Summary

1. Bank of America and others are acting in their economic interest;

2. It is illegal to discriminate due solely to national origin;

3. This kind of program ultimately will serve as an assimilation technique for illegal immigrants.

Analysis

First, under the 1964 Civil Rights Act it is illegal to discriminate against someone solely because of his or her country of origin--legal or illegal. Second, B of A and others will insist on a government-issued "number." For illegals, they can get tax-identification numbers (not Social Security numbers) from the IRS, which is more than happy to issue them. These tax ID numbers are what banks and other lenders require when performing such lending.

From the bank's viewpoint, they see a market of 12-14 million people who have no credit cards, generally have no bank account (which I understand B of A will require), and a market that is underserved and unbanked. The bank's action is eminently understandable from a competitive and economic point of view.

Other banks have been or soon will be opening more traditional banking programs to illegal aliens (although most media people prefer the term "undocumented workers."). Banco Popular and others have been trying to mine this type of market for some time now.

If one believes we can send all the immigrants home, then creating programs to finance their lifestyle in the U.S. would be unappealing. Those who believe that the illegals are here to stay, on the other hand, will be glad to get these people more in the mainstream economically and get their tax contributions into the U.S. Treasury.

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