Fair Finance Watch: Watchdogging & Taking Action from the South Bronx to the Federal Courts

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S&P Global, "Politics likely at play in First Citizens, CIT deal delay,"  "Matthew Lee, executive director of Inner City Press and Fair Finance Watch and someone who has lodged numerous objections to bank deals, said: "My recent experience; Buffalo Business First, "Comments on the M&T/People's United merger," "Matthew Lee, executive director, Inner City Press/Fair Finance Watch, wrote in opposition  Hartford Daily Voice, "Ex-Employees Accuse People's United Bank Of Discrimination,"   Shelterforce, "Trump Agencies Resist Calls to Suspend Non-Essential Rulemaking,"  "A ‘Sea Change’ at the Fed Could Open the Door to Bank Mergers," Bloomberg News: “Hudson City Minority Loans Faces Probe as M&T Deal Idles;  Settled - Fight continues Disparities Continued at Citi, Chase, BofA & Wells as Fed Lax on M&T, US Bank & Smaller; "Mercantile and Firstbank merger will likely be delayed, Consumer protection group alleges Mercantile Bank loaned no money to minorities" Ogemaw County Herald Follow us on TWITTER  BloggingHeads.tv Click here for ICP Books

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Fair Finance Watch is a Non-Governmental Organization Focused on the Fairness of the Financial Services Industries - Banking, Insurance and Securities - to Local Communities, Urban and Rural, North and (Global) South, including under Human Rights Laws

FFW researches, documents and advocates around financial firms' activities, and how they affect local communities. FFW files its findings with tribunals, regulatory agencies, and elsewhere, including on this Web site.

Deutsche Bank To Settle Suit Citing Epstein and FBME Proposes to Pay $26M in SDNY

By Matthew Russell Lee, Patreon Maxwell book
BBC - Honduras - CIA Trial book - NY Mag

SDNY COURTHOUSE, Sept 26 – Deutsche Bank was sued for its lax anti-money laundering and Know Your Customer controls, and for doing business with, among others, scandal-plagued FBME Bank and Danske Estonia, and... Jeffrey Epstein.

  On September 23, 2022, a proposed settlement was filed with U.S. District Court for the Southern District of New York Judge Jed S. Rakoffo. Inner City Press found it in the SDNY docket and will report on its review by Judge Rakoff. 

  Deutsche Bank proposes to pay $26,250,000 to settle the claims. 

The memo of law, at 9, proposes that "by entering into the Stipulation, the Defendants do not admit liability and continue to deny that they engaged in any misconduct or violated the law." But where is the US Federal Reserve, if not the German regulators who missed Wirecard?

And why are prosecutors working WITH Deutsche Bank, on anything? This case is Karimi v. Deutsche Bank Aktiengesellschaft, et al., 22-cv-2854 (Rakoff)

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[Update - after FFW's protest, the application below was withdrawn] February 28, 2022

First Internet Bank Hit By 1st CRA Protest of 2022 Requested Withdrawal But Noncompliant

By Matthew Russell Lee, Patreon Story
BBC - Guardian UK - Honduras - ESPN

FEDERAL COURT / S Bronx, Feb 22 – Whether or not the U.S. Community Reinvestment Act will be again enforced until the new Administration and its regulators remains an open question.

  As the first CRA challenge of 2022, Fair Finance Watch with Inner City Press on the FOIA filed comments with the Federal Reserve against First Internet Bank, below.

  On January 19, First Internet Bank wrote to say that anything for which it requested confidential treatment MUST be withheld. For First Internet Bank, Larry Tomlin of SmithAmundsen of Indianapolis tells Inner City Press and the regulators and DOJ that Fair Finance Watch should withdraw its comments. Really? Inner City Press immediately filed a new and expanded FOIA request.

On February 22, First Internet - the bank that said Inner City Press' comment against it should be withdrawn - had to respond to this question: "5. According to First Internet Bank of Indiana's CRA Performance Evaluation, dated April 6, 2021, the bank received ratings of "Needs to Improve" and "Substantial Noncompliance" in each year (2018, 2019, and 2020) on Tests 6 ("Small Business Lending to Borrowers with Revenues of $1 million or less") and 9 ("Community Development Lending"). Provide information on how the bank has improved performance on these two metrics since 2020. Additionally, provide information on how the bank plans to improve these metrics following the merger with First Century Bank."

Its response? "The Bank continues to focus on and improve its CRA performance across the board." No, disparate.

January 31, 2022

CommunityBank of Texas After Money Laundering Case Hit by Protest by Fair Finance Watch

By Matthew Russell Lee, Patreon Story
BBC - Guardian UK - Honduras - ESPN

FEDERAL COURT / S Bronx, Jan 26 – Whether or not the U.S. Community Reinvestment Act will be again enforced until the new Administration and its regulators remains an open question. The same is the case about money laundering

   Now as the fourth CRA challenge of 2022, Fair Finance Watch with Inner City Press on the FOIA has filed comments with the Federal Reserve against CommunityBank of Texas, fresh off a money laundering / Bank Secrecy Act settlement, with a disparate record: "This is a timely first comment on, the Applications of CBTX, Inc., Beaumont, Texas; to merge with Allegiance Bancshares, Inc., and thereby indirectly acquire Allegiance Bank, both of Houston, Texas. As an initial matter, this is a request that the FRS immediately send by email to Inner City Press all non-exempt portions of the applications / notices for which the Applicants have requested confidential treatment. Fair Finance Watch has been tracking both banks, and has found their lending patterns troubling.   In Texas in 2020, CBTX's CommunityBank made 65 mortgage loans to whites with 54 denials. Meanwhile to African Americans it made only THREE loans, while denying fully ten applications. A referring should be made to the DOJ for fair lending violations.     In Texas in 2020, Alliance Bank made 257 mortgage loans to whites with 38 denials. Meanwhile to African Americans it made only SIX loans, while denying fully seven applications. Again, a referring should be made to the DOJ for fair lending violations.   Public evidentiary hearings are needed - especially because, and specifically on, CommunityBank's violations of the Bank Secrecy Act: "WASHINGTON—The Office of the Comptroller of the Currency (OCC) today announced a $1 million civil money penalty against CommunityBank of Texas, N.A., Beaumont, Texas, for violations of the OCC’s Bank Secrecy Act regulations.  The OCC found that CommunityBank of Texas failed to adopt and implement a Bank Secrecy Act/Anti-Money Laundering system of internal controls to assure ongoing compliance with the Bank Secrecy Act and its implementing regulations. Such deficiencies resulted in CommunityBank’s failure to timely file complete suspicious activity reports for approximately $100 million of suspicious activity.  The OCC’s civil money penalty is separate from, but coordinated with, the settlement between CommunityBank and the Financial Crimes Enforcement Network (FinCEN), which is also being announced today."     FFW and Inner City Press have been deeply concerned about the rush by the Federal Reserve's to rubber-stamp mergers by redliners, money launderers and predatory lenders. This has been killing the Community Reinvestment Act and we timely request public hearings. The comment period should be extended; evidentiary hearings should be held; and on the current record, the application should not be approved."

January 31, 2022

Inner City Press / Fair Finance Watch challenged Berkshire Bank's takeover, and the Fed has asked:

"Provide a list of organizations and community groups, if any, with which Berkshire Bank has engaged since 2020 to help reach African American borrowers in New York. In your response, please provide detailed information about the partnerships that Berkshire Bank engaged in with these organizations and community groups since 2020. 8. Provide information about Berkshire Bank’s efforts to reach African American borrowers in New York, including specialized products and marketing campaigns, since 2020 (if any). 9. Berkshire Bank received a “Needs to Improve” rating in the New York state assessment area during its May 7, 2019, CRA Performance Evaluation. Describe strategies, if any, that Berkshire Bank has implemented since 2019 to improve its performance in the New York state assessment area." Watch this site.

January 24, 2022

Fair Finance Watch with Inner City Press on the FOIA this week filed a CRA challenge to the Applications of Alerus Financial Corporation to merge with MPB BHC, Inc., and thereby indirectly acquire Metro Phoenix Bank, and related applications.

Fair Finance Watch has been tracking Alerus Bank NA, and has found its lending patterns troubling. Alerus Bank NA in 2020 based on its disparate marketing made 5,041 mortgage loans to whites, with only 79 denials to whites -- while making only 105 loans to African Americans, and denying six applications from African Americans. This is outrageous. This application should be denied, and a referral made to the Justice Department, as the Fed did far too late on Cadence Bank, whose lesser disparities Inner City Press similarly raised to the Fed.   

Public evidentiary hearings are needed - including on this timely entered into the record: a former employee of KPC Healthcare, filed a class action complaint on June 1, 2020, alleging that, among other things, (i) in approving the Transaction, Alerus Financial, N.A. (Alerus), the Trustee of the KPC ESOP, caused the KPC ESOP to pay more than fair market value for KPC Healthcare’s stock... See, Class Action Complaint, Gamino v. KPC Healthcare Holdings, Inc., No. 5:20-cv-01126-SB-SHK (C.D. Cal. June 1, 2020), ECF No. 1.

January 17, 2022

  Fair Finance Watch with Inner City Press on the FOIA this week filed a CRA challenge to the Applications of Home Bank N.A. to acquire Texan Bank:

"Dear Director for Southern District Licencing and others at the OCC:  This is a request for a full copy of, and a timely first comment on, the Applications of Home Bank N.A. to acquire Texan Bank.

 Fair Finance Watch has been tracking Home Bank, N.A. and is concerned by its disparate lending. This proposal would impose it on new communities in Houston, Texas. Home Bank NA in Louisiana in 2020 based on its disparate marketing made 616 mortgage loans to whites, with 48 denials to whites -- while making only 53 loans to African Americans, and denying fully 11 applications from African Americans. This is far out of keeping with the demographics, and other lenders, in Louisiana - this is outrageous. This application should be denied, and a referral made to the Justice Department, as the Federal Reserve did far too late on Cadence Bank, whose lesser disparities Inner City Press similarly raised to the Fed.   

It is significant that this application is stuck at the end of the Weekly Bulletin: "ADDENDUM SECTION: This Application was omitted from a prior Weekly Bulletin." This militates for the requested extension of the public comment period, and an inquiry / explanation. The comment period should be extended; evidentiary hearings should be held; and on the current record, the application should not be approved.


January 10, 2022

Fair Finance Watch with Inner City Press on the FOIA has filed a 2d CRA challenge of 2022, to the Fed (so far) on the Applications of TBB Investments LLC and TBB Intermediate LLC to become bank holding companies by acquiring Berkshire Bancorp, Inc and related applications.

 Berkshire Bank in 2020 in New York State based on its disparate marketing made 335 mortgage loans to whites, with only 129 denials to whites -- while making only TWO loans to African Americans, and denying three applications from African Americans. This is outrageous. This application should be denied, and a referral made to the Justice Department... See also the conditions imposed by the FDIC after Fair Finance Watch comments to the FDIC on the sale of Berkshire branches.   Public evidentiary hearings are needed - including on this timely entered into the record: Reclusive landlord Moses Marx resigns as Berkshire chairman, see here.

January 3, 2022

First Internet Bank Georgia Bid Hit By 1st CRA Protest of 2022 by Fair Finance Watch

By Matthew Russell Lee, Patreon Story
BBC - Guardian UK - Honduras - ESPN

FEDERAL COURT / S Bronx, Jan 2 – Whether or not the U.S. Community Reinvestment Act will be again enforced until the new Administration and its regulators remains an open question.

   Now as the first CRA challenge of 2022, Fair Finance Watch with Inner City Press on the FOIA has filed comments with the Federal Reserve against First Internet Bank: "This is a request for a full copy of, and a timely first comment on, the Applications of First Internet Bancorp to acquire First Century Bancorp and First Century Bank, N.A., Commerce, Georgia. 

Fair Finance Watch has been tracking First Internet Bank, and has found its lending patterns troubling.  First Internet Bank in 2020 based on its disparate marketing made 2114 mortgage loans to whites, with only 178 denials to whites -- while making only 66 loans to African Americans, and denying 21 applications from African Americans. FIB essential denies African Americans three times more frequently than whites - worse that the rest of the industry - and makes a far smaller percentage of its loans to African Americans than other banks, particularly those based in Indiana (or Georgia). 

This application should be denied, and a referral made to the Justice Department, as the Fed did far too late on Cadence Bank, whose lesser disparities Inner City Press similarly raised to the Fed.    Public evidentiary hearings are needed - including on First Internet Bank's "tax product lending."

And on this, timely entered into the record:  "07/31/2019  Gave them all my personal info for a mortgage loan and received no call back tried to contact them to no avail. Scared it was a scam to get my info. They were recommended by credit karma. They have my fathers info also. They guaranteed they would get this done. Complaint Type: Problems with Product/Service Status: Answered 03/13/2019  I have attempted to contact someone at this office countless times via phone call, email and chat, I have been unsuccessful in finding out the reason this bank has decided to lock my account and HOLD MY FUNDs WITHOUT INFORMING ME... 

FFW and Inner City Press have been deeply concerned about the rush by the Federal Reserve's to rubber-stamp mergers by redliners and predatory lenders. This has been killing the Community Reinvestment Act and we timely request public hearings. The comment period should be extended; evidentiary hearings should be held; and on the current record, the application should not be approved."

CRA Litmus Test As M&T People's Challenged On Racial Disparities In Lending in NY CT PA

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - ESPN

FEDERAL COURT / S Bronx, March 27 – Whether or not the U.S. Community Reinvestment Act will be again enforced until the new Administration and its regulators is an open question. And the proposed merger of two redlining banks, M&T and People's United, will be the litmus test.

  On March 27, Fair Finance Watch and Inner City Press on the FOIA filed a challenge with the Federal Reserve to the banks' application: "This is a timely first comment opposing and requesting an extension of the FRB's public comment period on the Applications by M&T Bank Corporation to acquire People's United Financial.   

   The applicant M&T in New York State in 2019 made 8,613 home loans to whites and only 629 to African Americans.  M&T in New York State in 2019 made 3.4 loans to whites for each denial to whites. It made only 1.4 loans to African Americans for every denial to African Americans.  

 This is totally unacceptable.       

  The applicant M&T in Connecticut in 2019 made 251 home loans to whites and only 27 to African Americans.  M&T in Connecticut in 2019 made 2 loans to whites for each denial to whites. It made only 1.28 loans to African Americans for every denial to African Americans.    This is unacceptable. 

        The applicant M&T in Pennsylvania in 2019 made 3565 home loans to whites and only 106 to African Americans.

 M&T in Pennsylvania in 2019 made 2.52 loans to whites for each denial to whites. It made only 1.15 loans to African Americans for every denial to African Americans. 

  This is totally unacceptable.

     Meanwhile, People's says it will close some 140 branches.   

    FFW and Inner City Press have been deeply concerned about the rush by the FRS' penchant to rubberstamp mergers by redliners, particularly during the pandemic. We note the Fed's recent website statement that a comment period has been extended to allow participation amid the Coronavirus crisis. This should be done, by the Fed's logic, on this and other applications. We timely request public hearings.  

 The hearings, and your review, should also address M&T's discrimation, see, e.g., (EEOC v. Manufacturers and Traders Trust Co., d/b/a M&T Bank., Civil Action No. 1:16-cv-03180-ELH) in U.S. District Court for the District of Maryland, Northern Division.  See also, this.

  The comment period should be extended; evidentiary hearings should be held; and on the current record, the application should not be approved.

 Meanwhile in Federal court, PNC Bank and its Midland Loan Services have been sued for usury, predatory lending and civil conspiracy, under New York and Federal law.  

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PNC Bank Is Sued For Usury and NY Civil Conspiracy As Applies For BBVA Under CRA

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - ESPN

SDNY COURTHOUSE, Dec 29 – PNC Bank and its Midland Loan Services have been sued for usury, predatory lending and civil conspiracy, under New York and Federal law.  

 The complaint docketed on December 29 in the U.S. District Court for the Southern District of New York, which Inner City Press covers, describes PNC's lending on a number of homes and allegedly racking up $250 charges.

It questions the reporting on line 205 of the HUD statement. When the plaintiff questioned it, he was called an "assh*ole." 

 The case is filed while PNC seeks to buy the US retail banking business of BBVA for $16 billion, an application to the Federal Reserve Board and other regulators which is subject to the Community Reinvestment Act.

 The case is Barli v. PNC Bank, NA et al., 20-cv-11027 (Unassigned)

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July 28, 2020, Hartford Daily Voice, "Ex-Employees Accuse People's United Bank Of Discrimination  Kristin Palpini, "Fair Finance Watch tried to block People’s from acquiring Framington Bank alleging People’s has a record of discriminatory lending," https://dailyvoice.com/connecticut/hartford/business/ex-employees-accuse-peoples-united-bank-of-discrimination/791591/

March 18, 2020, Shelterforce, "Trump Agencies Resist Calls to Suspend Non-Essential Rulemaking," by Miriam Axel-Lute, "'In light of the Coronavirus / COVID-19 crisis, leading to the shutdown of some courts, shelter in place orders and regulatory extensions even by the SEC,' the OCC and FDIC comment period be extended for months, wrote Matthew Lee of Fair Finance Watch in a formal comment to the OCC," https://shelterforce.org/2020/03/18/federal-agencies-resist-calls-suspend-rulemaking/

Barron's, Jan 31, 2018, "A ‘Sea Change’ at the Fed Could Open the Door to Bank Mergers," By Ben Walsh, "Barron’s spoke to one group, Fair Finance Watch, that submitted comments in the Cadence and Synovus transactions. Matthew Lee, the group’s executive director says he believes that the Fed’s approval structure creates makes it necessary for groups like his to file CRA comments to ensure that transactions are given appropriate review," https://www.barrons.com/articles/federal-reserve-is-seen-helping-bank-mergers-51548943990

July 31, 2018, People's United “Bank buyout challenged over lending record,” By Howard French, Journal Inquirer http://www.journalinquirer.com/business/bank-buyout-challenged-over-lending-record/article_7ebbbb20-94d9-11e8-8b75-ef58d76f8c15.html

Jan 18, 2018, Shelterforce, on Wells Fargo branch closings: https://shelterforce.org/2018/01/20/shelter-shorts-week-community-development-jan-19/

May 2, 2017: “Watchdog group opposes Sterling Bancorp, Astoria Financial merger,” Westchester County Business Journal https://westfaironline.com/88802/watchdog-group-opposes-sterling-bancorp-astoria-financial-merger/

Dec 20, 2016, NYCB-Astoria withdrawn: http://www.insidemortgagefinance.com/imfnews/1_1007/daily/nycb-and-astoria-financial-cancel-their-merger-1000039503-1.html

August 15, 2016: "People’s United Bank faces opposition in proposed acquisition of New York bank," Connecticut Post

April 25, 2016: "Fed extends comment period on application by Huntington Bancshares to acquire FirstMerit Corp," Crain's Cleveland Business

April 2, 2016: "Scrutiny, suit delay local bank sale," S.C. Post & Courier

November 17, 2015: "Pending sale of First Niagara generates investigations into shareholder interests," Buffalo Business First

September 15, 2015: “Hudson City Savings Bank agrees to $32.75M mortgage discrimination settlement,” Bergen (NJ) Record

July 17, 2015: "Fed probes RBC role in City National loan, possibly delaying merger deal," Scott Reckard, LA Times

April 15, 2015: “Hudson City Minority Loans Faces Probe as M&T Deal Idles,” Bloomberg News

April 29, 2014: “U.S. Bank closing 13 branches in Charter One buyout,” Crain's Chicago Business

April 5, 2104: In 2013 Disparities Continued at Citi, Chase, BofA & Wells as Fed Lax on M&T, US Bank & Smaller

November 29, 2013: "Mercantile and Firstbank merger will likely be delayed, Consumer protection group alleges Mercantile Bank loaned no money to minorities in 2012," by Eric Young, Ogemaw County Herald

November 29, 2013, "Mercantile, Alma bank merger is under protest," Grand Rapids Business Journal

November 25, 2103, "Federal Reserve holds up merger of Mercantile Bank Corp. and FirstBank Corp. over minority lending practices," by Jim Harger, MLive/Grand Rapids Press

4/1/13 -- CRA: In 2012 Disparities Continued at Citi, Chase, BofA & Wells as Fed Lax, ICP Studies & Challenges.

Back on the bank beat, October 2012: "M&T deal is challenged over inner-city lending," by Jonathan Epstein, Buffalo News, Oct. 10, 2012

"Fair lending advocate challenging Hudson City-M&T merger," by Richard Newman, NJ Record, Oct. 12, 2012

Click here for Sept 26, 2011 New Yorker on Inner City Press -- then there was some push back, documents here

4/3/11 -- In 2010 Subprime Lending Grew More Disparate at Citi, Chase, Wells & BofA

3/13/11 - “Flag raised on merger of Hancock, Whitney banks,” New Orleans Times Picayune

2/17/10 -- FFW in The Guardian (UK), Feb. 16, 2010, on Wells Fargo's subprime

4/2/09 -- Subprime Survivors Wells, BofA and JPM Chase Were More Disparate By Race in 2008 than Wachovia or Countrywide, Study Finds

7, 2008 -- First Study of 2007 lending data, disparities at Chase, Citigroup, WaMu, Wachovia, Bank of America and Countrywide, in run-up to Federal Reserve public hearings. Bank Beat: Disparities at targets National City and KeyCorp, US Bancorp's HOEPA loans

Housing group challenges Fed's Bear Stearns deal (Reuters of March 16, 2008)

Campaign advisers tied to lending crisis
(USA Today of April 2, 2008, re subprime Delta)

July 4, 2007 - 1st challenge to ABN Amro's proposes sale of LaSalle to Bank of America

April 10, 2007 - Subprime Racial Disparities By Banks in New York State Worse than at Countrywide, Which Settled Predatory Lending Charges in NYS in 2006

April 4, 2007 - First study of 2006 HMDA data and see, "Banks Prone to Sell Minorities Pricy Loans," Reuters / Washington Post

2006 - FFW study of mortgage lending in Detroit: Ameriquest, Citigroup

Some coverage (click here for more): HSBC Faces Bid Challenge,” by Conal Walsh, The Observer, September 18, 2005

2005 -- FFW's Campaign against Riggs Bank’s cheap settlement for money laundering for human rights abusers, and the sale of Riggs to PNC - click here.

Also, on this site, FFW's analysis of Equatorial Guinea - click here

Navigate using the map below, on which the area names are links:


 Click here re           Click here re         Click here for          Click here re
 United States          FFW Campaigns    In Other Media      Non-USA/Global

         FFW researches, documents and advocates around financial firms' activities, and how they affect local communities. FFW files its findings with tribunals, regulatory agencies, and elsewhere, including on this Web site . Click here to view analyses of several multinational financial institutions' effects on consumers and the environment, worldwide: for two examples, Citigroup and HSBC. Click here for some initial brainstorming on the application of human rights and international law to the global financial services companies, and for citations (where possible, links) to resource material.  Click here for some September 2004 campaigns -- PNC/Riggs (Finance Watch Reports of August 16, 2004, onwards), J.P. Morgan Chase, etc..  Click here for an ongoing report on the campaign to reform anti-money laundering, tax haven, and bank secrecy laws.   Click here for the Human Rights Enforcement project, including its new (9/04) criminal justice and local human rights project.

2/05 -- FFW's Campaign against Riggs Bank’s cheap settlement for money laundering for human rights abusers, and the sale of Riggs to PNC - click here

Money Laundering Alert named Fair Finance Watch its “Hero” for November 2004 - click here to view

Beginnings of a FFW initiative:

Human Rights & Finance: Predatory Lending in a Deregulated Network Economy

    If the biggest names in finance -- Citigroup, HSBC, General Electric and AIG -- have been engaged in predatory lending in the United States, there's a need for an inquiry into their behavior in less regulated economies internationally.

    An inescapable trend in this new millennium is the export of subprime lending models beyond the United States. Citigroup, following its acquisition of Associates First Capital Corporation in late 2000, began offering subprime loans to lower-income consumers in countries from Brazil and Mexico to India and Korea. The Hong Kong Shanghai Banking Corporation (HSBC) bought Household International a mere month after Household settled predatory lending charges with attorneys general in 42 states for half a billion dollars. In making the deal, HSBC chairman Sir John Bond said that the profits would come from exporting Household's model to the 81 other countries in which HSBC does business; a month later, HSBC announced it would compete in subprime with Citigroup in Brazil.

    From Australia through North America and back to Eastern Europe, General Electric, through its GE Capital unit, has developed a subprime lending capacity on which the sun never sets. The insurance company AIG has more quietly taken the subprime lending model of American General, which AIG bought in 2001, to the other countries in which AIG goes business.

    This consensus around high-rate lending in emerging markets by the world's largest bank (Citigroup), insurer (AIG) and corporation (GE) is indicative of the way in which c