A Letter to Councilman Kenyatta Johnson

March 29, 2018 - Lending Our Communities New Jersey, New York and PA

This is a reprint of a letter sent to Councilman Johnson regarding his hearing on racial disparities in home lending. View a PDF of the letter here.

Dear Councilman Johnson,

Thank you for inviting us to join the March 29 public hearing on racial disparities in home lending. While we respectfully decline your invitation, we are writing to share our perspective and to say that we would welcome future opportunities to work collaboratively with you and other community leaders in Philadelphia to address this important industry-wide issue.

By way of context, the public hearing was scheduled after a recent article disclosed information from the Reveal Center for Investigative Reporting (Reveal). While we agree that racial disparities in home lending warrant review and consideration, we believe that the role banks play in the mortgage market, and the rules that govern that market, were not accurately represented by Reveal. We have attached to this letter the analysis released by the American Bankers Association, which explains some of the factual issues and limitations in Reveal's reporting.

As we have repeatedly affirmed, we, at TD Bank, do not consider race, ethnicity, religion, gender identity, sexual orientation or membership in any other protected class in our loan underwriting process or in any other product or service offering. In fact, the 2016 public data on our conventional purchase lending shows that Black applicants were more likely than their non-Hispanic White counterparts to receive loan approvals at TD Bank than at other financial institutions in Philadelphia (using the industry standard odds ratio).

TD Bank lends money with the confidence that customers will be able to repay their loans, decreasing the likelihood that a homeowner will become delinquent and/or face foreclosure. At the time of application, we are required to evaluate each customer's financial information in accordance with banking regulations and our own credit-based standards. Unlike other financial institutions, TD Bank does not screen and turn away checking account applicants based on prior history at other institutions, making our products accessible to more people, including consumers who have experienced charge-offs at other banks and need a second chance. To help our customers achieve their financial goals, such as owning a home, we also offer financial education to a diverse population of consumers, which includes working with nonprofit organizations like the Philadelphia-based Clarifi and the Urban Affairs Coalition to help people manage their personal finances.

In short, TD Bank remains fully committed to offering the financial access, resources and education our customers need to overcome obstacles, improve their credit profiles and achieve their financial goals, across all of our diverse communities. 

This commitment reflects a long-standing tradition of active community support. In Philadelphia, 16.7 percent of our stores are located in majority-minority areas; and two stores serve customers located in Chester, West Oak Lane and Mount Airy. In 2017, TD Bank added seven new deposit-taking ATMs in Philadelphia, in neighborhoods with a majority of Black residents.

Through the TD Bank Foundation, we made contributions in excess of $4.19 million from 2015 to 2017 to the Philadelphia metro area, with a goal of strengthening neighborhoods and creating economic opportunities across the diverse communities we proudly serve.

Thank you, again, for reaching out to us about this vital industry-wide issue.  

Best regards,

Paige Carlson-Heim

Regional Community Development Manager


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