DOEREN MAYHEW
Failure to Ensure Its Outreach , Marketing or Advertising Reached Market Populations
Citadel failed to ensure its outreach , marketing and advertising for its mortgage lending services reached majority Black and Hispanic neighborhoods . In the majority White neighborhoods within the market area , Citadel ’ s mortgage lending services were available to prospective applicants who walked into its physical branches . Given there was only one branch in a Black and Hispanic neighborhood in Chester County , and none in Philadelphia County where 76 % of the majority Black and Hispanic census tracts within the credit union ’ s market area are located , these services were not readily available to the vast majority of residents of those neighborhoods . Citadel did not take steps to train or incentivize its mortgage loan originators to compensate for its lack of branches and serve the residents of these neighborhoods . The credit union assigned each mortgage loan originator to take applications from borrowers around particular branches but assigned no mortgage loan originators to take applications from borrowers in Philadelphia County , despite accounting for 34 % of its overall market area . Outlined below are key areas in which the credit union failed to adequately market to the impacted communities :
• Advertising : Citadel ’ s marketing and outreach strategy was focused primarily on brand recognition , failing to include any efforts to market and advertise its mortgage lending services to these areas . The credit union did not monitor where it distributed its marketing or outreach materials to ensure distribution occurred in all neighborhoods throughout its market area .
• Direct Mail : Occasionally , the credit union used direct mail campaigns to attract new members . When it conducted these campaigns , it sent mail to residents located near its existing branches , most of which went to majority White areas .
• Communications : Citadel also did not advertise or market in Spanish or attempt to reach Hispanic areas within its market area , even though it made up 9 % of its market area ’ s population . Additionally , the credit union did not translate direct mailings or other materials into Spanish . Citadel ’ s own fair lending policy prohibits “ using only English in an area where the majority of the members or potential members are non-English speaking .” However , the credit union did not try to determine whether areas within its market area were majority non-English speaking .
The credit union also did not employ any mortgage loan originators who spoke Spanish . Its employees responsible for assisting customers with residential real estate loans were unable to provide mortgage lending services to Spanish-speaking applicants and prospective applicants .
• Seminars : Citadel promoted its First-Time Home Buyers Program through seminars . The seminars were only held at its headquarters , branches and a local library in majority White areas . Participants received financial incentives for attending a seminar in the form of reduced closing costs upon taking out a residential mortgage , which led to the credit union denying residents of majority Black and Hispanic neighborhoods this cost-saving opportunity .
Continued on page 4
VIEWPOINTS : REGULATORY COMPLIANCE EDITION | 03