Bank of America Branch Closure Challenge Letter
Dear Comptroller Noreika,

The Maryland Consumer Rights Coalition (MCRC) is a statewide coalition that advances economic inclusion and financial justice through research, advocacy, consumer education, and direct service. Our 8,500 supporters include consumer advocates, practitioners, and low-income and working families throughout Maryland.

Bank of America has filed paperwork announcing its intention to close its Reisterstown Plaza branch at 6538 Reisterstown Rd, Baltimore, MD 21215. This branch is located in a moderate-income community in Northwest Baltimore. The community is 92.5% minority and 34.3% of the population lives below the poverty line. The branch held $99,161,000 in deposits as of June 30, 2016. This is a 223.5% increase over the deposits held at this branch in 2011, indicating that this branch has grown in importance to the community in recent years. Once this branch closes on September 12, 2017, the nearest Bank of America branch for area consumers will be 4.2 miles away – a considerable distance in a City with limited public transit.

Bank of America consistently holds approximately 40% of the deposits in Baltimore City and has been Baltimore’s leading deposit holder for more than a decade. Since 2006, Bank of America has closed eight of its full-service branches. That accounts for a third of its branches in Baltimore City. Fifty-seven percent of the branches closed were located in low- and moderate-income census tracts. This is despite the fact that branches in moderate-income census tracts have had a 304% increase in deposits since 2006; deposits at branches in low-income census tracts have increased by 142% in the same time period.

Bank of America’s branch closures have also had a disparate impact on communities of color. The average minority population in census tracts where Bank of America has closed branches is 69%. The average minority population in census tracts where Bank of America maintains branches is 49%. Minorities make up 72% of Baltimore City’s population .

Under the Community Reinvestment Act, Bank of America has a continuing, affirmative obligation to serve the communities from which it takes deposits. As the leading deposit holder in Baltimore City, Bank of America must have a robust plan for meeting the banking needs of the entire community – especially those areas which wither from chronic economic disinvestment.

Therefore, we, the undersigned community members and organizations request a hearing to determine how the needs of the community will be served as Bank of America retreats from Baltimore neighborhoods.

Sincerely,

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