Dear Secretary Johnson, and Governors of the FRB:
On behalf of Inner City Press/Community on the Move and its members and affiliates, and the Fair Finance Watch (collectively, "ICP"), and in connection with the applications of PNC Financial Services Group, Inc., PNC Bancorp, Inc. and their affiliates to acquire Riggs National Corporation and Riggs Bank National Association, this is a second timely comment, including a formal request that Chairman Greenspan recuse himself from the PNC - Riggs proceeding. It should first be noted that since ICP's first comment, the Washington Post of August 21, 2004, has reported on the widening criminal investigation of Riggs. "The Post's Saturday story, citing a letter to federal bank regulators from the District of Columbia's U.S. attorney's office, said the investigation includes Joe Albritton, Riggs' largest shareholder, his wife, Barbara, and son, Robert, who is chairman of Riggs... A lengthy probe could affect the company's pending acquisition by PNC Financial Services (PNC) for $779 million. The deal was announced in mid-July. Riggs has already paid a $25 million civil penalty to the U.S. Comptroller of the Currency over allegations that its Riggs Bank laundered money for Saudi Arabian diplomats." CBS MarketWatch, August 21, 2004.
This development further calls into question the wisdom of considering allowing the sale of Riggs at this time, until the investigations, including into terrorism-related money laundering, are completed. A sale to a bank with a troubled compliance record like PNC's, which also funds high-cost payday lenders including in the target bank's market, would be particularly unwise and harmful.
Unless PNC's Riggs application is withdrawn or dismissed forthwith, ICP contends that chairman Greenspan should be recused from involvement in this proceeding. Those involved in decision-making on Bank Holding Company Act applications, particularly one of this import, need to be impartial, and to be seen to be impartial. In April 2004, PNC awarded chairman Greenspan's wife $50,000. At the time, industry publications questioned the propriety of the award, to the spouse of PNC's chief regulator. See, e.g., American Banker newspaper of March 24, 2004, Pg. 3, "Earth to PNC" -
"Corporate America's ethics have come under considerable scrutiny in recent years for obvious reasons, so it's no surprise PNC Financial Services Group Inc.'s decision to present a $50,000 prize to the spouse of its top regulator would raise eyebrows. PNC is promoting a black-tie awards ceremony, scheduled for April 24 in Wilmington, Del., at which it will present five high achievers with the 2004 Common Wealth Awards. The winners are the actor Christopher Reeve, the Chilean author Isabel Allende, actress Meryl Streep, scientist Stanley Prusiner and Andrea Mitchell -- the chief foreign affairs correspondent for NBC News and the wife of Federal Reserve Board Chairman Alan Greenspan. The awards are given by the trust of Ralph Hayes, who sat on the board of PNC predecessors from 1943 until 1965. PNC is the administrator of the Hayes trust....
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