DOEREN MAYHEW
• Loan Subsidy Fund : Invest a minimum of $ 6 million in a loan subsidy fund with the goal of increasing credit for home mortgage , improvement and refinance loans extended in majority Black and Hispanic census tracts in Philadelphia County .
• Community Development Partnership Program : Partner with one or more community-based or governmental organizations to provide residents of majority Black and Hispanic census tracts with services related to credit , consumer financial education , homeownership and / or foreclosure prevention . Through these partnerships , it must spend at least $ 250,000 over the term of the consent order to provide such services .
• Advertising , Outreach , Consumer Financial Education and Credit Initiatives : Spend at least $ 270,000 over the term of the consent order on advertising , outreach , consumer financial education and credit counseling targeted toward majority Black and Hispanic census tracts within Philadelphia County . It must advertise its mortgage lending services and products in these same areas at least to the same extent it advertises its mortgage lending services and products to majority White census tracts . Citadel must provide a minimum of two seminars per year targeted and marketed toward residents in majority Black and Hispanic census tracts and held in locations intended to be reasonably convenient to those residents with translation and interpretation services in Spanish , if warranted . These seminars must cover credit counseling , financial literacy and other related consumer financial education aimed at helping identify and develop qualified loan applicants from those areas .
The Impact
The NCUA ’ s Chairman Todd Harper issued a statement regarding the consent order , stating the NCUA regularly refers credit unions to the DOJ when it identifies patterns or practices of discrimination that require appropriate relief for harmed consumers . For 2023 and 2024 , Harper pointed out these referrals impacted more than 75,000 consumers .
“ While Citadel respectfully disagrees with the allegations regarding our lending practices , we view this settlement as a vital opportunity to enhance our commitment to proactive community engagement . We acknowledge that our efforts did not allow us to reach majority Black and Hispanic census tracts in Philadelphia . As we look back at our history , this is a situation arising from what we weren ’ t doing , rather than one of intentional acts . Banking has not been immune to the digital disruption that has swept across various industries for decades and Citadel ’ s robust focus on our digital journey shifted our strategy away from new brick-and-mortar branches in recent years , which inadvertently impacted our ability to serve our region as broadly as we had planned . Philadelphia has always been , and remains , part of our growth plan , but the evolution of our business model led to us falling short of opening branches in Philadelphia as we had agreed to do when we expanded our charter .”
BILL BROWN | CITADEL PRESIDENT / CEO
VIEWPOINTS : REGULATORY COMPLIANCE EDITION | 05