Dear Editor: We, the undersigned members of the Hudson County Board of Chosen Freeholders make this a timely comment opposing Hudson United Bancorp’s application to merge with Dime Bancorp, Inc., New York and Dime Bancorp, Inc.’s application to become a bank holding company in connection with the proposed merger of Hudson United Bancorp with and into Dime. The regulations states that financial institutions have continuing and affirmative obligations to help meet the needs of the local communities in which they are chartered. We, as elected officials, based upon information provided to us by New Jersey Citizen Action, believe that Hudson United Bank has not met the credit needs of communities in their assessment areas, especially in the Newark and Jersey City MSAs. New Jersey Citizen Action has reviewed the 1998 Home Mortgage Disclosure Act (HMDA) data for Hudson United and has found disparities in lending to minorities (particularly African-Americans) in both Newark and Jersey City MSAs. In 1998, Hudson United made 23 Conventional Home Purchase Loans in the Jersey City MSA, None of these loans were made to African-Americans and none of them were made to low-income earners. In that same year, in the Newark MSA, 64 Home Purchase Loans were made, and only one such loan was made to an African-American. Two loans were made to low-income earners. In 1998, Hudson United made 22 Home Refinance Loans in the Jersey City MSA; none of these loans were made to African-Americans or to low or moderate income borrowers. Of the 93 Home Refinance Loans made in the Newark MSA, only one was made to an African-American borrower. Hudson United’s lending to African-American borrowers in these two MSAs compares unfavorably with lending records of aggregate banks in these areas in 1998. Six percent of Home Purchase Loans by all lenders went to African-Americans in Newark, while only 1.6 percent of Hudson United’s mortgages were made to that population; 7 percent of all banks’ loans to refinance in 1998 went to African-Americans, while only 1.1 percent of Hudson United’s refinance loans were made to that population. In Jersey City, all banks loaned 5 percent and 5.8 percent for Home Purchase and Refinance, respectively, to African-Americans, while Hudson United’s statistics in the same categories for the same population were a flat zero percent. In the wake of this newest merger, HUBCO and Dime have announced a multi-state $2.5 billion pledge that is totally undefined, by state or product. Why should we believe that a new $2.5 billion pledge will find its way to New Jersey’s minority and low-income citizens when HUBCO has failed to live up to previous pledges it has made? Additionally, the bank has refused to provide specifically requested information regarding the past pledges and has refused to discuss ways to remediate the problems caused by their poor lending record. HUBCO made a previous pledge to make $35 million in loans to small businesses. A special focus was to be made to “assist minority and women-owned small business enterprises.” The bank has refused to provide the geographic area or the amounts of these loans. Also, no breakdown is provided on the types of small business loans they made. Additionally, HUBCO pledged to lend $5 million in construction loans to non-profits. The bank has not provided the amounts of the loans they made to these non-profits. New Jersey Citizen Action brought these concerns to the attention of Hudson United Bank repeatedly over the last four months. They have flatly refused to sit down with them to address the problems they are having meeting their own goals. We can only assume that Hudson United Bank — which has its corporate roots in the County of Hudson – is not making a good faith effort to correct an abysmal lending record to African-Americans in Newark or Jersey City MSAs, and is not interested in following through on their pledge. We challenge any merger between Hudson United Bank and The Dime Savings Bank at this time, and we request that a public hearing be held before approval is given. We are also requesting an additional 60 days be granted for the submission of comments due to the preceding holiday season and HUBCO’s failure to provide New Jersey Citizen Action with the requested data. We will be presenting a resolution to the entire freeholder board at its next meeting, requesting the same as well as asking that the county investigate divesting any funds currently deposited in Hudson United Bank. If you have any questions, please call either of the undersigned at 201-795-6001. William C. Braker, Hudson County Freeholder Chairperson Pro Tempore, District 3 William O’Dea, Hudson County Freeholder, District 2