Inner City Press' Community Reinvestment Reporter

  

     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 informationCBS 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.

September 28, 2020

Insurers Beat NYS Regulator In ACA Case in 2d Circuit Now SDNY Follows Suit

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - ESPN

SDNY COURTHOUSE, Sept 24 – Insurers sued the NYS Superintendent of Financial Services for a 2017-18 regulation requiring them to pay a portion of the funds they received under the ACA's risk adjustment program into the NYS treasury. 

 The insurers won in the Second Circuit Court of Appeals. 

 On September 24 U.S. District Court for the Southern District of New York  Judge John G. Koeltl held a proceeding. Inner City Press covered it.

   The State's lawyer wanted a delay, to change their regulations seemingly voluntarily.

 Judge Koeltl rejected these optics, and granted the insurers summary judgment.

The case is, or was, UnitedHealthcare of New York, Inc. et al v. Vullo, 17-cv-7694 (Koeltl)

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September 21, 2020

Varo Bank The Bancorp Application Protested to OCC But Crypto Brooks Rubber Stamps It

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - CJR - PFT

South Bronx, Sept 14 –  The fintech Varo has applied to the U.S. Office of the Comptroller of the Currency of pro-crypto Brian Brooks for a transaction with The Bancorp. Fair Finance Watch filed a timely protest:

"September 7, 2020    Office of the Comptroller of the Currency  DC Comptroller Brooks & Western District Office  1225 17th Street, Suite 300 Denver, CO 80202  

Dear Comptroller Brooks and others in the OCC:    On behalf of Inner City Press / Fair Finance Watch (FFW) and in my personal capacity, this is questionlessly timely protest to the application by Varo regarding The Bancorp.

FFW and Inner City Press are deeply concerned about the rush by the OCC under Acting Comptroller Brooks to let fintechs and others into banking, and by his comment about not regulating entities (banks) but rather activities. This is killing the Community Reinvestment Act and we timely request public hearings. 


State Street Bank Is Sued For Boston Club Culture Now Complains About Discovery

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - ESPN

SDNY COURTHOUSE, Sept 15 –   Two employees sued State State Bank for discrimination. Then their lawyer had some problems   

 On September 15 U.S. District Court for the Southern District of New York Judge Gregory H. Woods held a status conference. Inner City Press covered it.   

State Street's lawyer complained about the plaintiff getting double standards, while purporting to sympathize for their problems. The plaintiffs cite State Street's "notorious male-dominated 'Boston club' culture."

 The case is Shnyra et al v. State Street Bank and Trust Co., Inc., 19-cv-2420 (Woods)

September 14, 2020

Varo Bank The Bancorp Application Protested to OCC of Crypto Brooks By Fair Finance Watch

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - CJR - PFT

South Bronx, Sept 7 –  The fintech Varo has applied to the U.S. Office of the Comptroller of the Currency of pro-crypto Brian Brooks for a transaction with The Bancorp. Fair Finance Watch has filed a timely protest:

"September 7, 2020    Office of the Comptroller of the Currency  DC Comptroller Brooks & Western District Office  1225 17th Street, Suite 300 Denver, CO 80202  

Dear Comptroller Brooks and others in the OCC:    On behalf of Inner City Press / Fair Finance Watch (FFW) and in my personal capacity, this is questionlessly timely protest to the application by Varo regarding The Bancorp.

FFW and Inner City Press are deeply concerned about the rush by the OCC under Acting Comptroller Brooks to let fintechs and others into banking, and by his comment about not regulating entities (banks) but rather activities. This is killing the Community Reinvestment Act and we timely request public hearings.  

 As to Varo, consider for example the recent consumer complaints below, on top of  their service interruption in October 2019, including declined debit card transactions, which they tried to blame on their processor Galileo. See, e.g., this.

 More fundementally, consider weakened CRA duties, and disproportionate exclusion: low and moderate consumers disproportionately have prepaid or limited data plans and face disconnections of their mobile service. And just because consumers have email addresses does not mean that they have regular internet access, and if they close or move their accounts, they may lose access to their financial records.    

Despite or perhaps because of these and the service interruptions, using OCC deregulation, "Varo Money has raised an additional $241 million in Series D funding, the company announced today. The investment was co-led by new investor Gallatin Point Capital and existing investor The Rise Fund, co-founded by TPG. Also participating in the round were Bono (yes, that one), along with entrepreneur, impact investor and movie producer Jeff Skoll; plus HarbourVest Partners and Progressive Insurance.  To date, Varo has raised $419.4 million in funding."  

See also, for the record on which Inner City Press / Fair Finance Watch and I are timely requesting evidentiary hearings on this application, " NEWS Technology Finance  Unregulated Fintech Could be the Source of the Next Market Crash Posted to TechnologyFinance."    

Here for the record are recent consumer complaints against Varo:  Sep 02 Froze my account because I transferred money 3 times! 2.5 Details Varo Money - Froze my account because I transferred money 3 times! Varo Money - Froze my account because I transferred money 3 times! I was speechless when I received an email from Varo saying my account had been frozen due to an a number of transfers from my Chime account. I had a total of 3 transfers in the past year that I've had the account. I have $9,754 in my account and it came from unemployment, school refunds and tax refund. They won't respond to emails and customer service doens't know anything. How can this be legal? User's recommendation: find another bank because they will freeze your account.   No way to communicate with someone LOSS $9754 PREFERRED SOLUTION I want my money to be released immediately so I can transfer it to another bank 

Aug 07  Their website leaves many unanswered questions and when I called their listed phone number there was a very long and detailed recording and only by accident could you reach a prompt to talk with an agent. Another recording indicated that there would be a long delay in reaching an agent followed by some distorted music. After 20 minutes still no response so I disconnected. Their entire platform seems confusing and convoluted with unnecessary information. I would question the security of doing banking matters in an entirely mobile format with no customer service. 

Aug 04  Terrible service They closed my account. I've sent them 4 forms of id, proof of address, etc. After sending all that they said they still couldn't verify my identity and closed by account that I've had for years. Now I'm waiting for them to send my direct deposit back , and it's been a few days. User's recommendation: Don't use them."

       We timely request public hearings on, and the denial of, this application.  Thank you for your prompt attention,  Matthew R. Lee  Inner City Press / Fair Finance Watch."

  The Federal Reserve coordinated its timing with the OCC of Brian Brooks, who has numerous conflicts of interest in the fintech field.    Varo has bragged, "Varo has filed its Strategic Plan with the Office of the Comptroller of the Currency and believes that it will be approved in the near future. Varo respectfully submits that the OCC process is the appropriate forum for his comments. The Comment Letter vaguely references the “COVID-19 pandemic” and “Coronavirus restrictions” without providing any clear or definite demonstration as to how such pandemic or restrictions have interfered with the Commenter’s ability to meet the specified comment period or given rise to any hardship to Commenter or other meritorious reason to extend the comment period, or how the arbitrarily chosen “Phase Two” of such restrictions would alleviate any such unsubstantiated causes for delay. To the contrary, by virtue of the scope and content of the Comment Letter itself, the Commenter has clearly demonstrated his ability to comment within the specified comment period."

   What arrogance - commenting amid lockdowns is fine, the OCC is the place to comment. Well, now it's in.

       Watch this site.

September 7, 2020

From Coinbase Brooks Into OCC Says Will Not Regulate Entities Or Obey SDNY or CRA

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - CJR - PFT

UN GATE / SDNY COURT, Sept 1 – Acting U.S. Comptroller of the Currency Brian Brooks, as Coinbase’s chief legal officer,  was paid $1.4 million in salary -- separate from the stock options -- in the year and a half he spent with company, which had weighed seeking a charter through the OCC before making other moves to access the banking system."

  Now Brooks says, "I'm increasingly thinking of this agency as an activities regulator, not an entity regulator." But since the Community Reinvestment Act is enforced with regard to entities, this is an even more egregious attach on CRA than Otting engaged in. Combined with Brooks open contempt for rulings of the U.S. District Court for the Southern District of New York, it shows why he should be removed as Comptroller.

 On his conflicts of interest, Inner City Press asked - and then requested under FOIA - what are the "other tech firms" as to which Brooks is acknowledging a conflict.

   The OCC wrote to Inner City Press, faux apologizing for withholding information it has requested about Otting until after he had left the agency. Inner City Press immediately wrote back requesting a copy of Brooks' ethics letter and list of companies as to which even he acknowledges a conflict of interest.

  On June 18, that simple request was denied and so a FOIA request was filed, see below.

  And now more than a month later on July 22 the OCC has provide to Inner City Press under FOIA a copy of the ethics memo that Brooks is recused on: Amazon (minus AWS), Avant, Aventas, Merrill Lynch, CoinBase, EarnUp, Spring Labs, TextIQ - and Citibank N.A. residential mortgage business." We'll have more on this.

  From Inner City Press' FOIA request: "This is a request under FOIA on behalf of Inner City Press and in my personal capacity for all records concerning conflicts of interest or the appearance of conflict of interest by Acting Comptroller Brian Brooks, including but not limited to the Ethics letter Inner City Press requested from the OCC, below, and Coinbase, Avant, OneWest and any other firm.  Inner City Press in responding to a request by OCC to "close out" a FOIA request still not completed asked "I do have an OCC public information / transparency question - for the Acting Comptroller's ethics filing - can it be sent to me at Matthew.Lee@innercitypress.com? To identify it: "Brooks has submitted a letter through the agency's ethics office outlining companies he'll steer clear of because of potential conflicts of interest, including Amazon.com Inc., Bank of America Corp.'s Merrill Lynch unit, Coinbase and a number of other tech firms he's worked with." What are those companies? Thanks, -Matthew Lee, Inner City Press"  Days later and minutes ago Inner City Press received this: Good Morning Mr. Lee....  I don't know the answer to the question you asked.  You should file a FOIA request for the records you seek regarding the Acting Comptroller. " This is that request, on which expedited treatment should be granted - such disclosures are among the very purposes of FOIA."  Watch this site.

   Amid all this, Fair Finance Watch and Inner City Press / Community on the Move have launched a new project. And so far, Brooks' national banks have been among the worst. Watch this site.

August 31, 2020

Japanese FinTech Rakuten Retreats From CRA Evasion While OCC and Fed Cheer On Varo

By Matthew R. Lee

SOUTH BRONX, Aug 23 – Amid attacks on the U.S. Community Reinvestment Act now under Brian Brooks after Joseph Otting had his turn as Comptroller of the Currency, now Japan's Rakuten has withdrawn its application to get into banking. The opposition of smaller American banks didn't stop the OCC, and Federal Reserve on a delegated basis, from rubber stamping Varo into banking. But the line has been drawn, curved like an arrogant Amazon "smile," at this Japanese Internet company.

 Inner City Press / Fair Finance Watch has filed comments on all this. Previously: "A Japanese FinTech company is applying for a banking charter in the United States. The eCommerce firm Rakuten currently runs a shopper rewards program in the States, and said would file the necessary paperwork on Friday (July 26) with Federal Deposit Insurance Corp. (FDIC) and the state of Utah for an industrial loan company (ILC) charter.  Rakuten has about 13 million active users who earn rewards for purchasing products from participating merchants.   The bank would be headquartered in Utah and could handle users’ deposits, according to Lee Carter, Rakuten head of banking and potential ILC CEO. The company also wants to give members a credit card to make purchases in the future and also earn rewards.  Carter said he’s “kept a close eye on Square’s application.”  He also said the company would provide a complete plan for the Community Reinvestment Act with the application, because some groups are worried that FinTechs won’t be held accountable for certain rules.  “We have thought about that very, very carefully,” Carter said. “We’ll have specific goals for community service and investments back into the community."  We'll have about that.

August 24, 2020

Sued for PPP JPM Chase Citigroup Signature Tell Judge Rakoff of Chevron Deference

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - The Source

SDNY COURTHOUSE, Aug 21 – In the U.S. Paycheck Protection Program, banks limited the loans to their own customers first. Then they refused to pay compensation to agents, and got sued.

On August 21 U.S. District Court for the Southern District of New York Judge Jed S. Rakoff held an oral argument, on Zoom. Inner City Press covered it.  

  A lead defendant is JPMorgan Chase Bank, N.A.. There's also Citigroup, MUFG Union Bank and Signature Bank.

 Judge Rakoff was directed to Chevron deference and quipped, I think that's still good law. When the Zoom broke down, he said it must be "Putin."

  The banks have moved to dismiss for failure to state a claim and for lack of subject matter jurisdiction.  

  By the end of the proceeding, Judge Rakoff allowed sur-rebuttal and promised a prompt decision.

The case is James Quinn et al v. JPMorgan Chase Bank, N.A. et al., 20-cv-4100 (Rakoff)

August 17, 2020

The regulators, even amid the COVID-19 pandemic, have shown a willingness to rubber stamp applications including the Federal Reserve on a "delegate" / approval-only basis as they did with Varo's application to become a bank holding company.  

But these moves are drawing increasing scrutiny, and some bad-actors are having to settle charges, like Capital One's $80 million fine, here.... Aug, Texas: "Three affiliated banks have announced a merger to form a Central Texas banking franchise in San Antonio, Austin and the Texas Hill Country. Southwest Bancshares, Inc., a bank holding company for the Bank of San Antonio, Capitol of Texas Bancshares, Inc., a bank holding company for the Bank of Austin, and Texas Hill Country Bancshares, for the Texas Hill Country Bank, will merge into one company"  July 17, Missouri: "United State Bank, based in Lewistown, Missouri, signed a pending acquisition agreement with Canton State Bank, based in Canton, Missouri"  There are more branch closures, for example in Michigan, here.  And Florida, here (and South Carolina, here).

August 10, 2020

Rubber Stamp of Varo Bank Protested to Federal Reserve Chair Powell Collusion With OCC

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - CJR - PFT

South Bronx, Aug 3 –  How corrupt has the Federal Reserve become using the COVID-19 pandemic as ground cover? Well, despite rules that substantively challenged applications can only be approved by the Board of Governors in DC, on July 28 the Fed rubber stamped on a delegated basis fintech Varo's application to form a bank holding company. It is an unprecedented now low - but happens while the Federal Reserve withholds under FOIA all information about the impact of COVID-19 on the application by Brazil-based Banco Bradesco. Something has gone dreadfully wrong on C St.

  Here's the Fed's - Federal Reserve Bank of San Francisco's - July 28 letter, sent to Inner City Press: "Dear Mr. Walsh: The Federal Reserve Bank of San Francisco (“Reserve Bank”), acting under authority delegated by the Board of Governors of the Federal Reserve System (“Board”), and having considered the relevant statutory factors, hereby approves the subject application. In consideration of this filing, reliance was placed upon all the representations and the commitments made by or on behalf of Bancorp. No significant changes in the transaction should be made prior to consummation without our approval. Approval of the application is subject to the Board’s authority to require reports by and make inspections and examinations of BHCs and their subsidiaries, and to require such modification or termination of activities of a holding company or any of its subsidiaries as the Board finds necessary to ensure compliance with the BHC Act. Approval of the application is also subject to receipt of all other required regulatory approvals, non-objections, or consents with this transaction. The proposed transaction may be consummated upon approval. 1 Please notify the undersigned in writing when the transaction is consummated."

 Then the FRBSF wrote to Inner City Press saying it had five days until August 3 at 5 pm PST to request review. We have: "On behalf of Inner City Press / Fair Finance Watch and in my personal capacity, this is questionlessly timely request for review of the FRBSF's unprecedented and shamefully rubber stamping on delegated authority - which authority is ONLY to approval - of the application by Varo to get into banking (through the OCC), renewed complaint about the FRB's failure update its H2A, its continued processing and rubber-stamping of expansion applications amid the COVID-19 pandemic and on the withholding of HMDA data in online form by CFPB and other FFIEC regulators including the FRB - and a demand for actions.    On June 10 Inner City Press submitted to the Board a timely comment. We heard nothing bank - no Additional Information letter to Varo, no request to us for information - until receiving first a copy of the FRBSF's approval, then a letter which did not even mention most of the issues we raised to the Board in June. We wrote to the Board because we have no confidence at all in the FRBSF, which did not purport to explain the withholding of information from the public nor its craven rubber stamping to go along with the OCC, during pandemic lockdown no less.    We immediately wrote back to the FRBSF, again with no response: This is to confirm receipt of your letter - and to immediately inform you of Inner City Press / Fair Finance Watch's outrage that this important application was rubber stamped on a delegated basis by a Reserve Bank which can only approve. This is a new low -- applications by much smaller institutions, raising many fewer issues, are sent to the Board of Governors for decision. This is a major mistake - we will be pursuing it, and urge that there be no consummation of this illegitimate delegated rubber-stamp.     The FRB has coordinated its timing with the OCC of Brian Brooks, who has numerous conflicts of interest in the fintech field.    The FRBSF has become not a regulator, but a cheerleader. As to Varo, consider for example their service interruption in October 2019, including declined debit card transactions, which they tried to blame on their processor Galileo... More fundamentally, consider weakened CRA duties, and disproportionate exclusion: low and moderate consumers disproportionately have prepaid or limited data plans and face disconnections of their mobile service. And just because consumers have email addresses does not mean that they have regular internet access, and if they close or move their accounts, they may lose access to their financial records. We requested and request hearings. .This shameful delegated authority approval by the FRBSF timed to collude with the OCC with its conflicts of interest must be rescinded." Watch this site.

August 3, 2020

Federal Reserve Rubber Stamps Varo Into Banking On Delegated Basis As Denies FOIAs

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - CJR - PFT

South Bronx, July 28–  How corrupt has the Federal Reserve become using the COVID-19 pandemic as ground cover? Well, despite rules that substantively challenged applications can only be approved by the Board of Governors in DC, on July 28 the Fed rubber stamped on a delegated basis fintech Varo's application to form a bank holding company. It is an unprecedented now low - but happens while the Federal Reserve withholds under FOIA all information about the impact of COVID-19 on the application by Brazil-based Banco Bradesco. Something has gone dreadfully wrong on C St.

  Here's the Fed's - Federal Reserve Bank of San Francisco's - July 28 letter, sent to Inner City Press: "July 28, 2020 Via Electronic Mail Mr. Colin Walsh Varo Money, Inc. 222 Kearny Street, 9th Floor San Francisco, California 94108 RE: Varo Money, Inc., San Francisco, California (“Bancorp”), to become a bank holding company (“BHC”) through the acquisition of 100 percent of the voting shares of Varo Bank, N.A. (In Organization), Draper, Utah, pursuant to Section 3(a)(1) of the Bank Holding Company Act (“BHC Act”) Dear Mr. Walsh: The Federal Reserve Bank of San Francisco (“Reserve Bank”), acting under authority delegated by the Board of Governors of the Federal Reserve System (“Board”), and having considered the relevant statutory factors, hereby approves the subject application. In consideration of this filing, reliance was placed upon all the representations and the commitments made by or on behalf of Bancorp. No significant changes in the transaction should be made prior to consummation without our approval. Approval of the application is subject to the Board’s authority to require reports by and make inspections and examinations of BHCs and their subsidiaries, and to require such modification or termination of activities of a holding company or any of its subsidiaries as the Board finds necessary to ensure compliance with the BHC Act. Approval of the application is also subject to receipt of all other required regulatory approvals, non-objections, or consents with this transaction. The proposed transaction may be consummated upon approval. 1 Please notify the undersigned in writing when the transaction is consummated."

  Corrupt.

July 27, 2020

From Coinbase Brooks Into OCC With List of Conflicts Avant Aventas and Some of Citibank

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - CJR - PFT

UN GATE / SDNY COURT, July 22 – Acting U.S. Comptroller of the Currency Brian Brooks, as Coinbase’s chief legal officer,  was paid $1.4 million in salary -- separate from the stock options -- in the year and a half he spent with company, which had weighed seeking a charter through the OCC before making other moves to access the banking system."

  Inner City Press asked - and then requested under FOIA - what are the "other tech firms" as to which Brooks is acknowledging a conflict.

   The OCC wrote to Inner City Press, faux apologizing for withholding information it has requested about Otting until after he had left the agency. Inner City Press immediately wrote back requesting a copy of Brooks' ethics letter and list of companies as to which even he acknowledges a conflict of interest.

  On June 18, that simple request was denied and so a FOIA request was filed, see below.

  And now more than a month later on July 22 the OCC has provide to Inner City Press under FOIA a copy of the ethics memo that Brooks is recused on: Amazon (minus AWS), Avant, Aventas, Merrill Lynch, CoinBase, EarnUp, Spring Labs, TextIQ - and Citibank N.A. residential mortgage business." We'll have more on this.

July 20, 2020

SoFi Bid For Bank Charter From Pro FinTech Comptroller Brooks Is Opposed By Fair Finance Watch

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - The Source

SOUTH BRONX / SDNY, July 13 –   In the midst of the Coronavirus pandemic, and with a fintech and crypto-currency proponent installed as Acting Comptroller, SoFi and its controller SoftBank are seeking to get a U.S. bank charter. The WSJ and others have reported the bid, but it is not yet on the OCC's website (which often lags behind such that public comment periods end before notice is given). 

 Meanwhile Inner City Press' requests under the Freedom of Information Act into Acting Comproller Brian P. Brooks' conflicts of interest in the fintech and crypto-currency world have yet to be answers.  

And so on July 13 Fair Finance Watch filed with the OCC, including this: "July 13, 2020
 Office of the Comptroller of the Currency  DC Comptroller Brooks and Mr. Lybarger, Deputy Comptroller for Licensing  & Northeastern District Office 
 Re: Timely First Comment on SoFi's reported application to the OCC to get into banking 

Dear Mr. Lybarger, Ms. Cummings and others in the OCC:  This is a timely first comment opposing and requesting an extension of the required OCC's public comment period on reported proposal by SoFi to get a national bank charter.  

    This is a major proposal, by a fintech in which SoftBank has a large stake. Yet, it is not yet on the OCC's website, where as of July 13 the most recent Weekly Bulletin cuts on on July 4. The only charter application listed as open for comment is Monzo Bank; the New Bank application link does not work. So, any comment period will have be be extended. This is a request for the complete application, all portions that the OCC after review does not find withholdable under FOIA. 

     Inner City Press / Fair Finance Watch opposed SoFi's previous, suspended attempt to get into banking. Since then the questions have only grown.  

    For now, we note that Inner City Press asked the OCC's FOIA unit for a copy of Comptroller Brooks' conflict of interest list with fintechs but has yet to receive it. Pending receipt, we ask that Acting Comptroller Brooks be recused from this application and that you confirm this in writing.

      As to SoftBank, the dispute regarding another of its holdings, WeWork, portends the type of problems that regulators like the OCC are directed to keep out of, not invite into, the banking system.

     For the above reasons, including the ongoing COVID-19 pandemic lockdowns and restrictions, the comment period should not yet start or should extended, until in person public hearings can be held, and Comptroller Brooks' should be recused pending/and his conflict of interest list should be released." Watch this site. 

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July 13, 2020

Epstein Deals of Deutsche Bank Trigger $150M NYS Fine As UN Maxwell Deals UNexplained