Welcome to Inner City Press’ CRA Report.  Our other Reporters cover the financial services industry, human rights, the Federal Reserve, and other beats.  ICP has published a book about the CRA-relevant topic of predatory lending - click here for sample chapters, a map, and ordering information.  CBS MarketWatch of April 23, 2004, says the the novel has "some very funny moments," and that the non-fiction mixes "global statistics and first-person accounts."  The Washington Post of March 15, 2004, calls Predatory Bender: America in the Aughts "the first novel about predatory lending;" the London Times of April 15, 2004, "A Novel Approach," said it "has a cast of colorful characters."  See also, "City Lit: Roman a Klepto [Review of 'Predatory Bender']," City Limits, Oct. 2004.  The Pittsburgh City Paper says the 100-page afterword makes the "indispensable point that predatory lending is now being aggressively exported to the rest of the globe." Click here for that review; click here to Search This Site  Click here for Inner City Press' weekday news reports, from the United Nations and elsewhere.

Click here for Inner City Press' weekday news reports, from the United Nations and elsewhere. Click here for a recent BBC piece on Inner City Press' reporting from the United Nations. New: Follow us on TWITTER   BloggingHeads.tv  Click for March 1, 2011 BloggingHeads.tv re Libya, Sri Lanka, UN Corruption by Inner City Press. 2014: MRL on Beacon Reader  For or with more information, contact us. See, in November 2021, Inner City Press' book "Belt and Roadkill," here

by Matthew R. Lee

SOUTH BRONX, April 18 – Before Capital One announced and applied to buy Discover, they and their law firm were allowed to meet secretly with the Federal Reserve.

  After they applied late March 20,  Inner City Press submitted a Freedom of Information Act request to the Fed. While they granted expedited treatment, they delayed nearly a near before on March 4 dumping over 1000 redacted pages.

  These begin with ex parte meetings between the bank, its law firm and the Fed - telephone calls in February 2024, and a meeting inside the Fed on March 7, 2024 (the Fed waited until March 4, 2025 to disclose this). 1000 page on Inner City Press' DocumentCloud here. 200+ more pages here.  FOIA determination letter here

Inner City Press immediately appealed. More than a month later, and apparently preparing its rubber stamp, the Federal Reserve upheld its own withholding in full and denied the appeal, letter here
 - teeing up the April 18 approval, with Discovery consent order as fig leaf.

 The fix was in: on March 3, days after the CFPB dropped its lawsuit against Capital One, the OCC suddenly declared Capital One "Outstanding" under the Community Reinvestment Act. Who's in the  OCC's and Fed's wallet, now?

Back on July 26, after a FOIA appeal - and after closing the public comment period - the OCC belatedly gave Inner City Press documents showing Capital One briefed the OCC on a "big" deal in November 2023; it was code named "Project Sirius."

Then overly chummy texts from Andy Navarrete, who testified at the public meeting, and Pient Tran to the OCC's Marci Heppner and others.

For example, Andy to Marci, sorry for the late ping, if Richard wanted to call, could you do a 1:1 Zoom at 7:30 [pm]. But of course. That and more on the OCC  on Inner City Press' DocumentCloud here.

Then FOIA appeal denial and Good Friday rubber stamp.

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by Matthew R. Lee

SOUTH BRONX, April 11 – Before Capital One announced and applied to buy Discover, they and their law firm were allowed to meet secretly with the Federal Reserve.

  After they applied late March 20,  Inner City Press submitted a Freedom of Information Act request to the Fed. While they granted expedited treatment, they delayed nearly a near before on March 4 dumping over 1000 redacted pages.

  These begin with ex parte meetings between the bank, its law firm and the Fed - telephone calls in February 2024, and a meeting inside the Fed on March 7, 2024 (the Fed waited until March 4, 2025 to disclose this). 1000 page on Inner City Press' DocumentCloud here. 200+ more pages here.  FOIA determination letter here

Inner City Press immediately appealed. More than a month later, and apparently preparing its rubber stamp, the Federal Reserve upheld its own withholding in full and denied the appeal, letter here.

On March 3, days after the CFPB dropped its lawsuit against Capital One, the OCC suddenly declared Capital One "Outstanding" under the Community Reinvestment Act. Who's in the  OCC's and Fed's wallet, now?

Back on July 26, after a FOIA appeal - and after closing the public comment period - the OCC belatedly gave Inner City Press documents showing Capital One briefed the OCC on a "big" deal in November 2023; it was code named "Project Sirius."

Then overly chummy texts from Andy Navarrete, who testified at the public meeting, and Pient Tran to the OCC's Marci Heppner and others.

For example, Andy to Marci, sorry for the late ping, if Richard wanted to call, could you do a 1:1 Zoom at 7:30 [pm]. But of course. That and more on the OCC  on Inner City Press' DocumentCloud here

***

by Matthew R. Lee

SOUTH BRONX, April 3 – After Capital One applied to buy Discover, in an anticompetitive deal that should be rejected by regulators, now Rocket announces a plan to buy Mr. Cooper, after Redfin. Expect more - including questions.

On March 3, days after the CFPB dropped its lawsuit against Capital One, the OCC suddenly declared Capital One "Outstanding" under the Community Reinvestment Act. Who's in the  OCC's wallet, now?

Back on July 26, after a FOIA appeal - and after closing the public comment period - the OCC belatedly gave Inner City Press documents showing Capital One briefed the OCC on a "big" deal in November 2023; it was code named "Project Sirius." That and more now on Inner City Press' DocumentCloud here

  Now Inner City Press' FOIA to the Fed resulted in 1000 plus pages, but redactions. It appealed, and on March 11 was granted expedited processing.

Now on April 3, another extension: "we are extending the period for our response until April 17, 2025, in order to consult with two or more components of the Board having a substantial interest in the determination of the appeal. If a determination can be made before April 17, 2025, we will respond to you promptly." So will they rule on FOIA before they rule on the merger? Watch this site.

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by Matthew R. Lee

SOUTH BRONX / DC, March 28 – Before Capital One announced and applied to buy Discover, they and their law firm were allowed to meet secretly with the Federal Reserve, see below.

  After they applied late March 20, 2024  Inner City Press submitted a Freedom of Information Act request to the Fed. While they granted expedited treatment, they delayed nearly a near before on March 4, 2025 dumping over 1000 redacted pages.

Now on March 28 the Fed has announced that "the federal bank regulatory agencies today announced, in light of pending litigation, their intent to issue a proposal to both rescind the Community Reinvestment Act (CRA) final rule issued in October 2023 and reinstate the CRA framework that existed prior."

  The Fed's late-provided FOIA documents begin with ex parte meetings between the bank, its law firm and the Fed - telephone calls in February 2024, and a meeting inside the Fed on March 7, 2024 (the Fed waited until March 4, 2025 to disclose this). 1000 page on Inner City Press' DocumentCloud here. 200+ more pages here.  FOIA determination letter here

Inner City Press has filed a FOIA appeal to the Federal Reserve - and raised it in a March 21 comments, along with a new Bank for International Settlements study that cries out for denial of the merger.

On March 24, the Fed's response: "Because your letter was received after the end of the public comment period, it will not be made a part of the record of this case unless the Board in its sole discretion determines to consider your late comments." Yeah, discretion...

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by Matthew R. Lee

SOUTH BRONX, March 18 – Before Capital One announced and applied to buy Discover, they and their law firm were allowed to meet secretly with the Federal Reserve.

  After they applied late March 20,  Inner City Press submitted a Freedom of Information Act request to the Fed. While they granted expedited treatment, they delayed nearly a near before on March 4 dumping over 1000 redacted pages.

  These begin with ex parte meetings between the bank, its law firm and the Fed - telephone calls in February 2024, and a meeting inside the Fed on March 7, 2024 (the Fed waited until March 4, 2025 to disclose this). 1000 page on Inner City Press' DocumentCloud here. 200+ more pages here.  FOIA determination letter here

Inner City Press has filed a FOIA appeal to the Federal Reserve - including for the withheld competitive information. This is key, amid reports even DOJ has found subprime antitrust problems, hidden by the Fed so far.

On March 3, days after the CFPB dropped its lawsuit against Capital One, the OCC suddenly declared Capital One "Outstanding" under the Community Reinvestment Act. Who's in the  OCC's and Fed's wallet, now?

***

by Matthew R. Lee

SOUTH BRONX, March 11 – After Capital One applied to buy Discover, in an anticompetitive deal that should be rejected by regulators, now Rocket announces a plan to buy Redfin. Expect more - including questions.

On March 3, days after the CFPB dropped its lawsuit against Capital One, the OCC suddenly declared Capital One "Outstanding" under the Community Reinvestment Act. Who's in the  OCC's wallet, now?

Back on July 26, after a FOIA appeal - and after closing the public comment period - the OCC belatedly gave Inner City Press documents showing Capital One briefed the OCC on a "big" deal in November 2023; it was code named "Project Sirius." That and more now on Inner City Press' DocumentCloud here

  Now Inner City Press' FOIA to the Fed resulted in 1000 plus pages, but redactions. It appealed, and on March 11 was granted expedited processing. But will they rule on FOIA before they rule on the merger? Watch this site.

***

by Matthew R. Lee

SOUTH BRONX, March 6 – Before Capital One announced and applied to buy Discover, they and their law firm were allowed to meet secretly with the Federal Reserve.

  After they applied late March 20,  Inner City Press submitted a Freedom of Information Act request to the Fed. While they granted expedited treatment, they delayed nearly a near before on March 4 dumping over 1000 redacted pages.

  These begin with ex parte meetings between the bank, its law firm and the Fed - telephone calls in February 2024, and a meeting inside the Fed on March 7, 2024 (the Fed waited until March 4, 2025 to disclose this). 1000 page on Inner City Press' DocumentCloud here. 200+ more pages here.  FOIA determination letter here

Inner City Press has filed a FOIA appeal to the Federal Reserve including that "the records are heavily redacted. On this proposed merger in which antitrust harm to consumers is a major issue, the Board has withheld in full for example so-called 'Confidential Exhibit B Additional Information on Competitive Impact.'    In the second file the Board provided on March 4, 2025, pages 119 to 201 are redacted in full.     FOIA expressly mandates that any "reasonably segregable portion" of a record must be disclosed to a requester after the redaction - 5 U.S.C. § 552(b). And see, PHE, Inc. v. Dep’t. of Justice, 983 F.2d 248,252. Likewise, from the communications between Federal Reserve staff and representatives of the bank(s) there are redactions we are challenging on appeal. As simply one example, FRB attorney Lucy Chang received an email from Capital One's outside counsel on March 22, 2024, before public announcement of the merger proposal - after "thanks for getting back to me," an entire paragraph is redacted. In the same chain, "the vmail I left you next week [REDACTED]." These should all be reviewed on appeal.  

On March 3, days after the CFPB dropped its lawsuit against Capital One, the OCC suddenly declared Capital One "Outstanding" under the Community Reinvestment Act. Who's in the  OCC's and Fed's wallet, now?

***

by Matthew R. Lee

SOUTH BRONX, Feb 27 – Capital One has applied to buy Discover, in an anticompetitive deal that should be rejected by regulators if they mean what they have been saying. After they applied late March 20,  Inner City Press submitted a second Freedom of Information Act request to the Office of the Comptroller of the Currency (and to the Federal Reserve, see below).

On February 27, "the Plaintiff, Consumer Financial Protection Bureau, dismisses with prejudice this action against all Defendants" - Capital One. Who's in the Federal Reserve's and OCC's wallet, now?

Back on July 26, after a FOIA appeal - and after closing the public comment period - the OCC belatedly gave Inner City Press documents showing Capital One briefed the OCC on a "big" deal in November 2023; it was code named "Project Sirius."

Then overly chummy texts from Andy Navarrete, who testified at the public meeting, and Pient Tran to the OCC's Marci Heppner and others.

For example, Andy to Marci, sorry for the late ping, if Richard wanted to call, could you do a 1:1 Zoom at 7:30 [pm]. But of course. That and more now on Inner City Press' DocumentCloud here

  Inner City Press continues to dig through the records - and to prepare another FOIA appeal.

Back on June 25 the OCC belatedly responded to Inner City Press' FOIA request - by withholding in full 185 pages. OCC FOIA production on DocumentCloud here. Inner City Press appealed.

  On July 24, the very day on which the OCC and Fed said they were closing the written comment period, the OCC upheld in full its FOIA denials, determination letter on Inner City Press' Document Cloud here. Inner City Press has requested an extension of the comment periods - the Fed hasn't even responded. When did the Fed start secret talks with Capital One?

***

by Matthew Russell Lee, Patreon Book Substack

BRONX / FEDERAL COURT, Feb 19 –   General Motors is an opportunity. It previously applied to try to get into banking through the Utah Industrial Loan Company loophole, but was opposed and withdrew. 

  Now, for obvious reasons, it has reapplied - under the old CRA rules, which have been repealed and superseded, no less. On February 7 Fair Finance Watch filed opposition with the FDIC and Utah regulator:

This is a timely first comment by Fair Finance Watch  opposing and requesting an extension of the FDIC's public comment period on the Applications by General Motors for deposit insurance.

 This re-submitted proposal, if approved, would make a mockery of the Community Reinvestment Act. The FDIC should hold public hearings, and on the current record deny the application.   

GM does business and its bank would, well beyond Utah. But it seeks to limit its CRA to… Utah.   Tellingly, the application states that "GM Financial has developed this Community Reinvestment Act (“CRA”) plan based on the Federal Deposit Insurance Corporation (“FDIC”) CRA regulations that were effective on March 31, 2024, rather than the new framework that was finalized on October 24, 2023 (the “2023 CRA Framework”).

The questions to be considered at the public hearing are not only the regulatory evasion of ILCs - more unacceptable after the financial meltdown - but also CRA assessment areas, covering of affiliates, etc. 

On February 18, this: "William J. Donnelly, Senior Vice President  GM Financial  801 Cherry Street, Suite 3500  Fort Worth, TX 76102  Dear Mr. Donnelly:  This letter is in reference to a Community Reinvestment Act (CRA) protest filed by Mr. Matthew  R. Lee of Fair Finance Watch, concerning your application for an Industrial Loan Charter and  deposit insurance, filed on January 31, 2025.  We reviewed the enclosed correspondence and  consider it to constitute a protest for purposes of this application, in accordance with the  provisions of 12 C.F.R. Section 303.  The protest concerns the proposed institution’s CRA  compliance and how the convenience and needs factor will be addressed in the application  process.  You may provide a written response on the protest to me until March 5, 2025."

  Inner City Press also opposes the redactions to the application, including to the "Financial Model"  

Another car company has applied, and Inner City Press requested the application ten days ago without response yet - this is not acceptable. Watch this site.

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by Matthew Russell Lee, Patreon Book Substack

SDNY COURTHOUSE, Feb 12 – Capital One Bank refused a payment plan and moved to foreclose on woman's property in East Harlem in upper Manhattan, NYC.

 She sued in state court - and Capital One moved to transfer the case to Federal court in the U.S. District Court for the Southern District of New York, where Inner City Press found it in the docket. 

 The plaintiff recounts how she was tricked, akin to predatory lending. She is seeking punitive damages and an injunction preventing further foreclosure actions.

 The case is Sanders v. Capital One, N.A., 1:25-cv-1252 (Unassigned)

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by Matthew Russell Lee, Patreon Book Substack

BRONX / FEDERAL COURT, Feb 7 –   General Motors is an opportunity. It previously applied to try to get into banking through the Utah Industrial Loan Company loophole, but was opposed and withdrew. 

  Now, for obvious reasons, it has reapplied - under the old CRA rules, which have been repealed and superseded, no less. On February 7 Fair Finance Watch filed opposition with the FDIC and Utah regulator:

This is a timely first comment by Fair Finance Watch  opposing and requesting an extension of the FDIC's public comment period on the Applications by General Motors for deposit insurance.

 This re-submitted proposal, if approved, would make a mockery of the Community Reinvestment Act. The FDIC should hold public hearings, and on the current record deny the application.   

GM does business and its bank would, well beyond Utah. But it seeks to limit its CRA to… Utah.   Tellingly, the application states that "GM Financial has developed this Community Reinvestment Act (“CRA”) plan based on the Federal Deposit Insurance Corporation (“FDIC”) CRA regulations that were effective on March 31, 2024, rather than the new framework that was finalized on October 24, 2023 (the “2023 CRA Framework”).1 Implementation and enforcement of the 2023 framework was enjoined by the District Court for the Northern District of Texas on March 29, 2024,2 and its future effectiveness remains uncertain."

  Not only is GM, in reapplying, seeking to take advantage of that - it is clearly feeling it is more likely now to get a rubber stamp. But there even community banks oppose these ILC applications. The questions to be considered at the public hearing are not only the regulatory evasion of ILCs - more unacceptable after the financial meltdown - but also CRA assessment areas, covering of affiliates, etc. 

  The FDIC is administering a loophole that even many in the industry, because consumer and CRA advocates, oppose.       So, it is time for public hearings. 

    For the record, this is a timely comment on: "  20250105    GM Financial Bank Salt Lake City-Provo-OREM Area SALT LAKE CITY, UT    Deposit Insurance (New Bank)    01/31/2025    03/02/2025"

 It is unclear why this is listed as an application to the Chicago Region of the FDIC, which covers "Territory: Illinois, Indiana, Kentucky, Michigan, Ohio, Wisconsin." There should be an explanation. 

  Inner City Press also opposes the redactions to the application, including to the "Financial Model"   Watch this site.

***

By Matthew Russell Lee, Patreon

SOUTH BRONX / SDNY, Jan 31 Back in April 2021, Fair Finance Watch and Inner City Press predicted that the proposed merger of New York Community Bank and Flagstar would flounder, on disparate lending and regulatory evasions.

  Fair Finance Watch found that in 2019 Flagstar made 60,982 mortgage loans to whites, with 13,963 denial to whites - while making only 3799 loans to African Americans with fully 1777 denials to African American. This was significantly worse than other lenders.

  New York Community Bank's record as an enabler of and profiteer off slumlords led Inner City Press file a Community Reinvestment Act challenge to its then-proposed merger with Astoria Bank, which fell apart.

A year a half later, the proposed merger was still not done and the extended deadline was approaching, amid talk of, as we predicted, fair lending action.

Then at 8 am on November 7, the banks bragged they had Fed approval. But a visit to the Fed's website at 8:40 am did not find any press release of approval. The Fed is getting more and more lax. We'll have more on this.

Inner City Press has gone back to find Flagstar's comments on the proposed and still pending Community Reinvestment Act regulations - tellingly, full of resistance: "Because Flagstar supports the goals of the CRA, the Bank submits this comment letter to highlight concerns about the Agencies' proposed reforms to the CRA framework. This Proposal would undermine the objectives of the CRA and run contrary to the Agencies' stated effmts to ensure that the law continues to be an effective force for strengthening banks and the communities they serve, which j: intludes (i) low- and moderate-income ("LMI") individuals, families, and neighborhoods; (ii) small businesses and farms; and (iii) communities in need of financial services and economic development. Flagstar is particularly concerned about the proposed retail lending assessment area requirements, which would impose significant regulatory, operational, and staffing burdens on banks (especially when coupled with the proposed data collection requirements); force banks to spread limited CRA resources thin and undermine the effectiveness of their CRA programs; and place banks at a competitive disadvantage to nonbanks and other lenders not subject to the CRA. In our view, these challenges will discourage banks from engaging in retail lending and other CRA activities that could otherwise benefit local communities, contrary to the spirit of the law. Moreover, as applied to Flagstar, the proposed retail lending assessment requirements would be so overly burdensome and unworkable that they would likely cause us to question and rethink our business model. 1. There is insufficient data to justify abandoning longstanding interpretations of the CRA to require the delineation of lending-based assessment areas; Requiring the delineation of a lending-based assessment area would go beyond the text and purpose of the CRA." Yeah.

In late January 2025, Flagstar CFO Lee Smith said Flagstar is closing about 60 retail branches, most of which it leases; about 20 private-client retail locations; and a couple of operating centers that are owned by the bank.

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by Matthew R. Lee, Patreon Substack