it was $18 billion, for 1978 it was $17 billion. And what we are going to ask you to do is to break these down in a much more finite detail, by New York City, and boroughs, by the rest of the New York Standard Metropolitan Statistical Area, by SMSA, in the United States and outside the United States. We want to get a better picture of where Chase is making their loans. And we would prefer to get it through your cooperation, with your cooperation. Otherwise, we are going to ask the Comptroller of the Currency to do an extra special review of your loan portfolio, so that we can get a better understanding of whether there is compliance with the Community Reinvestment Act.

I mean, do you see these figures yourself? In other words, Citibank made 6,913 home mortgage loans in 1980 in the Greater New York Metropolitan Area, you made 1,920, Manufacturers made 9,011, and Chemical made 13,000. Do you want to write those figures down so we can talk to them, or do you recall them?

Mr. HUMMER. I understand the magnitude of them. But I can write down the exact numbers.

Mr. ROSENTHAL. Citibank made 6,913. Chase Manhattan made 1,920. Manufacturers Hanover made 9,011, and Chemical made 13,954. I would like you to comment on those. I mean, what is the explanation for this significant deficiency?

Mr. HUMMER. As read, I would hazard a guess that the figures are incomparable and do not compare apples to apples.

Mr. ROSENTHAL. Tell us why. I am anxious to learn.

Mr. HUMMER. I find it unlikely that in single family one to four family mortgages in the metropolitan area that Chemical made a number that, as measured here, is roughly 10 times ours, would be $500 million of new origination in that period. I would assume it includes other categories.

Mr. ROSENTHAL. What do you say?

Mr. SCHOCHAT. Well, our total portfolio is about $1 billion in home mortgages.

Mr. HUMMER. As is ours. But 50 percent of it, I very much doubt, was originated last year.

Mr. ROSENTHAL. These figures are from the Home Mortgage Disclosure Act statements given to the Federal Reserve Board.

Mr. HUMMER. Well, it is a very difficult thing to calculate out of those extremely difficult statements that are in extremely large volume. Chemical Bank's number, according to your interpretation, is that 50 percent of it was originated last year. I find that extremely unlikely.

According to a similar calculation, we have approximately the same billion that he mentions in outstanding mortgages and we only originated $50 million last year.

Mr. ROSENTHAL. $51 million.

Mr. HUMMER. That does not sound to me like the two numbers are on a comparable basis.

Mr. ROSENTHAL. Can anybody offer any light on this?

Mr. HUMMER. I mean, I know that our mortgage origination was substantially off last year for the same reason Citibank mentioned, which is that the application volume was very much lower than in the previous year because of interest rates. Our approval rate did not go down significantly. I am sure the other banks [approval

rates] did not go down significantly. But the application volume went down.

Mr. ROSENTHAL. Well, I do not have an explanation. You people should have a better explanation than I do. These are figures that were all provided for the Federal Reserve Board and provided to us. I mean, Citibank's figures for the 6,913 home mortgage loans were $340 million. Yours was $51 million. Manufacturers was $625 million. And Chemical bank was $846 million. Now, you say that those figures are not comparable.

Mr. HUMMER. They sound extraordinarily incomparable to me on the face of it.

Mr. ROSENTHAL. But we took them from the same source, from the same columns, from the same forms. I have no explanation. Mr. HUMMER. I did not take the data, sir. I have no answer to that.

Mr. ROSENTHAL. Does anybody have any comment? Mr. Hosey, do you have a thought?

Mr. HOSEY. No, Mr. Chairman, I have no comment on it. The numbers are what the numbers are. The numbers that go to these outside agencies are not taken lightly and under HMDA G-107, et cetera, and whatever the numbers are, they have been checked. Not by myself, but by accounting and other people in the institution.

Mr. ROSENTHAL. Do you have any comment?

Mr. DRUGER. Those are accurate numbers which, as far as Citibank is concerned, were confirmed by outside surveys that we made of mortgages actually closed in the five boroughs of New York.

Mr. ROSENTHAL. See, these are your numbers. I did not create them. These are numbers that you supplied to the Federal Reserve Board.

Mr. HUMMER. I am not disputing that. Our numbers appear accurate.

Mr. ROSENTHAL. But what is the explanation?

Mr. HUMMER. As we discussed a moment ago, if Chemical Bank, if the number is $800 million and I do not know, if their origination last year was $800 million and their total portfolio is $1 billion I find it quite conceivable

Mr. ROSENTHAL. The total lending was $2 billion last year, not the total portfolio. The total lending. What is it? What was it, Mr. Schochat? These are your figures. What are they?

Mr. SCHOCHAT. Can you read those off again?

Mr. ROSENTHAL. They are the same as exactly on here.

Mr. SCHOCHAT. I do not have the totals here.

Mr. ROSENTHAL. The total lending for real estate loans in 1980 was $2 billion.

Mr. SCHOCHAT. What I can say, Congressman Rosenthal, if those are the figures that we presented to the Federal Home Loan Board, those are accurate figures. They are audited figures and they are within the compliance requirements of the bank. So if those figures were not copied incorrectly, I would have to accept them.

Mr. ROSENTHAL. No, no, I am reading them accurately to the best of my ability. There is no question about it. The total mortgage loans for New York City were $846,799,988 for 1980. And these

sources are the Home Mortgage Loan Disclosure Statement, December 31, 1980, obtained through the Board of Governors of the Federal Reserve System, Washington, D.C. We list on this chart where each one came from.

It does not show for Citibank, the source. Oh, I see. This number, two, next to Chase Manhattan, shows the source. And the source is the Home Mortgage Loan Disclosure Statement of December 31, 1980. We obtained it from the Board of Governors of the Federal Reserve System.

In other words, you are not saying these figures are incorrect. Mr. HUMMER. I am not saying they are incorrect. I do not know how you took them off of a very complex report.

Mr. ROSENTHAL. The same way we took them off for the other three banks.

Mr. HUMMER. I simply am trying to say that I cannot comment on the figures of the other banks. I am quite familiar with the figures of Chase Manhattan. And the figures of Chase Manhattan show that, indeed, we only made 50 odd million dollars in residential mortgages in the New York City area last year. That represents what we consider only a portion of the SMSA and of our community. It is also true that we do not consider our total deposits versus mortgage originations in 1 year as responsive to the Community Reinvestment Act and its purposes. We consider home improvement loans, personal loans, secondary mortgage loans and so

on.

Mr. ROSENTHAL. How much are they?

Mr. HUMMER. Well, in grand total, we are proud of our record on those numbers.

Mr. ROSENTHAL. But you do not have any numbers. According to the figures that you supplied, and I think you agree, you made new mortgage loans in the Greater New York area last year of $51 million. You did, in fact, make new real estate loans in the rest of the country of $4.3 billion.

Mr. HUMMER. Well, sir, the two are, to me, no way related. Construction lending, which is very short term, a floating rate business, to compare it to a 30-year fixed rate personal mortgage, the two things are totally incomparable. They are not the same kind of business.

Mr. ROSENTHAL. Well, are they incomparable or not comparable for the other banks? I mean, when you look at the same figures, the same source and the same figures, from your bank and the other banks, there is a shocking difference.

Mr. HUMMER. I very much doubt that if you compared apples to apples you would find it shocking. I realize that those numbers appear very much out of line. They are two totally separate departments doing two totally separate kinds of business. The consumer banking sector does not manage real estate loans. The real estate department in our bank does not manage home mortgages. The primary Community Reinvestment Act focus is in the consumer banking sector, where we are very proud of our record in that area. And the fact that the real estate department may make X or Y quantity of loans elsewhere is simply not a factor in that.

Mr. ROSENTHAL. Well, it is a concern of the people, public officials like myself, who have a responsibility for seeing that New

York City gets its fair share of return on deposits made in New York City. Because that is what the law says.

I guess we are just going around in circles, you and I. We are going to have to deal with this at another level or in some other fashion. I am going to try and develop more information, hopefully voluntarily. And if not voluntarily, then involuntarily.

Thank you all very, very much. The subcommittee stands adjourned.

[Whereupon, at 12:14 p.m., the subcommittee adjourned, to reconvene subject to the call of the Chair.]

APPENDIXES

APPENDIX 1.-CHARTS: HOME MORTGAGE LOANS, DEPOSITS, AND SUMMARY OF LOANS FOR CITIBANK, CHASE MANHATTAN BANK, MANUFACTURERS HANOVER BANK, AND CHEMICAL BANK, 1978-81

1 "Assets and Deposits by State," obtained through the Board of Governors of the Federal Reserve System as of Mar. 31, 1981. 2 "Consolidated Reports of Condition," submitted to the Board of Governors of the Federal Reserve System as of June 30, 1981. 3 "Summary of Deposit Reports," submitted to FDIC as of June 30, 1980.

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