Monica Lynn Burch
Community Development Market Manager

Community Development
PL1325
130 North 18th Street
13th Floor
Philadelphia, PA 19103
Telephone: 267-671-1096
facsimile: 215-751-1518
monica.burch@citizensbank.com

CITIZENS BANK’S WRITTEN STATEMENT SUBMITTED TO THE CITY COUNCIL OF PHILADELPHIA
MARCH 27, 2018
Citizens Bank, N.A. appreciates the opportunity to submit this statement to the City Council of
Philadelphia.
ABOUT CITIZENS BANK
Citizens Financial Group, Inc. is one of the nation’s oldest and largest financial institutions, with $152.3
billion in assets as of December 31, 2017. Headquartered in Providence, Rhode Island, Citizens offers a
broad range of retail and commercial banking products and services to individuals, small businesses,
middle-market companies, large corporations and institutions. In Consumer Banking, Citizens helps its
retail customers “bank better” with mobile and online banking and the convenience of approximately
3,200 ATMs and approximately 1,150 Citizens Bank branches in 11 states in the New England, MidAtlantic and Midwest regions and office locations in 20 states. Citizens also provides mortgage lending,
auto lending, student lending and commercial banking services in select markets nationwide. In
Philadelphia, Citizens maintains 54 branches and employs 422 people.
HOW CITIZENS BANK SERVES THE LMI COMMUNITY IN PHILADELPHIA
Citizens Bank is dedicated to serving the mortgage financing needs of its community, including low- and
moderate-income (“LMI”) borrowers and families residing in LMI areas as well as traditionally
underserved communities. Citizens Bank has the largest branch network in the Philadelphia market with
54 branch locations. Twenty nine (29) of the 54 branches are located within or in close proximity to the
low- and moderate-income communities in the city. The bank has developed a multi-pronged program
to serve LMI residents in Philadelphia. The program includes:
1) A broad set of mortgage loan programs, including portfolio and government-guaranteed loan
programs, that benefit LMI homebuyers by addressing key factors that hinder the ability of LMI
and first-time homebuyers to achieve homeownership. Features and benefits of these
programs include lower down-payment requirements, higher debt to income ratios, and our
portfolio product also eliminates the need for private mortgage insurance. (See Attachment A
for a description of our flexible and affordable mortgage lending products.)
2) Dedicated mortgage loan officers focused on serving the needs of LMI borrowers.
3) Closing cost and down-payment assistance to borrowers who have low or moderate income or
are purchasing homes in LMI communities.

 4) Participating in and supporting local home-ownership programs.
5) Participating in and supporting non-profit organizations serving the needs of LMI and first-time
homebuyers through homeownership education initiatives.
The successes of our efforts are demonstrated by the results. In 2016 (the most current year for which
information is available), in the City of Philadelphia, we ranked 9th among all HMDA reportable lenders
in mortgage loan originations. However, when focusing on LMI borrowers, we ranked 8th; in terms of
mortgage lending to families purchasing homes in LMI census tracts, we ranked 5th. We were similarly
effective in reaching African American borrowers, in 2016 we ranked 6th among mortgage lenders to
African American borrowers. Citizens Bank’s historical success in mortgage lending to LMI borrowers
and in LMI communities were key elements that lead to the FDIC awarding the Bank an Outstanding
CRA rating during its most recent Performance Evaluation, which covered the period through the end of
June of 2015. In its assessment of Citizens in the Philadelphia MSA, the FDIC specifically concluded that
“the distribution of HMDA loans reflects excellent penetration to borrowers of different income level”
and that “the geographic distribution of HMDA loans reflects excellent penetration throughout the
area.”
Part of our success in serving the LMI community is attributable to our retail branch network. Citizens
has the highest concentration of branches in Philadelphia with 54 locations. Of those locations, 16, or
nearly 30%, are in low- or moderate-income census tracts, and an additional 13 branch facilities are
located within 1,000 feet of an LMI census tract, which positions Citizens well to serve the banking
needs of the residents of the LMI community.
We believe that our partnerships with local community organizations and leaders are another key
contributing factor to our success. Citizens Bank understands that a good bank is at the heart of a
community, and that investing in our communities enriches us all. That’s why we partner with local nonprofit organizations to build vital connections to help communities prosper. Organizations that we work
with participate in a variety of community-building activities, including: helping individuals find
affordable housing, workforce development, financial education, neighborhood revitalization and small
business technical assistance.
We partner with these organizations in several ways including: board or committee participation;
providing volunteer financial education instructors; colleague engagement in their programs as
panelists, subject matter experts and financial coaches.
For more than 10 years we have had a robust financial literacy program in Philadelphia where colleagues
have conducted financial education workshops throughout the city. Citizens Bank colleagues support
and participate in a variety of financial education initiatives in Philadelphia, including but not limited to,
partnerships with Philadelphia Works and the School District of Philadelphia as well as first-time home
buyer workshops with various organizations.
Our charitable contributions consist of program support in four specific areas that fortify the economic
vitality of our neighborhoods: fighting hunger, teaching money management, strengthening
communities and volunteerism. Our signature initiatives include:


Champions in Action – Since 2004, Citizens has awarded approximately $1.2 million to 43
organizations in the Greater Philadelphia area through Champions in Action, a unique initiative
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 



designed to provide financial, volunteer and promotional support for nonprofit organizations
that are addressing the needs and social challenges of our diverse neighborhoods. In
Philadelphia, we’ve partnered with NBC10/Telemundo62 and Philadelphia Media Network on
the program. In 2017, two $35,000 awards were made to Interim House and Lutheran
Settlement House.
Citizens Helping Citizens Manage Money – In 2017, Citizens Bank awarded $225,000 to 11
nonprofits in Pennsylvania, New Jersey and Delaware as part of the Citizens Helping Citizens
Manage Money initiative. Citizens’ multi-faceted financial education program leverages the
financial planning expertise of its bankers and its partnerships with local nonprofits focused on
financial education. These organizations received a contribution in recognition of and to further
support their commitments to teaching youth and adults about financial literacy and the
importance of managing money effectively.
Phans Feeding Families – Citizens Bank has partnered with The Philadelphia Phillies in the Phans
Feeding Families program since 2010. This initiative raises money and collects food to feed the
nearly one million people in the Delaware Valley that are at risk of hunger. In 2017, Citizens
Bank donated $40,000 to the cause, with proceeds benefiting Philabundance, the region’s
largest hunger relief organization. Additionally, through a colleague-funded giving campaign,
Citizens Bank colleagues donated an additional $30,000 of funds to Philabundance in 2017, for a
total contribution of $70,000.

Activities that have occurred in FY 2017 are identified in Attachment B.
HMDA DATA DOES NOT PROVIDE SUFFICIENT DATA TO MAKE A DETERMINATION REGARDING FAIR
LENDING
The Center for Investigative Reporting issued a report on February 15, 2018 (the “CIR Report”) that has
formed the basis for this hearing. In brief, the CIR Report said that it had analyzed Home Mortgage
Disclosure Act (“HMDA”) data in 61 metro areas, including Philadelphia, which showed that African
Americans and Hispanics were denied conventional mortgage loans at rates higher than Whites. The CIR
Report also concluded that a higher percentage of those minority groups generally, and those minorities
who were in the low- to moderate-income category in particular, were given higher cost loans than their
White counterparts.
HMDA data, by itself, does not tell the full story when it comes to the basis on which mortgage lenders
make their credit decisions. The shortcomings of HMDA and its regulations have been highlighted for
many years by political leaders, federal and state regulators, consumer groups, academics, and even
lenders. For example, in an article published in the Federal Reserve Bulletin in November 2017,
summarizing the results of the 2016 HMDA data on residential mortgage lending, the 3 economists who
authored the article had this to say about HMDA:
“Previous research experience gained in the fair lending enforcement process show that
differences in denial rates and in the incidence of higher-priced lending among racial or
ethnic groups stem, at least in part from factors related to credit risk that are not
available in the HMDA data, such as credit history (including credit scores), ratio of total
debt service payments to income (DTI), and LTV ratios.”
As noted above, the CIR Report could only work with publicly available HMDA data such as income and
loan amount. While these are important factors, the reality is that mortgage lenders make their credit
decisions by considering a great number of factors that are equally essential in loan underwriting, but
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 which are not part of the publicly available HMDA data. These additional factors include such critical
items as the applicant’s credit history (e.g., credit score) and debt-to-income ratio, as well as the interest
rate, total loan costs and loan-to-value ratio for the proposed loan.
The inadequacy of the publicly available data resulted in a significant amendment of HMDA by the
Dodd-Frank Act in 2010. As mandated by Dodd-Frank, the Consumer Financial Protection Bureau, or
CFPB, made wholesale amendments to the HMDA rules so that regulators, consumer groups, lenders
and other interested parties will be able to use the new HMDA data to make a more in-depth
assessment and comparison of a lender’s lending record.
The revised HMDA regulations now include not just the data points mentioned above, but such things as
discount points, lender credits, the property value, any prepayment penalty, the term of the loan and
any introductory interest rate for the loan, the origination channel, and the rate spread on the loan (i.e.,
the difference between the APR associated with the loan and a benchmark rate for all loans). The new
HMDA rules require 25 new data elements for a total of 48 data fields. Many of these additional data
points are among those that some lenders have shared with their regulators over the years when
undergoing fair lending exams but, until the new HMDA regulations became effective, could not be
shared with the public for privacy reasons.
CITIZENS BANK’S INTERNAL FAIR LENDING ANALYSIS
Citizens Bank maintains a robust Fair Lending Compliance program that includes statistically based
analyses for various Fair Lending risks. The bank conducts periodic analyses that compare the bank’s
performance relative to peers and branch coverage in minority neighborhoods of its footprint, including
Philadelphia. In addition, the bank’s Fair Lending program evaluates loan pricing and underwriting with
periodic statistical analyses and loan-level file reviews. Citizens Bank has undergone regulatory exams
for Fair Lending by both OCC and the CFPB. Management is committed to ensuring that all customers
are treated fairly and equitably.

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 ATTACHMENT A


Destination Home Loan Program – This program offers eligible, prospective homeowners an
opportunity to buy and sustain a home with a minimal down payment and a low-monthly mortgage
payment. The flexible terms, absence of mortgage insurance (PMI) and subsidized pricing have
allowed various borrowers to qualify for a mortgage when they otherwise may not have been able
to do so.



The Citizens Bank Closing Cost/Down Payment Assistance Program provides first-time homebuyers,
specifically low- and moderate-income borrowers and/or property located in a low- or moderateincome census tract with grant funds (no lien on property or repayment required) to be used toward
down payment and/or closing costs.



The Agency HARP (Home Affordable Refinance Program) assists borrowers who have a Fannie Mae
or Freddie Mac-owned loan and have been unable to refinance due to a decline in home prices
and/or non-availability of mortgage insurance coverage.



My Community Mortgage (MCM) helps to serve low- and moderate-income borrowers with flexible
terms and options. MCM is an affordable product with little or no cash required at closing, and
lower mortgage insurance requirements. Borrowers are subject to maximum income limitations.



Fannie Mae HomeReady helps to serve low- and moderate-income borrowers with flexible terms
and options. HomeReady is an affordable product with little or no cash required at closing, and
lower mortgage insurance requirements. Borrowers are subject to maximum income limitations.
Can be used in conjunction with the Citizens Bank Closing Cost/Down Payment Assistance Program.



Pennsylvania Housing Finance Agency (PHFA) programs feature a below-market interest rate and
low down-payment requirements. Borrowers are required to be first-time homebuyers as defined
by PHFA Sellers Guide, except in those cases where PHFA will waive such a requirement if the
borrower is purchasing in a targeted area as further defined by PHFA. This versatile product offering
has terms ranging from 5 to 30 years and can assume the first- or second- lien position.



The K424 Keystone Home Loan FHA features below- market interest rate, maximum 96.5% LTV
plus financed UFMIP (the total of which must not exceed 100% of appraised value) on plan 424 and
ability to submit loan through Desktop Underwriting.



Fannie Mae Loan Product is used in support of ongoing efforts to expand access to credit and
support sustainable homeownership, Fannie Mae offered > 95% to 97% LTV/CLTV/HCLTV
financing to help home buyers who would otherwise qualify for a mortgage but may not have
the resources for a larger down-payment, and to support refinance of existing Fannie Mae
mortgage loans.



Citizens Bank of Pennsylvania participated in the Federal Housing Administration (FHA) Fixed Rate
Plans – 214, 216 and 296 and the Veterans Administration (VA) Fixed Rate Loan Program – 215, 217
and 219.
o
o

15 Year Term (only) FHA Fixed Rate Conforming “Standard” Loan
20 to 30 Year Term FHA Fixed Rate Conforming “Standard” Loan
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 o


30 Year Term (only) FHA Fixed Rate High Balance Loan

The VA Loan is designed to offer long-term financing to eligible American veterans or their surviving
spouses. VA Loans are often made without any upfront payment(s) and frequently offer lower
interest rates than are typically available with other types of loans.

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 ATTACHMENT B
Affordable Housing Centers of Pennsylvania
A homebuyer workshop was conducted for first-time homebuyers.
Back On My Feet
A financial education workshop was conducted in partnership with the Urban Affairs Coalition.
Ceiba
Citizens Bank colleagues provided assistance at Ceiba’s VITA site during the 2017 tax season as well as a
mortgage workshop in 4th Q 2017.
City of Philadelphia
A financial education workshop was conducted at the Pelbano Recreation Center for members of the
community.
A Citizens Bank colleague participated in the City of Philadelphia/Entrepreneur Event at the PA
Convention Center providing Small Business financial education.
Clarifi
Citizens Bank colleagues participated in Clarifi’s Financial Coach Program providing support to Clarifi
clients to achieve their financial goals and reduce debt and two first-time home buyer workshops.
Coalition of Black Trade Unionists
A homebuyer financial education workshop was conducted and co-hosted by the Pennsylvania General
Assembly.
Delta Sigma Theta Sorority
Citizens Bank colleagues participated in the Juanita Kidd Stout Finance Conference in partnership with
Delta Sigma Theta Sorority, providing financial and homebuyer expertise.
District 1199C
Financial education support was provided to healthcare union employees.
Diversified Community Services
A series of financial education workshops were conducted for Diversified Community Services.
Educational Advocates Reaching Today’s Hardworking Students, Inc.
A financial education workshop was conducted for students at T.M. Pierce Elementary School.
El Centro de Estudiantes "Big Picture" High School
A financial education workshop and tour of the branch were provided to students in partnership with
the Urban Affairs Coalition.
Enterprise Center
Citizens Bank colleagues provided financial expertise to the Enterprise Center’s ScaleUp Philadelphia
Program as well as a series of financial education workshops in partnership with the Enterprise Center
and the Free Library of Philadelphia.
Entrepreneur Works
Citizens Bank colleagues presented a Small Business workshop to Entrepreneur Works.
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 Finanta
Financial education workshops for small business owners were held in partnership with Finanta.
Greatness Center of Philly
Financial education workshops for consumers were held.
Golden Slipper Senior Center
A Citizens Bank colleague provided elder adult financial education at the Golden Slipper Senior Center.
High School of the Future
Financial Education sessions were presented to the Community in partnership with State Senator
Vincent Hughes.
Junior Achievement of Southern Pennsylvania
Citizens Bank colleagues provided a JA Day of financial education to elementary students at Kenderton
Elementary School and Bethune Elementary School in partnership with Junior Achievement of
Southeastern PA.
Lendistry
Citizens Bank colleagues participated in a Small Business Access to Capital event in partnership with
Lendistry.
PA House of Representatives
A Small Business roundtable was conducted at Ezekiel Baptist Church in partnership with the PA House
of Representatives.
Penn Homeownership Services
A homebuyer workshop was provided in partnership with the Urban Affairs Coalition.
Philadelphia Head Start Partnership
Financial education workshops were provided to Philadelphia Head Start Partnership in partnership with
the Urban Affairs Coalition. Philadelphia Head Start Partnership is a program of the Public Health
Management Corporation.
Philadelphia Outreach Development Council
A financial education workshop was conducted for Philadelphia Outreach Development Council.
Philadelphia Works CareerLinks
Citizens Bank colleagues provided ongoing financial education to Philadelphia Works’ Esperanza
CareerLink and Germantown CareerLink to participants interested in finding employment or
transitioning into another career.
Pinn Memorial Baptist Church
Financial education was provided to members of the congregation and community at Pinn Memorial
Baptist Church.
Regular Fellows Foundation
Financial education was provided during 4th quarter of 2017.
Roxborough Academy
A Citizens Bank colleague provided workshops on Credit to parents on “Freshman Orientation Day.”
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 School District of Philadelphia
Citizens Bank colleagues participated in a series of financial education workshops in Philadelphia high
schools in partnership with the School District of Philadelphia in celebration of Financial Literacy Month.
Score Association
Eight sessions of financial education coaching were provided to small business owners in 2017.
Southwest CDC
A homebuyer workshop was conducted for Southwest CDC first-time homebuyers.
Special People of the Northeast
A financial education workshop was presented in the fourth quarter of 2017.
Teenshop, Inc.
Financial education support was provided to Teen Works, Inc. teenage girls.
University of Pennsylvania
A workshop on Managing the Homebuying Process was presented in partnership with the Urban Affairs
Coalition.
Uplift Solutions
Financial education workshops were conducted in partnership with Uplift Solutions at Enon Tabernacle
Church.
Urban Affairs Coalition
A financial education session was presented at the United Communities Houston Center in Partnership
with the Urban Affairs Coalition.
Urban League of Philadelphia
A homebuyer workshop was conducted for first-time homebuyers.
West Philadelphia Cultural Alliance
Financial education was provided to West Philadelphia Cultural Alliance.

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