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. See, in November 2021, Inner City Press' book "Belt and Roadkill," here


April 22, 2024

  As US bank regulations rubber stamp mergers, they withhold from the public even the applications they are approving. When the OCC put out for comment its FOIA regulations, Inner City Press commented:

April 19, 2024

RE: Docket ID OCC–2022–0008 - FOIA

Acting Comptroller Hsu and others at the OCC:

    Inner City Press, as an active FOIA requester to the OCC, timely comments on your pending regulation to demand that the OCC rule on the propriety of all requests for confidential treatment during the comment period on an application - or automatically extend the comment period.

  Too often, applicant national bank over-request confidential treatment, but benefit from it due to the OCC's slow processing of FOIA requests. Case in point is Capital One / Discover - Inner City Press on February 19 submitted a request for communications between the OCC and the banks. Still none of those records as of April 19, as the comment period is set to close. (We expect it to be extended, but this is not the case on most applications).

  Nor even on the application has the OCC ruled on the propriety of the requests for confidential treatment. This must be addressed by the OCC.

   There is other FOIA problems at the OCC - as well as some polite staffers, we note - but we emphasize the above to ensure consideration and action.

  Expectantly,

 

Matthew R. Lee, Esq., Executive Director
Inner City Press / Fair Finance Watch
Bronx, New York

April 15, 2024

Lakeland Bank DOJ Deal Left Disparities So Protest Now Fed Rubber Stamps Provident

by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX, NY, April 11– When the US Department of Justice sued and immediately settled with Lakeland Bank for fair lending violations, it announced a proposed merger with Provident Bank.

As if to sweep it under the carpet.

And when Fair Finance Watch looked into it, it found that the DOJ settlement did not address in any way the banks' disparities in New York. So on December 1, the FDIC's comment deadline, it filed a protest, with Inner City Press on the FOIA.

Jump cut to March 15, 2023, when Provident's Deputy General Counsel filed a letter with the New York Fed, cc-ing Rodgin Cohen - only on New Jersey, nothing on the disparities in New York.

On January 18 Provident asked two Board questions - by withholding the entire answers. Inner City Press immediately FOIAed: "The entire response is withheld, about fair lending compliance, including public commitments that are unfulfilled. This cannot stand; the information must be provided before the Board acts in any way on the application (other than denial.)"

Jump cut to mid-February: while still not providing the withheld past answer, the Fed asked more questions. Letter here.

On February 27 Provident provided spin, including that "under the consent order that it entered into with the U.S. Department of Justice.  These obligations require Lakeland Bank to, among other things, establish a $12  million loan subsidy fund to increase credit for consumers applying for loans in  majority-Black and Hispanic census tracts in a five-county area in and around  Newark, New Jersey" - but nothing where other disparities. Letter here.

On April 11, 2024, the Fed hauled off and approved, noting Inner City Press / Fair Finance Watch "objected to the proposal, alleging that in 2021, Provident Bank and Lakeland Bank made no home loans to African American individuals in New York State.30 30  The data cited by the commenter corresponds to publicly available 2021 data by Provident Bank and Lakeland Bank under HMDA. Following consummation of the proposed transaction, the combined organization will add to its assessment area Bronx and Kings counties, each of which includes a significant number of majority-minority and LMI communities... The Board also has considered the DOJ Consent Order, including Lakeland Bank’s efforts towards meeting its obligations under the DOJ Consent Order, and that the DOJ Consent Order binds Provident without further action by the Board." We'll see.

Watch this site.

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April 8, 2024

Amid Attack on CRA FirstSun HomeStreet Bid Hit on Disparities Now Belated Partial Response

by Matthew Russell Lee

SOUTH BRONX, April 1 – As US bank regulators talk about working to increase the fairness of the financial system, and closely scrutinizing mergers and the spread of bad practices, banks continue to assume they can combine.

  Before the Capital One - Discover proposal, and ABA lawsuit against the Community Reinvestment Act regulation, there was  FirstSun Capital Bancorp of Denver and Dallas saying it will merge with Homestreet, Inc. and Homestreet Bank of Seattle, Washington. 

  On February 23, 2024 Fair Finance Watch with Inner City Press on the FOIA filed with the Federal Reserve: "FirstSun's flagship Sunflower Bank, in Texas in 2022, made 694 mortgage loans to whites, and only 41 to African Americans. Meanwhile it denied 12 applications from African Americans, and only 34 from whites.   This is disparate, and more disparate both than the aggregate in Texas. 

    Nationwide in 2022, Sunflower Bank made 3059 mortgage loans to whites, and only 194 to African Americans. Meanwhile it denied 49 applications from African Americans, and only 259 from whites. 

   For the record, on managerial resources and otherwise, note that on September 27, 2023, FirstSun Capital Bancorp, the parent company of Sunflower Bank, Guardian Mortgage and First National 1870 (collectively, “Sunflower”), filed a notice of data breach with the Attorney General of California... an unauthorized party likely took advantage of the flaw in the MOVEit software and downloaded copies of files [containing] personally identifiable information."

   HomeStreet, meanwhile, is politely said to have had a "tough" 2023.

More than a month later, FirstSun emailed Fair Finance Watch and Inner City Press a response, referring to, but not providing copies of, letters of support it says it has procured. Nor has the Federal Reserve forwarded these along, or put them online. We'll have more on this.

     FFW and Inner City Press have been deeply concerned about the rush by the Federal Reserve to rubber-stamp mergers by redliners, money launderers and predatory lenders. This has been killing the Community Reinvestment Act and so a timely request public hearings.


April 1, 2024

Prosperity Bank Hit by CRA Challenge to Lone Star Bank now FDIC Condition Reimposed

By Matthew Russell Lee, Patreon

FEDERAL COURT / S Bronx, March 29 – Whether or not the U.S. Community Reinvestment Act will be again enforced under this Administration and its regulators including under the incoming divided Congress is an open question.

   On November 25, 2022 Fair Finance Watch with Inner City Press on the FOIA filed comments with the Federal Deposit Insurance Corporation against the applications by Prosperity Bank in Texas. In April 2023, the FDIC imposed conditions on one - and in March 2024, on the other, Lone Star.

November 25, 2022 

Federal Deposit Insurance Corporation Attn: Chairman Martin J. Gruenberg Dallas Kristie K. Elmquist, Regional Director Julie V. Banfield, Deputy Regional Director Chris Finnegan

Re: Comment on Applications by Prosperity Bank, El Campo, Texas to acquire Lone Star Bank of West Texas and FirstCapital Bank of Texas, N.A. 

Dear Chairman Gruenberg, Regional Director Elmquist, Ass't Regional Director Finnegan and others at the FDIC:   This is a request for all information in the possession of the FDIC about, and a timely comment on, the Applications of Prosperity Bank, El Campo, Texas to acquire Lone Star Bank of West Texas and FirstCapital Bank of Texas, N.A. which appear on the FDIC website under "Applications In Process Subject to the CRA Report" with an initial comment periods running through December 16. This comment is timely.  

   The applicant Prosperity Bank in 2021 in Texas based on its disparate marketing made 5453 mortgage loans to whites -- while making only 188 loans to African Americans. Meanwhile it denied fully 94 applications from African Americans, versus only 1186 from whites. This is far out of keeping with the demographics, and others lenders, in Texas in particularly in Prosperity Bank's CRA assessment areas - this is outrageous.    

  The applicant Prosperity Bank in 2021 in Oklahoma based on its disparate marketing made 320 mortgage loans to whites -- while making only 38 loans to African Americans.  This is far out of keeping with the demographics, and others lenders, in Oklahoma in particularly in Prosperity Bank's CRA assessment areas - this is outrageous.   Very Truly Yours,     Matthew Lee, Esq.   Executive Director  Inner City Press/Fair Finance Watch

On April 6, 2024 sent April 10, the FDIC imposed this condition: "After a careful review of the concerns, the FDIC decided to approve the application with the following condition. This condition will help ensure the home mortgage lending needs of African American populations in Prosperity Bank’s assessment areas are met. Enhance the bank’s Fair Lending Action Plan (Plan) adopted by the Board of Directors of Prosperity Bank and submit changes to the FDIC for approval within 60 days of the application approval date. The Plan updates and revisions, as applicable, should provide strategies to improve the volume of home mortgage applications from, and originations to African American applicants within each of the designated assessment areas established in Texas. The Plan should also provide strategies to improve the volume of home mortgage applications from, and originations in majority-minority census tracts and majority-Hispanic tracts within designated assessment areas in Texas. The enhancements should be developed in the context of available demographic data, as well as safe and sound lending considerations, and provide for periodic review of the Bank's efforts, using measurable criteria, to assess actions and progress. The Bank will continue to provide quarterly updates to the FDIC's Dallas Regional Office detailing the Bank's progress under the Plan."

The condition was re-imposed in March 2024 when the FDIC approved the Lone Star Bank application. Watch this site.

Watch this site.

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March 25, 2024

FDIC Imposes CRA Condition After Mississippi Bank Merger Challenged by Fair Finance Watch

by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX, March 23 – While the US bank regulators purport to be cracking down on fair lending and other abuses of consumers, they continue to allow banks of all sizes to pass exams and merge when they apply, despite deep disparities.  

On December 9, Fair Finance Watch (with Inner City Press on the FOIA) commented to the FDIC: Merchants & Marine Bank to acquire Mississippi River Bank:

   The applicant Merchants & Marine Bank in 2022 in  Mississippi based on its disparate marketing made 148mortgage loans to whites -- while making only 10 loans to African Americans. This is far out of keeping with the demographics, and others lenders, in Mississippi in particularly in Merchants & Marine Bank's CRA assessment areas. 

  In Alabama it is worse. And it would get worse in Louisiana, into which the bank is apply to expand via Mississippi River Bank.

   The applicant Merchants & Marine Bank in 2022 in Alabama based on its disparate marketing made 26 mortgage loans to whites -- and NONE. to African Americans.

 This is far out of keeping with the demographics, and others lenders, in Alabama in particularly in Merchants & Marine Bank's CRA assessment areas - this is outrageous. 

  There are other issues.... Fair Finance Watch is requesting an extension of the public comment period, evidentiary hearings and that, on the current record, the applications not be approved.

On March 19, 2024, the FDIC recounted Fair Finance Watch / Inner City Press' CRA protest and imposed a condition, to develop a plan to serve African American borrowers, we've uploaded it on DocumentCloud here.

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March 18, 2024

NYCB Was Gifted Signature Bank Now Otting Cash as CEO by Mnuchin Thumbs Nose at CRA

by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX / SDNY, March 16– With no public comment period, New York Community Bank was handed the 40 branches of Signature Bank, to re-open them as braches of Flagstar, which NYCB bought in a proceeding delayed by fair lending problems.

  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. And it was delayed.

  So, a fair lending rogue benefited from a bail out, or a bank with a former NYS Banking Superintendent Derrick Cephas, and Barney Frank, on its board of directors.

 Jump cut to early February 2024 and NYCB's stock price fell by 60%, Valley National down too.

On February 29, NYCB's long time CEO Thomas Cangemi was out and NYCB said it had "identified material weaknesses." Why didn't the regulators identify them, as Fair Finance Watch protested Flagstar, and on Signature?

Now the kicker: Steve Mnuchin invests, and taps as CEO of NYCB Joseph Otting, who led attacks on the Community Reinvestment Act, and scammed the CRA comment process when last he headed a bank.

 New York Community Bank CEO Joseph Otting will receive an annual base salary of $1.25 million, the bank disclosed in a Securities and Exchange Commission filing Friday.  Otting will also be eligible for an annual cash bonus with a target value of $2.25 million, but that amount could balloon to $4.5 million, according to the filing.  Otting is receiving a one-time, 10-year stock option award covering 15 million shares at $2 per share, NYCB said The options will vest over three years in equal quarterly installments, unless there’s a change in control of the bank. In that case, they’d vest immediately, the bank said.

So Otting may sell, or preside over the failure, of another bank, like OneWest.

We'll have more on this.

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March 4, 2024

Capital One Should Discover Merger Dead as FTC Hits Kroger & Inner City Press FOIAs Fed

by Matthew R. Lee

SOUTH BRONX, Feb 26 – Capital One will apply to buy Discover, in an anticompetitive deal that should be rejected by regulators if they mean what they have been saying. Public hearings should be held, not only on antitrust but also lending disparities at both companies. 

  On February 20 Capital One CEO Rich Fairbanks bragged about communications he's had with the regulators, then referred to "customary regulatory approvals." Inner City Press immediately submitted Freedom of Information Act requests to the Federal Reserve and OCC for all such communications. Both agencies confirmed receipt. The Fed wrote grandly that "You have provided facts regarding your qualification as a representative of the news media."

 But still no records as of March 2, when the FTC came out against Kroger's proposed $24.6B purchase of Albertsons, saying it "threatens shoppers & workers." So how could Capital One / Discover be approved?

February 26, 2024

Capital One Should Discover Merger Dead CEO Brags to Zombies Inner City Press FOIAs Fed

by Matthew R. Lee

SOUTH BRONX, Feb 20 – Capital One will apply to buy Discover, in an anticompetitive deal that should be rejected by regulators if they mean what they have been saying. Public hearings should be held, not only on antitrust but also lending disparities at both companies. 

  On February 20 Capital One CEO Rich Fairbanks bragged about communications he's had with the regulators, then referred to "customary regulatory approvals." Inner City Press immediately submitted Freedom of Information Act requests to the Federal Reserve and OCC for all such communications. Both agencies confirmed receipt.

 The call, a transcript of which was not posted hours later, consisted of largely craven questions from Capital One's stable of "analysts," including Goldman Sachs' Ryan Nash, TD Cohen's Moshe Orenbuch, from Citi an Aaron sitting in for Jill Shea, and finally JPMorgan's Rich Shane, who said "I'm not big on saying this on calls, but... congratulations." Really.

 As documented by Fair Finance Watch, Discover Bank in 2022 denied mortgage loans application from African Americans more than twice as frequently as those of whites. 

  Previously, Inner City Press and NCRC challenged Capital One's acquisition of ING Direct, see here.This time, given the antitrust enforcement claims being made in DC, this proposal should be dead in the water. Watch this site. 

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February 19, 2024

As JPMorgan Chase Seeks to Grab More Money in Affluent Areas Fair Finance Watch Protests

by Matthew R. Lee

South Bronx, Feb 17 -- The monopolization of banking in the US has seen JPMorgan Chase grow well beyond the 10% of nationwide deposit cap that Congress purported to set, as Chase was awarded First Republic and parts of other failed banks. 

  Now Chase proposes to gobble up even more deposits, this time by opening hundreds of branches, in affluent and disproportionately non-diverse communities. 

  Chase in applying to its purported regulator the Office of the Comptroller of the Currency or OCC has chosen not to include the street addresses of the branches it proposes to open.

So on February 17 Fair Finance Watch, with Inner City Press on the FOIA, submitted a sample first comment to the OCC, Acting Comptroller Michael J. Hsu and others, comparing branches Chase proposes to close and open in this instance, February 2 and February 6, in Ohio:  

  On February 2, 2024 the OCC received a filing from Chase to close Eastgate Wyler Park    867 WYLER PARK DRIVE         CINCINNATI    OH    45245    Hamilton    080223A  

On February 6, 2024, the OCC received an application from Chase to open Maineville Town Center    NWC of OH Hwy 48 and US Hwy 22         Maineville    OH    45039    Warren    217362A  

Now, because Chase chooses to list its proposed branch openings not by street address (which information it has) but instead by street-corner (apparently, even if not on a corner), we will herebelow compare the zip codes. [The OCC should henceforth require Chase and others to including street address and census tract in applications.]  

 In Zip Code 45245 where Chase is closing, there are 388 African American residents and 17,817 whites - significantly more diverse than Zip Code 45039 where Chase proposes to open (21,702 whites and only 191 African Americans).   

   In Zip Code 45245 where Chase is closing, fully 21% of households make less than $30,000, and 16% make between $30,000 and $50,000 - significantly lower income than Zip Code 45039 where Chase proposes to open (only 9% of households below $30,000 and only 12% between $30,000 and $50,000). 

  This comparison is troubling; the OCC should require Chase to (re) apply listing street addresses and census tracts, and should make its own comparisons, as this new Chase proposed strategy is rolled out.    

   Fair Finance Watch and Inner City Press are hereby opposing these applications / proposal (including proposed closings) and are requesting public hearing on this issue.

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February 12, 2024

ABA of Large Banks Sue CRA Reg on Day FNB Settles on Fair Lending after CRA Protest

by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX, NY Feb 5 – On the day a bank that has been permitted several mergers even as it engaged in discrimination settled those charges, on February 5 "The American Bankers Association, the U.S. Chamber of Commerce, Independent Community Bankers of America, Texas Bankers Association, Independent Bankers Association of Texas, Amarillo Chamber of Commerce and Longview Chamber of Commerce filed a lawsuit in the Northern District of Texas against the Federal Reserve, FDIC and OCC."

  Beyond venue shopping, the largest banks in the US are responsible for the ABA lawsuit - they are hypocrites, on which we'll have more.

Consider: First National Bank of Pennsylvania applied to the Federal Reserve to buy Yadkin bank in North Carolina, Fair Finance Watch challenged it on Community Reinvestment Act and fair lending grounds.  

 The Federal Reserve, as usually, rubber stamped the merger.   Now in February 2024 the Justice Department had sued and settled with FNB on fair lending grounds.

Inner City Press had wanted to ask DOJ about the Fed (including in its recent Patriot Bank action), but has been unable so far.  Watch this site

February 5, 2024

As OCC Proposes to End Automatic Approvals It Withheld under FOIA US Bank Letter it Used

By Matthew Russell Lee, Patreon

SOUTH BRONX NYC, Jan 29  – How untransparent and pro-bank are today's regulators, including the Office of the Comptroller of the Currency?

  We ask as the OCC on January 29, 2024 announced a proposal for what it pitched as more transparency in merger reviews. The proposal, they said, "detail[s] the types of deals that would typically secure approval and the issues that could complicate or derail transactions," Michael Hsu, the acting comptroller, said. The end of so-called automatic approvals is overplayed; a database would help. But too some, this appears to be a sop to the banks, not communities or consumers. Consider:

Back on February 10, 2023 came the OCC's denial in full of Inner City Press' Freedom of Information Act request about its approval of U.S. Bank's application to acquire Union Bank, which Fair Finance Watch and others challenged under the Community Reinvestment Act. 

 Inner City Press submitted the request in November 2022, and immediately clarified and narrowed the request after an OCC inquiry.

On February 10, 2023, the OCC responded - and withheld 16 pages in full

On February 14, Inner City Press filed its appeal.

On March 16, 2023, OCC Deputy General Counsel Patricia S. Grady denied the appeal in full - the bank's commitment letter the OCC based its approval all it totally secret. Letter on Inner City Press' DocumentCloud here. This is unacceptable. Will it be addressed?

  Watch this site.

January 29, 2029

  What is happening to the Federal Reserve? Beyond misrating Patriot Bank just before its DOJ redlining settlement, how the Fed is withholding info about its inquiry into Lakeland Bank's discrimination deal. Ten days ago - with no documents yet - Inner City Press / Fair Finance Watch FOIA-ed the Fed: "This is a formal FOIA request for the two exhibits withheld in full by Provident Financial Services, Inc., Jersey City, New Jersey in its January 18, 2024 Additional Information response in connection its pending application  to acquire Lakeland Bancorp, Inc., Oak Ridge, New Jersey, and thereby indirectly acquire Lakeland Bank, which recently settled lending discrimination charges with DOJ   The January 18 response recites then states: Provide an update to all action items included in the Consent Order, reflecting those items which have been completed and any other pertinent updates, including, but not limited to, the status of any deliverables required under the Consent Order that have not yet been completed. Please refer to the attached Confidential Exhibit 1 for a response to this Item.   The entire response is withheld, about fair lending compliance, including public commitments that are unfulfilled. This cannot stand; the information must be provided before the Board acts in any way on the application (other than denial.)


January 22, 2024


Patriot Bank Settled on Redlining After CRA Satisfactory Rating from Federal Reserve

by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX, Jan 20 – Patriot Bank in Tennessee settled redlining discrimination charges with DOJ on January 17, 2024.

But the Federal Reserve in 2022 gave Patriot Bank a "Satisfactory" rating under the Community Reinvestment Act, stating that "no evidence of discriminatory or other illegal  credit practices inconsistent with helping to meet community credit needs was identified." 

 So the Federal Reserve, at least its CRA exams and merger reviews, is not credible.

And DOJ? Settling for less than $2 million?

 Inner City Press has submitted a FOIA request to the Fed, on behalf of Fair Finance Watch, about another recent DOJ lending discrimiantion case and FRB merger, Provident / Lakeland - watch this site

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January 15, 2024

Disparate Hudson Valley Credit Union Wants to Gobble Up a Bank Removing it from CRA

by Matthew Russell Lee, Patreon Book Substack

SDNY COURTHOUSE, Jan 12 – The trend of credit unions buying banks is growing - and credit unions are not subject to the Community Reinvestment Act. Nor do some of them respect the fair lending laws.

  Take, this week, the proposed acquisition in New York of Catskill Hudson Bancorp by Hudson Valley Credit Union.

   Home Mortgage Disclosure Act data for 2022, reviewed by Inner City Press / Fair Finance Watch, show that Hudson Valley Credit Union made 141 loans to African Americans while denying more applications, 164, from African Americans. By contrast it made fully 2583 loans to white, which less than half than number of denials: 1128.

HVCU should be referred to the Justice Department for prosecution. But it will not be under the Community Reinvestment Act. This loophole must be closed.

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January 8, 2024

Truist Moving to Close 72 Bank Branches Amid Merger Fallout Covered Up by US Regulators

By Matthew R. Lee, FOIA docs

NEW YORK CITY, Jan 5 – Back when BB&T announced a $66 billion proposal to take over Suntrust Bank, they said they would close an undisclosed number of branches.

Then after Federal Reserve Governor Lael Brainard was asked by Inner City Press / Fair Finance Watch about the Fed's lax review of previous mergers, conveniently, the Fed "announce[d] termination of enforcement action with BB&T Corporation" for money laundering.

  Now in January 2024, the re-named Truist says it will close 72 branches by March. Nine branches are set to close in North Carolina and seven in the DC metropolitan area; also in Alabama, Georgia (8), Kentucky, Maryland and West Virginia. This is the result of the mergers the regulators allow, then don't follow up on.

We'll have more on this - watch this site. 

January 1, 2024

Old National Bank Bid for CapStar Protested After 2021 Settlement 2022 Lending Disparities

by Matthew Russell Lee

SOUTH BRONX, Dec 27 – As US bank regulators talk about working to increase the fairness of the financial system, banks with striking histories of discrimination, even histories acknowledged by settlement, blithely apply for approval to buy other banks. 

 So it is with Old National, which settled lending discrimination charges in 2021, but remained disparate after that - and now seeks to buy CapStar Bank in Nashville.   On December 27, Fair Finance Watch with Inner City Press on the FOIA filed comments with the Office of the Comptroller of the Currency:  "This is a timely first comment opposing and requesting an extension of the OCC's public comment period on the Applications by Old National to acquire CapStar.   As the OCC must know, Old National was the subject of fair lending discrimination charges and settled them in 2021. See, e.g., "Old National Bank preventing loan access to Black borrowers could be illegal, experts say"...    

But still in 2022, Old National in Indiana based on its disparate marketing made 2609 mortgage loans to whites, with 791 denials to whites -- while making only 114 loans to African Americans, with fully 97 denials.  This is unacceptable.  In 2022 in Minnesota, based on its disparate marketing, Old National made 850 loans to whites, with 223 denial and only 9 loans to African American, with just as many denials to African Americans: nine. This is totally unacceptable.      CapStar in Tennessee in 2022 made 1522 loans to whites with 125 denials, while making only 49 loans to African American, with ten denials. In North Carolina in 2022, CapStar made five loans to whites, and NONE to African Americans.    There is no public benefit to this proposal. 

   Fair Finance Watch and Inner City Press have been deeply concerned about the rush by the OCC's penchant to rubberstamp mergers by redliners. We timely request public hearings. The comment period should be extended; evidentiary hearings should be held; and on the current record, the application should not be approved

December 25, 2023

Sleazy as can be: U.S. Bank will pay $36 million over allegations the company illegally blocked out-of-work consumers from accessing unemployment benefits during the coronavirus pandemic, top federal banking regulators announced on Tuesday.  At the onset of the COVID-19 pandemic, U.S. Bank had contracts with at least 19 states and the District of Columbia to deliver unemployment benefits to millions of newly out-of-work Americans through its prepaid card.  But due to expanded antifraud controls, the nation's fifth-largest lender froze tens of thousands of prepaid card accounts without leaving users a way to regain access, according to the U.S. Office of the Comptroller of the Currency and U.S. Consumer Financial Protection Bureau.

December 18, 2023

  Fair Finance Watch's CRA filing in Mississippi has been deemed by the FDIC to "constitute a protest for purposes of this application:

Dear Mr. Lee,  This letter is to acknowledge receipt of your correspondence on December 9, 2023, concerning  an application filed by Merchants & Marine Bank, Pascagoula, Mississippi, to merge with  Mississippi River Bank, Belle Chasse, Louisiana.  We reviewed your correspondence in accordance with the guidelines of 12 C.F.R. Section 303.2  (c) and (1) and consider it to constitute a protest for purposes of this application. A determination on the request for a hearing has not yet been made and the FDIC will provide information regarding that request in subsequent correspondence.  cc: Merchants & Marine Bank CEO Clayton Legear

December 11, 2023