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WRITE A LETTER TO THE FDIC BY MARCH 31, 2005

FIRST BANK OF DELAWARE’S

CRA PERFORMANCE DESERVES A FAILING GRADE

FIRST BANK OF DELAWARE

SWIMS WITH PAYDAY

LENDING SHARKS!

PAYDAY LENDER RENT-A-BANKS OUT OF DELAWARE !

First Bank of Delaware, headquartered in Wilmington, is a shell operation disguised as a bank, set up to facilitate harmful payday lending activities.  First Bank is not providing enough community investments, services, or lending to low-income communities in Wilmington, where its only two branches are located.

Instead, First Bank hurts low-income borrowers by making a high volume of abusive payday loans through payday lender partners in other states, including Dollar Financial Group in Arizona, California, and Ohio, and Check’n Go in Michigan and Texas.  First Bank also partners with Liberty Tax Service to offer high-fee Refund Anticipation Loans (RAL’s) nationwide, and with Check'n Go to offer internet payday lending.  The bank has evaded government regulation by withdrawing from the Federal Reserve System in favor of oversight by the FDIC, the only regulatory agency that allows banks to partner with payday lenders.  Of 5,000 banks regulated by the FDIC, First Bank is 1 of only 12 still renting their services to payday lenders.

 Help shut down this unscrupulous member of the Dirty Dozen Rent-A-Banks.

First Bank is currently facing a Community Reinvestment Act (CRA) exam given by the FDIC to test how well it is reinvesting in the community where it is located.  Write a letter to the FDIC by March 31, 2005 and let them know First Bank of Delaware’s CRA performance deserves a failing grade.

SAMPLE LETTER:

POSTMARK BY MARCH 31, 2005

Scott D. Strockoz, Compliance Deputy Regional Director
Federal Deposit Insurance Corporation Regional Office
20 Exchange Place, Room 6014
New York, NY 10005-3201

Attention:  First Bank of Delaware CRA Exam

Dear Mr. Strockoz:

I am writing to urge you to fail First Bank of Delaware on its upcoming CRA exam.  The bank is violating the FDIC’s payday lending guidelines with an unsafe and unsound percentage of its business devoted to unscrupulous payday lending.  It has completely failed to serve its CRA assessment areas.  First Bank of Delaware’s CRA performance deserves a failing grade.

There is no evidence that First Bank of Delaware is fulfilling any of its obligations under the Community Reinvestment Act to provide community development financing and basic banking services to low- and moderate-income communities where its Delaware branches are located.  Neither the FDIC nor the Delaware State Banking Commission has publicly available information regarding the bank’s performance in these areas.

Also, First Bank of Delaware poses a significant safety and soundness concern.

     ·        Payday lending accounted for $2.9 million of its parent bank’s total net income of $4.9 million during 2003, or 59%.

·        As of February 2005, First Bank was spun out as a separate corporate entity, with an even higher percentage of its revenues derived from payday lending.

·        The bank is clearly a shell operation set up to facilitate harmful payday lending activities in other states, and does not serve its own community assessment area.

·        First Bank issues a high volume of abusive and unsafe payday loans through several payday lender partners, including Dollar Financial Group in Arizona, California and Ohio, and Check’n Go in Michigan and Texas.

Under the Community Reinvestment Act, banks have a responsibility to serve all citizens’ credit needs, including low- and moderate-income (LMI) communities, consistent with safety and soundness.  First Bank of Delaware instead engages in the unsafe and unsound payday lending practice that is a slap in the face to CRA’s mandate for banks to serve credit needs.

Thank you.  If you have any questions, call me at __________________________  (Phone #)

Sincerely,                                                              Date _________________________________

Name ________________________________   E-mail _______________________________

Address _________________________   City _______________   State ____   Zip _________