IN THE UNITED STATES DISTRICT COURT FOR THE
                           DISTRICT OF NEW MEXICO

   UNITED STATES OF AMERICA,
   Plaintiff

   v.

                                              CIVIL ACTION NO: 97-0096 HB

   FIRST NATIONAL BANK OF DONA
   ANA COUNTY,
   Defendant.

                                 COMPLAINT

   The United States of America alleges:

    1. This action is brought by the United States to enforce the
       provisions of Title VIII of the Civil Rights Act of 1968 (the Fair
       Housing Act) as amended by the Fair Housing Act Amendments Act of
       1988, 42 U.S.C. §§ 3601-3619, and the Equal Credit Opportunity
       Act, 15 U.S.C. §§ 1691-1691f, as amended.
    2. This court has jurisdiction of this action pursuant to 28 U.S.C.
       13-45, 42 U.S.C. § 3614(a), and 15 U.S.C. § 1691e(h); venue is
       appropriate pursuant to 28 U.S.C. §§ 1391(c) and 1392(a).
    3. Defendant First National Bank of Dona Ana County (hereinafter also
       referred to as "First National Bank" or "the lender") has its
       principal place of business in Las Cruces, New Mexico. First
       National Bank has five branches serving greater Las Cruces, and
       outlying branches in Anthony, Hatch, Santa Teresa and White Sands,
       New Mexico.
    4. The Defendant is subject to federal laws prohibiting certain types
       of discrimination in lending, including the Fair Housing Act and
       the Equal Credit Opportunity Act. The Defendant engages in
       residential real estate-related transactions and is a creditor
       within the meaning of the Equal Credit Opportunity Act.
    5. According to the 1990 Census, over 25% of all housing units in the
       Las Cruces, Metropolitan Statistical Area (MSA) were mobile home
       dwellings, the majority of which were occupied by Hispanics.
       Specifically, in 1990 there were 8,926 owner-occupied mobile homes
       in the Las Cruces MSA, 5,009 (56%) of which were occupied by
       Hispanics. As of 1990, 36% of Hispanic homeowners in the Las
       Cruces, MSA, resided in mobile homes.
    6. Since at least 1990, First National Bank has offered loans for the
       purchase of mobile homes as part of the lender's consumer lending
       program. The loans are designed for persons desiring to purchase a
       mobile home as their primary residence. These loans are secured by