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ACTION STRATEGIES: MAKING DISCLOSURE WORK IN OUR NEIGHBORHOODS

Neighborhood Research

Because both the public and private sectors typically base decisions regarding which neighborhoods get what resources solely on their own research--be it market analysis, census data, or other types of information-community groups can have meaningful impact only if they have a clear understanding of and can communicate the real perceptions and priorities of their neighboring residents. The disclosure reports were released September 30, 1976, and community organizations which have not already done so should conduct some background research. A comprehensive neighborhood profile puts your group in a far better position to utilize the mortgage 7 lending data. This profile should include such information as: credit and loan availability, housing needs, condition of housing stock, and the potential lenders in the neighborhood.

Documentation can range from citing

Research can be done in many ways. unsuccessful attempts to obtain mortgage loans in a given neighborhood to uncovering inconsistent mortgage terms stipulated by lending institutions. Urban depositories using the bulk of their assets to develop the suburbs for example, have been identified by a variety of community groups. The relative "sophistication" of the research is less important than its ability

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An excellent source of various neighborhood research is found in the testimony for the Home Mortgage Disclosure Act hearings before the Senate Housing, Banking and Urban Affairs Committee. May, 1975 (Vol.I).

verify disinvestment by lending institutions and demonstrate that the residents affected by this policy are worthy of credit.

This

Besides the fact that it elicits hard information, such research is valuable because the competence to carry on such an activity confers legitimacy and recognition upon citizens groups in the eyes of public officials, public interest organizations, and, for the most part, private lenders. in turn leads to a more substantive role for neighborhood organizations wishing to affect policies and programs pertinent to their communities. Some community groups have voiced a concern about the relationship between organizing efforts and the research function. They have felt that to do research they would either have to cut back on organizing or hire a professional (lawyer) to get research in an "acceptable" format.

Neither

of these steps are necessary to get the answers most groups need. In fact, our experience has shown that the majority of groups have used the gathering of information as a form of organizing.

Door-to-door surveys,

neighborhood meetings, going down to city government to look at public documents are all forms of research--and organizing.

examples of neighborhood surveys.)

(See appendices for

Neighborhood groups not already having one should create a regular committee responsible for neighborhood research. This group can also deal with disclosure reports for their areas.

In addition to utilizing this data a research committee should be aware of or in contact with agencies having additional information useful to their own organizations. These include:

a) Planning Department Offices--Employees here have plans for the cities' neighborhoods and can do zip code conversions into census tracts. In most cases, there is a planner (s) assigned to specific areas; some of

these people are "neighborhood advocates" and community groups should be in close contact with the one responsible for their community.

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(b) Housing and Community Development Offices--In cities which have filed for Community Development funds, there is a related Housing Assistance Plan. The purpose of this program is to gather and disseminate detailed information about specific aspects of the city (socio-economic factors, housing stock, etc.) which might prove very helpful to your group. Beyond this, Housing and Community Development offices contain information on various proposals for neighborhood and housing programs, as well as reports on specific housing and finance needs for the different parts of the city.

(c) City Registry of Deeds--Public information about all residential property transactions that occur in the city--their terms and the people involved--is located here.

(d) Depository Institutions--reports of their investment actions and deposits are available upon request. Some places (e.g. California) are required to file monthly or annual reports of their activities.

Specific to monitoring the disclosure data, these neighborhood re

search committees should:

1) determine what is being done to analyze the data--either by the public agencies or the lending institutions themselves. Neighborhood

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NOTE: The resources of zip code conversions and neighborhood advocate planners are usually found in the larger cities, rather than the smaller

ones.

groups should play a role in the analysis process, especially in providing a community focus regarding the implications of the lending patterns and what is necessary for positive change;

2) approach all local depository institutions

either by a visit or the reporting forms they use, to receive a copy of

their disclosure reports, and to offer assistance in getting this information

out;

3) contact the regional Federal Reserve Board office near you (see Appendices for list) for general information on the disclosure regulations, any particular questions about them, what measures exist for enforcement, and how to find out if a local depository institution is requesting an exemption;

4) check with other community groups in your city to see what they have discovered regarding lending patterns of financial institutions; in their neighborhoods;

The

5) publicize lending institutions in your community which have been steadily supportive of and responsive to the credit needs of the neighborhood. Attempt to work with those having opposite practices, especially if they are major depositories for the residents in that area. committees might want to monitor disclosure reports of two such institutions, charting in detail their different lending patterns; this will allow them to better pinpoint the redlining occurring in their neighborhoods.

6) refer to memo (in Appendices) by Jon Brown, Public Interest

Research Group.

7) Check with local community groups listed in the resource section, about the work they've done.

Negotiating With Public Officials

Any actions related to disclosure should include the question of

where public funds are deposited.

The answer to this question has clear

implications for both public policy--especially on a local level--and strategies for reinvestment--i.e. dealing with public officials and the lending institutions themselves. And remember, the role of public officials was spelled out in the disclosure legislation as "the distribution of public sector investments in a manner designed to improve the private investment ,,8

environment.

City officials control large amounts of money (your taxes, federal monies, etc.) and these funds must be deposited somewhere. If properly used, this depository action can wield enough power to affect the lending patterns of local depository institutions. However, most cities spread their funds among a number of depository institutions. While there are no laws or restrictions about the procedures of depositing public funds, there are in most cases limits on the amount of funds one institution may receive. This "ceiling" has been used primarily as a protective measure. For the most part, deposit of city funds has not been connected with any other city policies.

However, some impact can be made and community organizations should press their local officials to bring to bear whatever depository powers they can exercise. Within the past few years, certain cities and states have been recognizing and utilizing these depository powers. City officials are adopting "social criteria" such as a commitment to anti-redlining

policies to determine the institutions in which they will deposit their

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Home Mortgage Disclosure Act of 1975 (P.L. 94-200). Section 302 (b).

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