To the Editor:

Vice President Al Gore did not invent the Internet, and Comptroller of the Currency John Hawke did not invent the shared branch for inner cities ["OCC Eyes Bank Consortiums to Serve the Inner-City Poor," Dec. 3, page 2].

Chapter 8, "A Shared Bank Branch CRA Compliance Strategy," in "The CRA Handbook" (McGraw-Hill, 1998) traces the roots of the concept back to Detroit credit unions in 1975. They used them mainly for suburban shopping center locations, since no one credit union could afford an expensive branch.

After considerable research on their experience, I proposed the generic shared branch for inner cities, almost identical to Mr. Hawke's recent proposal, in a February 1985 Savings Institutions magazine article. That and an earlier, unpublished research paper on this topic were forwarded to the Federal Reserve's Consumer Advisory Council in October 1986 and to the American Bankers Association's branch administration division in 1987.

Though neither of those groups expressed interest in pursuing the shared branch idea, former Comptroller Eugene Ludwig did, and he encouraged me to write about my experience in establishing such a pilot project to serve Miami's unbanked Overtown community. This article was published in the September 1997 OCC publication "Community Development: A Profitable Market Opportunity." In fact, the OCC was most supportive of my proposal for inner cities and even prepared a legal opinion on it.

I am delighted that Comptroller Hawke is resurrecting this proposal, and I stand ready to assist him on a pro bono basis in any way possible to make the shared bank branch a reality.

Kenneth H. Thomas
Lecturer in Finance, Wharton School
of the University of Pennsylvania

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