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Prepared by the
as Vegas Foreclosure Task ForceOctober 2011
Deutsche Bankand the Las Ve asForeclosure Crisis
g
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3 Executive Summary
5 Our Campaign
6 Devastating our Neighborhoods
7 Mapping Deutsche Banks Real Estate Owned
8 Deutsche Bank Comes to Your Neighborhood
10 Building the Housing Bubble
11 Benefitting from the Bailout
12 Evading Financial Reform
13 Demanding Accountability
14 Notes
Contents
2 Las Vegas Foreclosure Task Force
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The Las Vegas Foreclosure Task Force is a coalition
o community, labor, and aith-based organizations
n southern Nevada who care about the impact o
oreclosures on our neighborhoods and are standing
up or our communities.This report provides an
analysis o Deutsche Banks role in the Las Vegas
housing and fnancial crises. As a major stakeholder
n the Las Vegas Valley and a large benefciary o
US taxpayer bailout dollars, Deutsche Bank should
be held responsible or its actions in our community.
Key fndings o the report include:
Deutsche Bank is devastating Las Vegas neighborhoods
and lacks local accountability.
Deutsche Bank owns over 500 houses in Clark
County, Nevada. The Las Vegas Foreclosure Task
force has surveyed over 250 of these houses, and
many are vacant, abandoned and dilapidated.
Some of Deutsche Banks houses had garbage, dead
vegetation, graffiti and boarded up windows. Others
contained animal carcasses, exposed wires, broken
glass, and rancid pools. Such houses may violate
local housing codes and also pose serious threats to
neighborhood and youth safety.
The foreclosure crisis is having a devastating impact
on Las Vegas neighborhoods, and Deutsche Bank
continues to contribute to the problem. As a result
of falling property values, Las Vegas residents face
painful budget cuts and increased crime and safety
issues.
Deutsche Bank is a major stakeholder and employ
in Las Vegas. Yet Deutsche has neither establishe
Las Vegas home loan modification centers nor ma
all necessary repairs to bank owned properties.
Deutsche Bank has moved in the opposite directio
by (unsuccessfully) challenging the constitutionalit
of Nevadas Foreclosure Mediation Program.
Deutsche Bank helped build the housing bubble and
benefted rom a US taxpayer-fnanced bailout.
Deutsche Bank was a central contributor to the
housing bubble, and to its collapse. Deutsche
Bank originated subprime and At-A mortgage loans
and packaged these mortgage loans into complex
financial products called Collateralized Debt
Obligations (CDOs). Deutsche Bank also created
financial derivatives which also allowed institution
investors and the bank itself to bet against the veCDO securities it was creating and selling.
When the housing bubble burst, the US governmen
was forced to intervene to stabilize the financial
system. Deutsche Bank became a major beneficia
of Federal Reserve programs to stabilize the shaky
financial system. Deutsche Bank benefited from
$11.8 billion from the US taxpayer-financed AIG
bailout and $2 billion in emergency low-cost funds
made available by the Federal Reserve.
Executive Summary
Continued on next p
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Deutsche Bank is attempting to evade new Dodd-Frank
fnancial regulations that may mitigate uture housing
and fnancial crises.
In July 2010, the Dodd-Frank Wall Street Reform
and Consumer Protection Act was signed into law,
with the express purpose of reducing systemic risk,
increasing transparency and promoting integrity in
the financial system. Many of the Dodd-Frank rules
have yet to be written by federal agencies.
Deutsche Bank is attempting to circumvent capital
requirements under Dodd-Frank while holding onto
substantial US tax benefits. Under Dodd-Franks
Collins Amendment, Deutsche Bank could be
required to inject as much as $20 billion to its US
bank holding company, Taunus Corporation. But
instead of raising the capital needed to comply
with the law, the bank has decided to restructureTaunus in order to avoid the new rule altogether.
Restructuring executed solely to circumvent new
capital requirements undermines the intent of the
Dodd-Frank Act to reduce systemic risk.
The Las Vegas Foreclosure Task Force calls on
Deutsche Bank to take a comprehensive approach
o mitigating the oreclosure crisis, both locally and
ationally. Our demands include:
Responsible Foreclosure Process. In order
to ensure a responsible, fair and accessible
foreclosure process for homeowners, Deutsche
Bank should require its servicers to open loan
modification centers in southern Nevada and
identify local representatives to make necessary
repairs on Deutsche Bank owned properties.
Rehabilitation Fund. We call on Deutsche Bank
to contribute $25 million to a Rehabilitation Fund
which will be used to purchase, rehabilitate and
resell properties in concentrated areas.
Vigorous Action as Trustee. We call on Deutsche
Bank to aggressively pursue its responsibilities as
trustee of dozens of mortgage trusts to maximize
investor returns by pursuing loan modifications
when warranted. Deutsche Bank should use its
trustee authority to either require servicers to entein to modification agreements with homeowners or
replace those servicers with other servicers who
will act in the best interest of the trust.
Financial Reorm. We call on Deutsche Bank to
abandon its plan to evade new rules requiring
additional capital at its US holding company.
Executive Summary continued
4 Las Vegas Foreclosure Task Force
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Las Vegas has been devastated by the economic
crisis and the downturn in the housing market.
n act, Clark County has the highest density o
oreclosures in the country and has been called
ground zero o the housing and fnancial crises.1
The Las Vegas Foreclosure Task Forcea consortium
f community, labor and faith-based organizations that
epresent Las Vegas residentsis launching a campaign
o hold Deutsche Bank, a Frankfurt, Germany-based bank,
ccountable to our community.
hrough our research, we have learned that Deutsche
Bank owns over 500 houses in the Las Vegas
alley. We surveyed over 250 Deutsche Bank owned
properties. Many of these properties are dilapidated,
acant and abandoned. These properties cause
remendous problems for our neighborhoods: safety
ssues for citizens, neighborhood deterioration, andecreased property values. As a result, local authorities
re spending taxpayer dollars on additional building
nspections, as well as fire and police services.
As a major owner of casino companies, Deutsche Bank
s an important stakeholder and employer in Las Vegas.
With significant, potentially long term investments in
he Las Vegas gaming industry, Deutsche Bank has a
esponsibility to be accountable to local communities.
Yet Deutsche Bank has neither established Las
Vegas home loan modifcation centers nor made all
ecessary repairs to bank owned properties. Indeed,
Deutsche has moved in the opposite direction by
unsuccessfully) challenging the constitutionality of
Nevadas Foreclosure Mediation Program, a process
in which lenders and homeowners can meet in person
and exchange proposals to avoid foreclosure and keep
families in their homes.2
We view this situation as unacceptable. Deutsche Ban
is a global bank that had a hand in producing the hous
crisis and also received rom an $11.8 billion payout
a part of the US taxpayer-financed AIG bailout. The La
Vegas Foreclosure Task Force is committed to holding
Deutsche Bank accountable for its business practices
our neighborhoods.
Our Campaign
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Mapping Deutsche BanksReal Estate Owned
Source: RealtyTrac, June 2011
Figure 1:Deutsche Banks real
estate owned Figure Deutsche Banks re
estate owned per 10
single-family un
2005-2008 2008 2008 2008-2010
Deutsche Bank
participates in
Federal Reserve
Board programs to
provide low
interest loa
buy toxic
assets, an
stabilize th
system.
Deutsche
Bank is
identified as the
largest owner of
foreclosed homes
in Kansas City.
Deutsche Bank receives
$11.8 billion of taxpayer
bailout money through
AIG counterparty
contracts.
eutsche Bank
cts as sponsor for
ver $150 billion
n total mortgage
ecurities and
s underwriter
or over
105 billion
n mortgage
ecurities. 32
Timeline:DeutscheBanksRecord
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In 2008, Deutsche Bank was the largest
owner of foreclosed properties in Kansas
City. According to the local Legal Aid society,
Deutsche Bank had allowed many properties
to fall into disrepair. The Legal Aid society sent
letters to Deutsche Bank demanding some
attention to the community.13
In 2011, Deutsche Bank sued to
stop a Nevada program aimed at
keepingNevada borrowers in their
homes. In August, a Nevada judge
ruled against Deutsche Bank to
uphold the program. As of
September 15, Deutsche Bank has
not appealed the decision.22
In 2011, the City ofLos Angeles reportedlyfiled suit against Deutsche Bank for allegedly
being one of the major slumlords in the
city.21 Deutsche Bank has denied the
allegations and claims that the case has been
filed against the wrong party. Deutsche
claims that as trustee rather than as a servicer
it is not contractually responsible for the
upkeep of foreclosed properties. As of
September 22, the case remains ongoing.
A Milwaukee community group has brou
attention to Deutsche Banks foreclosure
presence in Wisconsin. Milwaukee
representatives traveled to the Deutsche B
shareholder meeting last year and receive
commitment from the bank to help stabili
their neighborhoods.19
Deutsche Bank Comesto Your Neighborhood
The Las Vegas Foreclosure Task Force joins a chorus o voices rom around th
nation who are standing up to Deutsche Bank and demanding accountability.
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Las Vegas Foreclosure Task Force
In 2009, a Florida task force created by the Florida
Supreme Court identified Deutsche Bank as one of
the banks with the most foreclosures in its state. The
task force recommended that the Florida Supreme
Court address the explosion of foreclosures as soon
as possible for the welfare of our courts, our
communities, our businesses, and our state.14
In early 2010, Deutsche Bank was the large
owner of foreclosed homes in New Haven,
Connecticut. The bank has allowed many of
the properties to fall into disrepair.15 New
Haven community groups have organizedmeetings with Deutsche Bank representative
to protest the banks foreclosure practices.16
In July 2011, the New York Daily News identified
Deutsche Bank as the largest owner of foreclosed
homes in the City and, also, the owner of the most
homes with open code violations. In response, the
New York legislature has passed a law requiring
banks to maintain foreclosed properties before a
foreclosure auction.17
In Ohio, in 2007, a federal judge dismissed
several Deutsche Bank foreclosure cases
because the Bank lacked necessary
documentation.18 Deutsche Bank has not
appealed the decision.
In an effort to stem foreclosures, the cit
Providence enacted an ordinance to
require banks to take part in homeowne
mediation before foreclosing. Deutsche
Bank sued the city to rescind the ordina
In May 2010, a Rhode Island Superior
Court judge ruled against Deutsche Ban
Deutsche Bank has not appealed.
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Building the Housing Bubblehe financial crisis of 2008 was precipitated by a bubble
n the US housing market. In many areas, Deutsche Bank
was a central contributor to this housing bubble, and
o its collapse. Deutsche Bank, through subsidiaries,
riginated subprime and Alt-A mortgage loans, packaged
hese mortgage loans into complex financial products
alled Collateralized Debt Obligations (CDOs), and sold
hese CDOs, piecemeal, to investors. According to its
nancial statements, between 2005 and 2008, Deutsche
Bank packaged together over $150 billion in total
mortgage securities, and also, sold about $105 billion in
mortgages directly to investors.23
Deutsche Bank also created fnancial derivatives which
allowed institutional investors and the bank itsel to
bet against the very CDO securities it was creating and
elling. This practice magnified the effects of the crisis.24
When the mortgage bubble burst, the US government
was forced to intervene to stabilize the financial system.Deutsche Bank became a major beneficiary of Federal
Reserve programs to stabilize the shaky financial
ystem. In the years following the crisis, Deutsche, in
ts capacity as a trustee for the owners of the mortgage-
acked securities it sold to investors, has become
n increasing, if unwelcome and allegedly negligent,
presence in many
communities across
the United States.
In many of the
foreclosures, Deutsche
Bank was acting as the
trustee for investors
in mortgage pools. As
a trustee, Deutsche
Bank has a duty to
act in the interest of
those investors. Among the duties of the trustee is to
ensure that the underlying mortgages were properly
transferred to the mortgage trust and that the financial
institution sponsoring the trust has accurately describe
the mortgages so transferred. If a trustee discovers tha
mortgages were not properly transferred, for example,
it has a responsibility to compel the trust sponsor torepurchase those mortgages. Trustees also oversee th
mortgage servicers who process payments on behalf o
the trust. If the trustee determines that servicers have
been derelict in their contractual obligations to the trus
or have otherwise engaged in improper activity, it may b
able to terminate such servicers and bring in new ones
Deutsche Bank waspart of a CDO machine
run by investment banks that produced hundreds
of billions of high risk CDO securities.
US Senate Permanent Subcommittee on Investigations
Timeline:DeutscheBanksRecord
2008-2011 2010 2010 2011
City of Los Angeles
suit against Deutsc
Bank. Deutsche Ba
denies allegations.
of September
2011, the
case
is ongoing.
Deutsche
Bank is
identified as
the largest owner of
foreclosed homes in
New Haven, CT.
Securities Exchange
Commission reportedly
starts criminal probe into
Deutsches CDS
business.Multiple
investors file
separate suits
against Deutsche
for losses sustained
in mortgage backed
securities.
10 Las Vegas Foreclosure Task Force
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Timeline:DeutscheBanksRecord
2011 2011 2011 2011
The FederalHousing FinanceAgency files suitagainst DeutscheBank for allegedlymisrepresenting the quof mortgages they sold Fannie Mae and FreddieMac during the housingbubble. No response tosuit has yet been filed.
Deutsche Bank lobbies
Commodities Futures
Trading Commission
and other
government
bodies on
derivatives
rules.
Wall Street Journal
Reports that
Deutsche Bank
tries to maneuver
around Dodd
Frank regulations
intended to ensure the
stability and integrity of
the financial system.
S Attorney files suitgainst Deutsche andortgageIT. Deutscheank files motiondismiss. As of
eptember 2011, theS Attorney files anmended and expandedomplaint. These is ongoing.
Benefitting from the BailoutWhen the mortgage market crashed, Deutsche
Bank was a major benefciary o US taxpayer
support meant to stabilize the fnancial system.
Specifcally:
As one of the largest counterparties of failed insurer
AIG, Deutsche Bank received $11.8 billion of the funds
used to bail out AIG.25
The Federal Reserve made emergency low-cost funds
widely available to foreign as well as US member
nstitutions through its discount window. Deutsche Bank
was the second heaviest user o such unds, borrowing
more than $2 billion.26
The Federal Reserve also created a program known as
the Term Asset-Backed Securities Lending Facility, which
allowed banks to use their assets, including troubled or
hard-to-value assets, as collateral for short term loans.Deutsche Bank was the largest user of the program,
sending the Fed more than $290 billion worth o
mortgage securities.27
According to the Congressional Oversight Panel, the
AIG bailout distorted the marketplace by transforming
highly risky derivative bets into fully guaranteed
payment obligations, and, in 2010, continued to
have a poisonous effect on the marketplace.28 In
2009, Deutsche Bank had profits of over $5 billion.29
Incredibly, a few months before receiving billions of
dollars from the Federal Reserve as part of the AIG
bailout, the bank paid out to its shareholders more tha
$3 billion in dividends. And since then it has paid out
additional $2 billion in dividends.30
In 2008, the financial system failed. The
financial regulatory system failed. Though
there were many causes of the 2008 financ
crisis, derivatives played a central role.
Gary Gensler, Chairm
Commodity Futures Trading Commis
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Evading Financial Reform
12 Las Vegas Foreclosure Task Force
As the 2008 crisis and bank bailouts proved, our existing
nancial regulatory framework has failed us. In July
2010, the Dodd-Frank Wall Street Reform and Consumer
Protection Act was signed into law, with the express
purpose of reducing systemic risk, increasing transparency
nd promoting integrity in the financial system.
Many of the Dodd-Frank rules have yet to be written
y a bevy of agencies, including the Federal Reserve,
Securities Exchange Commission and Commodity
Futures Trading Commission. Meanwhile, many of the
ame global banks that fueled the financial crisis are
ow spending millions to lobby against the robustpplication of the new law, or in some cases, to quash
he new rules altogether.33
he regulation of financial derivatives, for example,
s a critical component of the Dodd-Frank Act. As
f September 2011, Deutsche Bank has met over a
dozen times with federal regulators to water down
proposed derivative rules.34 Deutsche Bank has argue
that foreign banks already have extensive control
mechanisms to regulate certain aspects of derivative
which are subject to home country rules.35 But those
home country rules did not protect US taxpayers fro
the derivative bets that Deutsche Bank made with AIG
Even more troubling, Deutsche Bank is also attemptin
to circumvent capital requirements under Dodd-Frank
while holding onto substantial US tax benefts. Under
Dodd-Franks Collins Amendment, Deutsche Bank
could be required to inject as much as $20 billion to it
US bank holding company, Taunus Corporation.36 But
instead of raising the capital needed to comply with
the law, the bank has decided to restructure Taunus in
order to avoid the new rule altogether. Restructuring
executed solely to circumvent new capital requirement
undermines the intent of the Dodd-Frank Act to reducesystemic risk and makes the job of preventing future
bailouts that much harder.
Capital regulation is the supplest and
most dynamic tool we have to keep pace
with the shifting sources of risk taken by
financial firms.Daniel K. Tarullo
Member, Federal Reserve Board of Governors
Source: Deutsche Bank 2010 Financial Report
What is Deutsche Bank?
Deutsche is a global investment bank, based in Germany andoperating across the world. Heres a quick snapshot of DeutscheBanks finances at end of 2010 (all figures in millions):
2010 Total Assets 1,905,630
2010 Net Revenue 28,567
2010 Net Income 2,330
2010 bonuses, compensation, benefits 12,671
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4
Demanding Accountability3
2
1
Las Vegas Foreclosure Task Force 1
As a major stakeholder in the Las Vegas, and
benefciary o US taxpayer dollars, Deutsche Bank
should be held responsible or its actions in our
community. The Las Vegas Foreclosure Task Force
calls on Deutsche Bank to take a comprehensive
approach to mitigating the oreclosure crisis, both
ocally and nationally.
Responsible Foreclosure Process. In order to
ensure a responsible, fair and accessible foreclosure
process for homeowners, Deutsche Bank should
implement the following measures, which will provide
homeowners with a means to speak directly with bank
representatives.
Modifcation Centers Require all Deutsche Bank servicers
to open loan modification centers in southern Nevada to
ensure a fair and accessible foreclosure process.
Local Representatives Identify locally based
representatives that can be contacted to make necessary
repairs on Deutsche Bank owned properties.
Rehabilitation Fund. Deutsche Bank cannot
continue to neglect our neighborhoods. In order
to restore vacant properties, a pool of revolving
capital is needed. With average rehabilitation costs
of $35,000 per property, 500 houses could be
brought back to life. In order to cover such costs,
we call on Deutsche to contribute $25 million to a
Rehabilitation Fund which will be used to purchase,
rehabilitate and resell properties in concentrated
areas.37
Vigorous Action as Trustee. We call upon Deutsch
Bank to aggressively pursue its responsibilities as
trustee of dozens of mortgage trusts to maximize
investor returns by pursuing loan modifications
when warranted. To the extent that servicers are
failing to pursue loan modifications, even when
such modifications would be the best alternative t
foreclosure, Deutsche Bank should use its trustee
authority to either require servicers to enter into
modification agreements with homeowners or
replace those servicers with other servicers who
will act in the best interest of the trust.
Financial Reorm. Deutsche Bank was a main
contributor to the housing bubble and its collapse
and a recipient of bailout money. Our communities
cannot afford another financial crisis. We call on
Deutsche Bank to abandon its plan to evade new
rules requiring additional capital at its US holdingcompany.
Addressing the financial crisis cant be
just about Wall Street, or even just about
Main Street, it has to be about the 30,000
homeowners in Clark County alone that h
lost their homes this year and the families
that are struggling all over the country.
Elizabeth Warren (20
Former Chair, Congressional Oversight P
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Field Hearing Before the Congressional Oversight Panel, Clark County, NV:Ground Zero of the Housing and Financial Crises, December 16, 2008;Archive-News, Clark County is U.S. Foreclosure Capital, December 10,2010.
Reno Gazette-Journal, Real Estate: Judge rules that Nevadas foreclosuremediation is constitutional, August 30, 2011.
See Clark County, Nevada, Municipal Code 11.06.020; Las Vegas,Nevada, Municipal Code 9.04.010; North Las Vegas, Nevada, MunicipalCode, 8.24.060; Henderson, Nevada, Municipal Code 15.12.030
Las Vegas Review-Journal, Price-slide slowdown signals housing bottom isnear, Las Vegas Review-Journal, July 20, 2011.
Ibid.
Ibid.
Las Vegas Review-Journal, Damaged foreclosures hurting Las Vegas val-es, July 17, 2011.
Las Vegas Sun, Clark County treasurer: Property tax revenue will drop$130 million next year, January 14, 2011.
Las Vegas Sun, District to cut 200 bus driver positions, change schoolstart times, April 8, 2011; Las Vegas Sun, School District to hang on to1,000 teachers, maintain sizes, June 8, 2011.
0 See Las Vegas Sun, Metro takes aim at thieves targeting vacanthomes, June 22, 2011; Las Vegas Sun, Vandals suspected of starting
fire at vacant house, May 13, 2011.
1 KTNV 14 News, Massive bee hive found in foreclosed home plaguesneighborhood, May 5, 2011.
2 KLAS-TV 8 News, County Addresses Vacant Home Epidemic, July 19,2011.
3 Pitch News, As Kansas Citys largest owner of foreclosed properties,Deutsche Bank lets the city rot, August 21, 2008.
4 Florida Supreme Court Task Force, Final Report and Recommendationson Residential Mor tgage Foreclosure Crisis, August 17, 2009.
5 New Haven Independent, Cops Raid Deutsche Banks House, Jan. 27,2010.
6 New Haven Independent, This is the Face of Deutsche Bank, April 28,2009.
7 New York Daily News, Banks default on duty, let foreclosed homes be-come eyesores and disregard fines, July 24, 2011.
8 New York Times, Foreclosures Hit a Snag for Lenders, November 15,2007.
9 Spiegel Online, Americas Foreclosure King: How the United States Becamea PR Disaster for Deutsche Bank, June 10, 2010; Milwaukee JournalSentinel, Deutsche Bank commits $2.4 million to fight city foreclosures,June 23, 2011.
20 Providence Journal Bulletin, Judge Upholds Citys Foreclosure Ordi-nance, May 20, 2010. See Deutsche Bank National Trust Company v.City of Providence, State of Rhode Island Superior Court, P.C. No. 10-1240.
21 Bloomberg, Deutsche Bank Sued by City of Los Angeles for Evicting LoIncome Tenants, May 4, 2011.
22 Reno Gazette-Journal, Judge Rules Nevadas Foreclosure Mediation Prgram Constitutional, Reno Gazette. August 30, 2011.
23 Deutsche Bank, 2011 2Q Interim Financial Report,July, 2011; DeutscBank, SEC Form 20-F, March 2010.
24 Financial Crisis Inquiry Commission, The Financial Crisis Inquiry Report
January 2011, p.191
25 Business Week, German and French banks got $36 billion from AIGbailout, March 15, 2009.
26 Bloomberg, Foreign Banks tapped Feds Secret Lifeline Most at CrisisPeak, April 1, 2011.
27 Huffington Post, Fed Opens Books, Revealing Foreign Megabanks WerBiggest Beneficiaries, January 31, 2011.
28 Congressional Oversight Panel, The AIG Rescue, Its Impact on Marketand the Governments Exit Strategy, June Oversight Report, June 10,2010.
29 Deutsche Bank, Press Release, February 4, 2010.
30 Deutsche Bank Annual Report 2009 and 2010; Interim Repor t 2Q 201
31 US Senate Permanent Subcommittee on Investigations, Wall Street andthe Financial Crisis: Anatomy of a F inancial Collapse, April 13, 2011.
32 Deutsche Bank, SEC Form 20-F, March, 2010.
33 On the relationship between the financial crisis and Dodd-Frank derivatand capital rules, see Gary Gensler, Testimony of Chairman Gary GensBefore the Financial Crisis Inquir y Commission, July 1, 2010; and DanK. Tarullo, Regulating Systemically Important Financial Firms, June 32011.
34 Commodity Futures Trading Commission, External Meetings, CFTCwebsite, accessed September 2011.
35 Public comment letter submitted to the CFTC and SEC by Barclays BanPLC, BNP Paribas SA, Deutsche Bank AG, Royal Bank of Canada, RoyalBank of Scotland, Societe Generale, UBS AG, Re: Application of Title Vof the Dodd-Frank Wall Street Reform and Consumer Protection Act toForeign Banks Global Swaps Businesses, January 11, 2011.
36 Wall Street Journal, Deutsche Bank Maneuvers Around New Law, Apr13, 2011.
37 For rehabilitation cost estimates, see Southern Wisconsin Common GrResearch and Action Report Regarding the Foreclosure Crisis in SouthEastern Wisconsin, January 1, 2010.
*All photos taken between June and July 2011 when held by Deutsche Ban
some properties shown may have subsequently been cleaned up and/or so
Notes
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he Las Vegas Foreclosure Task Force
630 S. Commerce Street
as Vegas, NV 89102
Clergy & Laity
United for Economic Jus
www.lvforeclosuretaskforce.org
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