:hi:
Office of the Comptroller of the Currency
Attn: Comptroller John D. Hawke, Jr., et al.
250 E Street, SW, Washington, DC 20219
Re: Timely Comment in Opposition to, and Requesting an Evidentiary Hearing on, the Applications of PNC Financial Services Group, Inc. & PNC Bancorp, Inc., to acquire Riggs National Corporation & Riggs Bank NA National Association
Dear Mr. Chairman, Governors, Secretary Johnson, OCC, FRB:
On behalf of Inner City Press/Community on the Move and its members and affiliates, and the Fair Finance Watch (collectively, "ICP"), this is a timely comment opposing, and requesting an extension of the comment period and an evidentiary hearing on, the Applications of PNC Financial Services Group, Inc., PNC Bancorp, Inc. and their affiliates (on- and off-balance sheet, collectively "PNC") to acquire Riggs National Corporation, Riggs Bank National Association and their various on- and offshore affiliates (collectively, "Riggs").
In this application,
a bank that is essentially an international crime scene is proposed to be acquired by a regional bank with little to no international banking experience, with serious recent managerial problems, with worsening lending disparities and which, ICP emphasizes for purpose of its hearing request, funds and enables major nationwide payday lenders such as Check n’ Go a/k/a CNG Financial Corporation, including Check n’ Go of Washington D.C., Inc. (see annexed UCC filing from the District of Columbia Department of Finance and Revenue).
Beyond PNC’s direct support for predatory lending, ICP has reviewed PNC's lending record based on just-released 2003 data and below sets forth troubling disparities therein. However, it should first be emphasized how inappropriate a buyer for troubled Riggs PNC is, as a bank holding company that so recently engaged in accounting fraud, and been subject to a deferred prosecution agreement with the U.S. Department of Justice. The Associated Press on July 17, 2004, "Riggs, a troubled bank for diplomats, sold," by Marcy Gordon, reported that PNC "has also had regulatory problems of its own. In June 2003, a PNC subsidiary agreed to pay $90 million in restitution and $25 million in fines to settle allegations of securities violations. The subsidiary was accused of conspiracy to violate federal securities laws by transferring $762 million in troubled loans and investments to off-balance-sheet entities."
The Financial Times of July 17, 2004, reported that "the investigations are far from over. A grand jury is looking into the bank's dealings with Equatorial Guinea, which could lead to criminal charges, and the Senate committee on governmental affairs is conducting a separate investigation into more than 150 accounts associated with Saudi Arabia. Even that may not be the end of it. According to Senate investigators, some 85 per cent of Riggs' 15,000 embassy and international private banking accounts - the core of its overseas business - had significant problems with documentation."
ICP’s recent research finds for example that Riggs served -- or serves -- as correspondent for, among others, Bank of Sierra Leone, Sierra Leone Commercial Bank Ltd, Energobank of Bishkek, Kyrgyzstan, Banco de Cabo Verde, Banco Internacional SA, and others. See attached, which includes a listing of account numbers.
....
http://www.innercitypress.org/finwatch.html(lots more there--must read for anybody following the new BCCI)
And yes, interesting that they turned down a better offer to keep it in the crime family (Tres. Sec. Snow's connections especially).