since OneWest Bank took over.
  4. Are regulators aware of the cases below and others filed, and will this impact the regulator’s possible approval of this merger?
  • Earlier this year a federal court unsealed a False Claims Act complaint against OWB alleging that OWB routinely violated the HAMP program and FHA loss mitigation rules. In United States ex rel Fisher vs. OneWest Bank FSB, the complaint also alleged that OWB “almost always” added new debt to the borrower’s loan balance.
  • In 2013, a San Luis Obispo couple received a million dollar plus settlement from OWB for foreclosing on them while they believed they were negotiating for a loan modification.
  • What other cases have been filed against OneWest and are the regulators considering these as part of their decision making process as to whether OneWest has been meeting community credit needs, and whether this merger will provide a public benefit?

The bank regulators who are reviewing this merger all urge distressed homeowners to work with housing counselors from HUD-certified agencies. These same counselors suggest that OneWest Bank has been incredibly difficult, if not impossible, working with housing counselors in helping people to avoid foreclosure.

Do regulators believe the same approach to homeowners and housing counselors will continue if OneWest is merged with CIT Group? If not, why do regulators believe the bank will change its behavior?

Counselor comments:

“IndyMac. The average processing time is 12 months. They continually request updated documents and state that they never received docs. It’s so frustrating. Even when you escalate the file the same results occur, having to update docs continually for months on end.” (2011)

“Indymac: Their ability to receive documents (unless it is online) is atrocious. They seemingly are always missing docs that are already there. Their online portal is limited in data transfer capacity. Some of their loans are insured, giving them no motive to modify.”(2012)

“Indymac has the worst performance in terms of foreclosure prevention. Very difficult to obtain any assistance. We had a client that was a victim of dual tracking and had their home foreclosed on.”(2012)

Tomorrow’s questions for regulators will focus on government subsidies for the banks.

Additional Context:

Since the start of the foreclosure crisis, the California Reinvestment Coalition has conducted ten surveys of California housing counselors and their experiences in helping homeowners avoid foreclosure. A sampling of the results related to OneWest are included below, most surveys have between 60-90 responses.

In a July 2010 survey, thirty housing counselors cited OneWest Bank (OWB) as the worst offender for not offering affordable loan modifications, more than all fifteen of the other servicers surveyed. Later that year, only two servicers received more votes than OWB from housing counselors for being the most difficult servicer to work with in trying to help homeowners avoid foreclosure.

In June of 2011, 50% of responding counselors rated OWB as “terrible,” a higher percentage than for all other eleven servicers considered.

In a February 2012 survey, 95% of responding counselors said OWB was “terrible” or “bad”, the second worst rating of all servicers considered.That same survey year, OWB was voted second “worst servicer.”

CRC’s detailed letter to the Federal Reserve Bank of New York includes a preliminary analysis of the merger and a long list of concerns and unanswered questions about the proposed merger, including the loss-share agreement.

Should FDIC Continue Loss-Share Agreements at Too Big Too Fail Bank?

UPDATE: According to CRC calculations, the FDIC has already paid out more than $1 billion to OneWest under the shared loss agreements, with another $1.4 billion expected to be paid out before 2019. See CRC’s fact sheet to read more about it: OneWest Loss Share Fact Sheet

OneWest Bank Merger

The California Reinvestment Coalition, as part of its “5 Days of Unanswered Questions about the CIT Group/OneWest Bank Merger” today focused on the loss-share agreement the FDIC extended to the wealthy investors who bought IndyMac Bank.

no info to public

In response to a FOIA request that CRC submitted to the FDIC, the regulator responded that our request for a fee waiver was denied, in part because “the subject matter of your request is not now of interest to the general public.”

Under the loss-share agreement, the investors in OneWest Bank have to absorb the first 20% of loan losses (approximately $2.5 billion) related to foreclosures from bad loans that IndyMac originated. Once that threshold is met, the FDIC pays for 80% of the next 10% of losses, and 95% of losses beyond that.Something doesn't smell rightCRC’s detailed letter to the Federal Reserve Bank of New York includes a preliminary analysis of the merger and a long list of concerns about the proposed merger. Another 30 organizations, CRC members and allied organizations, sent letters to bank regulators, asking for an extension on the comment period and for regulators to hold hearings in Los Angeles.Paulina Gonzalez, executive director of CRC, explains: “We asked Joseph Otting and John Thain about the amount of money OneWest Bank has received from the FDIC under the loss-share agreement, but they refused to answer us. Given the history of these two banks, we could see why they may be embarrassed at disclosing how much of a government subsidy they’ve received, but the public has a right to know this information.”Kevin Stein, associate director at CRC, adds: “We submitted a FOIA request to the FDIC, asking how much money has been paid out under the loss-share agreements. CRC is a nonprofit and we believe this information is important for the general public to know, so we asked for a fee waiver. We were shocked to hear from the FDIC that they denied our fee waiver in part because: ‘The subject matter of your request is not now of interest to the general public.’ Since when is corporate welfare related to the financial crisis not of interest to the general public?”

On Day Two, CRC members are asking regulators the following questions about the loss-share agreement:

  1. How much money has the FDIC paid to OneWest under the shared-loss agreement related to the purchases of IndyMac Bank, La Jolla Bank F.S.B., and First Federal Bank of California, F.S.B.?
  2. What is the basis on which the FDIC will decide whether to allow the transfer of the loss share agreement from OneWest Bank to CIT?
  3. Beyond the 2011 audit that the FDIC won’t share with the public, has an independent audit been conducted of OneWest bank’s adherence to the loan modification requirements included in the loss share agreement? Will an independent audit be completed before the loss-share agreement is transferred to the new bank?
  4. Under the loss-share agreement, the FDIC is authorized to complete quarterly audits of OneWest’s compliance with the loss-share agreement. During the past 22 quarters since the loss-share agreement was created, how many quarterly audits have been conducted by the FDIC?
  5. Will the FDIC make the results of the audit available to the general public?Is the FDIC concerned that OneWest’s foreclosure record may be at odds with the loss-share agreement? According to RealtyTrac Data, OneWest Bank has foreclosed on over 35,000 Californians, including over 2,000 foreclosures based on reverse mortgages serviced by OneWests’s subsidiary, Freedom Financial, a reverse mortgage lender/servicer.

Tomorrow’s questions for regulators will focus on the foreclosure track record of OneWest Bank in California.

Austin Powers

Additional Context:

CRC’s FOIA Request to the FDIC about the loss share agreements is available here.

The FDIC’s initial response denying CRC’s request for a fee waiver is available here.

American Banker noted (OneWest Makes Money, But Making Friends is the Harder Part, Feb 23, 2010) that: “in less than a year, private equity buyers of IndyMac Bank…. have turned a $1.6 billion profit…Yet thriving on a mess that has already cost tens of thousands of IndyMac borrowers their homes is an awkward situation, and not just for the team of billionaire backers including George Soros, John Paulson and Christopher Flowers…But it’s the terms of the FDIC deal that have yielded the bank’s outsize earnings. OneWest paid $13.9 billion for IndyMac’s assets – a 23% discount to their face value that more than covered OneWest’s $2.5 billion “first loss” obligation.”

For a copy of CRC’s letter to the Federal Reserve Bank of New York opposing the merger, click here: CRC letter to FRBNY

FDIC denied FOIA request

Advocates Announce 5 Days of Questions about CIT Group and OneWest Bank Merger

OneWest Bank Merger

The California Reinvestment Coalition announced a new campaign today to increase the public’s awareness of a proposed bank merger combining CIT Group with OneWest Bank.  The merger, if approved, would create a nearly $70 billion, Systemically Important Financial Institution (SIFI), AKA a Too Big To Fail bank, in Southern California.

A SIFI is a financial institution that is so large, over $50 billion in assets, that its failure could trigger another financial crisis. In this newest proposed bank merger, banking regulators are being asked to approve the union of two banks with troubled histories, OneWest Bank and CIT Group, to form the country’s newest Too Big To Fail bank.

CIT Group, headquartered in New Jersey, is proposing to buy OneWest Bank, headquartered in Pasadena, California. The two banks both have a checkered past. CIT Group took $2.3 billion in TARP funds just a few months before it declared bankruptcy, which meant CIT Group never repaid the $2.3 billion it received from the US Government.OneWest was formed from the ashes of one of the largest bank failures in history, Indymac Bank. Indymac was seized by the FDIC after depositers made a run on the bank in 2009. The FDIC later sold IndyMac at a discount to a group of investors: IMB Holdings Inc. These investors now stand to double their money, and community groups want to know if the regulators are going to ensure there is public benefit and not just investor gain as a result of the merger.

The first of several deadlines for public input to regulators was last Friday, and the California Reinvestment Coalition (CRC) and 25 community organizations sent letters to the New York Federal Reserve Bank, opposing the merger and asking regulators to hold hearings in Los Angeles. CRC’s detailed letter to the Federal Reserve Bank of New York includes a preliminary analysis of the merger and a long list of concerns and unanswered questions about the proposed merger.

Kevin Stein, associate director of CRC, explains: “A recent tape recording of bank regulators coddling the banks they’re supposed to regulate has reduced the public’s confidence that regulators are watching the store. This merger of two banks who required massive government bailouts adds to those concerns because it is an example of investors profiting while communities are left holding the bag. We are urging the bank regulators to conduct their due diligence on this merger which will create a $70 billion institution, and hold hearings in Los Angeles. If there’s not a clear community and public benefit, and instead only a continuing subsidy of the largest institutions and investors, the merger shouldn’t happen.”

As part of the public awareness campaign, the California Reinvestment Coalition will shine a light on five troubling themes about the merger (a new theme each day) as part of a broad public awareness campaign.

On Day One, CRC members are asking regulators: “What (if any) are the public benefits in allowing the creation of another Too Big To Fail Bank?”

CRC is urging regulators to answer the following questions about the public benefit (or lack thereof) of the merger.

• In a merger of this kind, regulators are required to assess the benefits of the merger against the risks created by it. Given the troubled history of the two banks, including the damage caused to communities through the tens of thousands of foreclosures by OneWest bank, and the unpaid $2.3 billion given to CIT Group through TARP, are regulators going to ensure that the newly merged bank has a community benefit and reinvestment plan in place that is commensurate to its new size? How will regulators weigh the risks to the financial system by the creation of a new SIFI bank, especially since taxpayers and communities have already paid for previous risks created by these two institutions?

• Will regulators ask the leadership at the banks why it has set CRA goals in community development and investments that it appears the banks may have already met? Isn’t that bar too low for a bank this large?

• Only fifteen percent of OneWest bank branches are in low and moderate-income census tracts. Based on this measure and others, CRC members believe OneWest Bank is already failing to meet the needs of low and moderate income Californians. How would this new bank merger change that? Should low and moderate income Californians expect to see any benefit from this merger? Why should low income communities accept OneWest’s promise to serve them through mobile banking instead of brick and mortar branches when other communities get both?

• The majority of “small business” loans currently made by OneWest bank are to businesses with over $1 million in revenue. Small businesses create local jobs, strengthen local communities, and are an asset building tool for families. As part of the merger, will the regulators ensure that the bank has a plan to increase its focus on small business lending to smaller businesses (those with less than $1 million in revenue annually)?

• Why have the banks not established clear goals for contracting with Minority, Women, and Disadvantaged Business Enterprises vendors? Does the leadership value contracting with these businesses? If so, why aren’t there any clear benchmarks in the bank’s CRA plan?

Tomorrow’s questions for regulators will focus on the loss-share agreements the FDIC gave to the purchasers of IndyMac bank, the fact that the banks are now asking the FDIC to transfer the agreements to CIT Group, and how much money the FDIC has paid out under these loss-share agreements.

For a copy of CRC’s letter to the Federal Reserve Bank of New York, click here: CRC letter to FRBNY