Good day.  My name is Conrad Egan and I am President and CEO of the National Housing Conference.  I would like to thank you for allowing me to present testimony supporting the proposed merger of Bank of America and FleetBoston Financial.

The National Housing Conference is the nation’s oldest affordable housing advocacy organization. NHC’s mission is to see that every American, regardless of income, has the opportunity to live in decent housing in a safe and stable neighborhood.  NHC, and its research affiliate, the Center for Housing Policy, have been at the forefront of efforts to broaden public awareness of the affordable housing shortage in this country especially the increasingly significant problem facing America’s working families.

National Housing Conference members are nationally known experts in affordable housing and housing finance, including state and local officials, nonprofit and for-profit community development specialists, builders, bankers, investors, insurers, owners, labor leaders, lawyers, architects and planners.

Bank of America and FleetBoston Financial are both major funders of and participants in NHC.  Bank of America has maintained a membership in NHC for nearly 10 years, and senior Bank officials have donated considerable time to the organization. In fact, NHC’s Immediate Past Chairman was the head of the Bank’s community development corporation.  It is not an overstatement to say that Bank of America’s sustained support has been critical to the organization.

NHC’s initiatives include groundbreaking research documenting housing needs.  For instance, one of our most recent studies, America's Working Families and the Housing Landscape, reveals that between 1997 and 2001 there was a staggering 67 percent rise in the number of working families spending more than half of their income on housing. The study also found that in 2001, approximately one in seven American households paid more than half their income for housing or lived in dilapidated conditions.  Most alarmingly, a growing proportion of these households were low- to moderate-income families working full-time jobs.  Our research is in many ways responsible for moving this issue to the forefront of public policy debate.

In addition, NHC focuses on reaching out to members of the business community to engage them in constructive conversation about local problems relating to housing affordability and community revitalization.  Bank of America was instrumental in helping NHC organize one such discussion in Charlotte, NC, last April.  Nearly 100 business and civic leaders and housing experts met to explore what programs appear to be addressing
community housing needs, what can be done to encourage these efforts and barriers that stand in the way of additional progress.  Meetings such as this one have been held around the country (with Bank of America and Fleet participants involved).  These meetings provide invaluable insight into emerging issues and help us to identify programs that show promise in meeting affordable housing needs.

However, Bank of America’s commitment and involvement extends well beyond NHC.  ACORN, Consumer Federation of America, The Enterprise Foundation, Local Initiatives Support Corporation, NAACP and National Council of LaRaza are just a few of the many groups that have received significant financial and technical assistance from Bank of America.  These collaborations are responsible for transforming communities across the country, supporting small businesses, creating jobs, improving consumer financial literacy and opportunity, and building affordable single and multifamily housing. 

The Bank’s community development corporation is a model for other financial institutions.  Since its inception more than twenty-five years ago, it has, in partnership with local groups and governments, created or helped to create more than one hundred thousand affordable housing units representing an equity investment of more than $2.5 billion.  In 2003, Banc of America CDC invested more than $600 million in community development equity in its franchise.  Today the Bank is the banking industry leader in investment volume/product in Low Income Housing Tax Credits, Historic Tax Credits, Community Development Financial Institutions and direct real estate development.

The Bank has invested more than $2 billion in Low Income Housing Tax Credit projects from coast to coast, making it one of the largest equity investors in rental housing for low- to moderate-income individuals and families.  Since 1999, the Bank has loaned or invested $230 billion in economic development, affordable housing and homeownership, small businesses and consumer loans to low- and moderate-income borrowers, and is thereby exceeding its $350 billion commitment over 10 years.

Bank of America also is the leader in scale and innovation for financing and investment for the nation’s Public Housing Authorities. 

Over the last 15 years, Bank of America has provided more than $500 million in funding to local authority initiatives conducted under state programs, which are without benefit of HUD funding.

The Bank has consistently demonstrated one of the nation’s deepest and broadest commitments to the future of public housing through its work with the HOPE VI program where it has provided debt financing, equity investments and development services to more than two dozen HOPE VI projects across its franchise.   Participation has been as lender, equity investor and as joint-venture developer.
                            
The Bank’s leading role as a public housing finance innovator was again demonstrated when it pioneered Capital Fund Program financing for public housing three years ago and last month closed a $693 million CFP financing for the Puerto Rico Public Housing Administration – the largest ever application of this Bank of America developed technique.

Bank of America is member in good standing with the San Francisco, Seattle, and Atlanta Federal Home Loan Bank’s.  The Bank is believed to be the largest participant in the Federal Home Loan Bank AHP program in the country and is very active in each of the three Federal Home Loan Bank regions. In 2002 and 2003, Bank of America had 105 winning AHP applications representing $51 million in AHP funding. Overall, the Bank has obtained AHP grants and loans resulting in more than 20,000 units of housing funded through the AHP Program.

 The AHP program is a critical component of the more than $2.2 billion in annual affordable housing lending by the Bank.

The Bank has a dedicated staff of professionals focused specifically on the AHP and other FHLB programs (including predevelopment lending, economic development and first time homebuyer assistance), which is part of why its success rate on AHP applications is well above the overall averages in Seattle, Atlanta and San Francisco. 

The Bank’s vision and leadership have been recognized by many groups.  In 1999, the Bank’s then Chairman and CEO Hugh McColl was named NHC’s Housing Person of the Year.  The National Alliance to End Homelessness, the Greenling Institute and Goodwill Industries are just a few of the other groups honoring the Bank for its affordable housing and community development achievements.  In 2002, President Bush recognized the Bank’s America/Works program, an initiative to move people from poverty to self-sufficiency.

Bank of America’s longstanding commitment to the communities it serves is exemplified by its recent announcement that it will lend and invest $750 billion for affordable housing and community development over the next decade.  The National Housing Conference believes that the unprecedented size of this goal, along with the Bank’s outstanding track record will create a greatly enhanced and expanded level of investment in Fleet’s markets.  For this reason, we support the merger of Bank of American and FleetBoston Financial.  I urge you to allow it to move forward.