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

August 8, 2022

On Community Reinvestment Act Reg Timely Comments In But Mergers Get Rubber Stamped

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

FEDERAL COURT / S Bronx, August 5 – Whether or not the U.S. Community Reinvestment Act will actually be enforced under thus Administration and its regulators remains an open question. Mergers continue to be rubber stamped. But the agencies requested comments by August 5, and Fair Finance Watch and Inner City Press and others in NCRC have met the deadline:

" On behalf of Inner City Press / Fair Finance Watch, this is a timely comment on the Community Reinvestment Act.    While below we address points from the joint proposal, since CRA is only enforcement on merger and expansion applications, the credibility and transparency of the agencies' enforcement of CRA on merger must be improved.to more fulsomely include review of fair lending laws, as well as CRA and negative impacts of recent mergers, from branch closings to raised prices to, yes, layoffs.

      The agencies currently do not sufficient consider "the probable effect of the transaction in meeting the convenience and needs of the community to be served." When the effect of a transaction includes further denuding lower income communities of branches, that is NOT meeting the convenience or needs of these communities.  

  The regulators are far too narrow. One recent example: Fair Finance Watch raised to the FRB and OCC that merger partner MUFG still does business in Russia amid its invasion of Ukraine. This is clearly risky (as well as immoral) and yet the Fed and OCC have not even asked MUFG or its proposed partner about it.  

 Also, employees are clearly "stakeholders" - yet the Federal Reserve had a footnote implying that no level of job loss is relevant to it in reviewing a merger. The CFPB should be consulted, as should legal data bases of discrimination cases. It must be made easier for the impacted public to comment, and to get copies of the regulators questions to the banks, and the banks answers.   The HHI understates the anticompetitive effects of recent mergers, with small banks being considered competitors to the Top Ten. More public comments, and more public hearings, are needed.   

  The agencies rubber stamp nearly all mergers. The bottom line is, some transactions should be denied. For example, when Investors Bank with its weak fair lending record got a conditional approval from the FDIC, it should have been a denial. The Federal Reserve absurdly allows Reserve Banks, which have no power to deny, to approve applications even by banks with rare Needs to Improve CRA ratings (Berkshire Bank).    As NCRC members, we join in NCRC's comments, including that CRA must explicitly consider bank activity by race and ethnicity... The agencies must improve their FOIA responsiveness and compliance, too.   Matthew R. Lee, Esq., Executive Director Fair Finance Watch / Inner City Press

August 1, 2022


As Toronto Dominion Bid To Buy First Horizon Opposed, Fed Defers to Murky OCC Website, Recommendations Given

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

SDNY / SOUTH BRONX, July 27 – Seemingly oblivious to US regulators stated desire to tighten up their merger review rules, specifically on fair lending, Toronto Dominion on February 28 announced a $13.4 billion proposal to buy First Horizon.

 Fair Finance Watch has been concerned by TD Bank's lending disparities for some time. Nationwide in 2020, TD Bank denied almost as many applications from African Americans (833) as it made in mortgage loans to African Americans (853). It was far more generous with white borrowers: 23,469 loans made, with only 9009 denials. 

 Fair Finance Watch immediately online noted that in New York State in 2020, TD Bank was even worse. It denied more mortgage applications from African Americans (255) that it made loans to African Americans in NYC (198). Again, TD Bank was far more generous with white borrowers in NYS: 3,558 loans made, with only 1714 denials. 

 Fair Finance Watch said: but just as the Federal Reserve begrudgingly is holding a public hearing on US Bancorp - MUFG / Union Bank, on March 8, there is even more reason to hold multiple hearings on a large and disparate Canadian bank buying Horizon.

Then: "The Federal Reserve Board (Board) and the Office of the Comptroller of the Currency (OCC) today announced a joint public meeting on the proposal by The Toronto-Dominion Bank, Toronto, Ontario, Canada, to acquire First Horizon Corporation, Memphis, Tennessee. The purpose of the public meeting is to collect information from a wide range of stakeholders as the agencies evaluate the proposed applications. By law, the agencies are required to evaluate: the convenience and needs of the communities to be served by the combined organization; the insured depository institutions’ performance under the Community Reinvestment Act; competition in the relevant markets; the effects of the proposal on the stability of the U.S. banking or financial system; the financial and managerial resources and future prospects of the companies and banks involved in the proposal; and the effectiveness of the companies and banks in combatting money laundering activities. The public meeting will be held virtually on August 18, 2022, at 9:00 a.m. EDT. Members of the public seeking to present oral comments must register by 12:00 p.m. EDT on July 28, 2022 through the online registration web page, which will be updated with registration details by June 8, 2022."

 But as of July 27, the Fed's link is to an OCC website which does not provide information about registering for the public meeting, only commenting. Fair Finance Watch timely used the box to register, and asked for confirmation. So far, this:

"Your comment was submitted successfully! Comment Tracking Number: l63-3wqi-yw6q  Your comment has been sent for review. This process is dependent on agency public submission policies/procedures and processing times. Once the agency has posted your comment, you may view it on Regulations.gov using your Comment Tracking Number.  Agency: COMPTROLLER OF THE CURRENCY (OCC) Document Type: Other Title: Merger Application - TD Bank NA - First Horizon Bank (2022-LB-Combination-326132) Document ID: OCC-2022-0010-0001  Comment: This is a timely registration to testify at the Federal Reserve's and OCC's public hearing on the TD - First Horizon proposal. The link on the Fed's web page led here, which there this no clear place to register. But this is a timely request, please immediately confirm receipt."

Inner City Press has subsequently provided these recommendations to a responsive, or at least responding, OCC-er: "for grassroots community groups it should not be made difficult to comment, or to register for public meetings. The press release announcing a public meeting on a merger should link directly to a simple interface to register. I am not sure that a "summary of expected testimony" should be required  -- and even if it is, should not be limited to 200 characters." Watch this site.

July 25, 2022

After Federal Reserve Talked 1-Way on CRA No Live Qs FRBNY Provide Off Record Reply

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

FEDERAL COURT / S Bronx, July 19 – Whether or not the U.S. Community Reinvestment Act will actually be enforced under the new Administration and its regulators remains an open question. But no live questions were taken by the Federal Reserve Bank of New York when it talked, one-way, about the CRA this month.

"This virtual event is intended for banks, consumer and community organizations, CRA stakeholders, and the general public. Selected questions submitted upon registration will be addressed during the event. There will not be live questions."

  Inner City Press asked them, "Why was it decided by the FRBNY that "there will be no live questions"? Who decided it?"

  On July 12, after the event, a "Corporate Communication Associate" at the FRBNY who demanded to not be named emailed back an answer labeled "off the record." Is this any way for a public institution to respond? Except, the Federal Reserve Banks are NOT public institution. Then why do they have a role in setting policy (like CRA) and approving bank mergers? We'll have more on this. And this:

The CFPB, Inner City Press has learned, has a policy of automatically closing complaints that name more than one institution, claiming that they can (or will) only forward the complaint to a single institution. This makes little sense on, for example, a wire transfer. But the CFPB Press office has yet to explain, so a FOIA request has been submitted. Watch this site.

 Back in December Inner City Press reported that BMO Harris' application to buy Bank of the West and its more than 500 branches from BNP would be a litmus test.

 Fair Finance Watch noted, from Day 1, that in 2020 BMO Harris denied many more mortgage applications from African Americans than it approved: 509 denied versus only 223 loans made to African Americans, nationwide. BMO's numbers for whites were the reverse: 9270 loans made, versus less then six thousand denials.

On May 17 the Federal Reserve and OCC announced that they will at least hold a public meeting: The public meeting will be held virtually on July 14, 2022, at 11:00 a.m. EDT. Members of the public seeking to present oral comments must register by 12:00 p.m. EDT on June 23, 2022, through the online registration webpage."

  Inner City Press / Fair Finance Watch visited the page on June 20, Juneteenth (Observed), in order to register - and found the Fed's "we want to know your views" - in 200 characters. Is that enough? Fair Finance Watch entered: "Concerns: BMO Harris HMDA disparities (nationside in 2020 only 223 mortgages to African Americans, vs. 9270 to whites), its destruction of evidence in a MN bankruptcy case;  BNP's activities in Russia." 

  Next came a series of Federal Reserve emails that went into spam, then a threat that if one didn't appear on screen for the Fed in one of four one-hour windows (three remaining) you couldn't testify. You had to ask to get the WebEx link. Inner City Press signed up - then came, at the same time, an FBI press conference about crypto fraud OneCoin, on which the Fed told Inner City Press under FOIA it has not a single document. Really?

 The penultimate slot conflicts with a press conference by the incoming president of the UN Security Council for July, Brazil. And July 5? The irony was, Inner City Press did this same sign up for the US Bancorp - MUFG public meeting. Why have to do it again?

We testified, and commented again in writing by the July 19 deadline. We'll have more on this- watch this site.

July 18, 2022

As BMO Harris Seeks Bank of the West Bulls Exec Shills & Fair Finance Watch Cites Ukraine

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

FEDERAL COURT / S Bronx, July 14 – Whether or not the U.S. Community Reinvestment Act will actually be enforced until the new Administration and its regulators remains an open question. Back in December Inner City Press reported that BMO Harris' application to buy Bank of the West and its more than 500 branches from BNP would be a litmus test.

 Fair Finance Watch noted, from Day 1, that in 2020 BMO Harris denied many more mortgage applications from African Americans than it approved: 509 denied versus only 223 loans made to African Americans, nationwide. BMO's numbers for whites were the reverse: 9270 loans made, versus less then six thousand denials.

On May 17 the Federal Reserve and OCC announced that they will at least hold a public meeting: The public meeting would be held virtually on July 14, 2022.

And on that day, Fair Finance Watch testified, then Inner City Press live tweeted, below:

Good afternoon. I'm Matthew Lee and on behalf of Fair Finance Watch and Inner City Press, this three minute statement concerns the proposal by Bank of Montral Harris to acquire BNP Paribas' Bank of the West. [Ad libbed about the need for more hearings on mid-sized mergers, and for Fed and OCC merger process review as FDIC has; named-checked Michael Barr and his duties.]

On the Community Reinvestment Act and fair lending. Fair Finance Watch conducted an analysis of the 2021 Home Mortgage Disclosure Act data of BMO Harris Bank and finds the disparities troubling.  In 2021 nationwide, BMO Harris Bank made only 289 mortgages to African Americans, versus 10,709 to whites. BMO Harris Bank's denial rate disparty was even more troubling: 5,889 denials to whites, half of its number of loans to whites. For African Americans, 647 denials, roughly three times it number of loans of to African Americans. A five to one disparity?

These disparities should not just result in a Fed footnote that the data cited by Fair Finance Watch is accurate but HMDA data is not probative. The recently confirmed Governors, particularly yesterday's confirmee Michael Barr, should go on the record on this before the Board rules. 

 As you will hear from other witnesses...  there are branch closing issues that should be addressed.  

 There is another issue which Inner City Press hereby timely raises to the Federal Reserve Board: the questionable and shifting position of BNP Paribas on Russia and its war on Ukraine. This year BNP told its employees to watch out from criticizing Russia's invasion, even on social media. See, e.g., this: "Watch what you say about Russian invasion, BNP Paribas warns bankers - Bank tells staff to clarify that any social media posts represent their own, personal views."

 As a managerial and corruption issue, BMO Harris was exposed by U.S. Bankruptcy Judge Kathleen Sanberg, who ruled that BMO “intentionally destroyed and failed to preserve” evidence of emails and other communications between the Petters company and its bank. She sanctioned BMO by saying the trustee could tell the jury about the destroyed evidence and also introduce documents over the bank’s objection. See, Kelley v. BMO Harris Bank N.A., 19-cv-01756, U.S. District Court, District of Minnesota (St. Paul).   These issues must be addressed; on the current record, the application should not be approved.

Then, the threadette:

Just testified to the Fed and OCC about Bank of Montreal - BNP Paribas merger, urging both regulators to do better. Beyond lending disparities, raised BMP's ham-handed gagging of its employees about the war in Ukraine, and a troubling BMO case 19-cv-01756

Corporate circus: Over-the-top testimony in favor of merger of Bank of Montreal & BNP Paribas' Bank of the West is Reinsdorf of the NBA's Chicago Bulls. Mortgage lending disparities, shameful positions on Ukraine and destruction of evidence ignored. Bull, indeed.

Collusion circus: so many of those supporting the merger begin identically, calling regulators Alison Tho, Colette Fried, Ben Olson, Jason Almonte & Donna Murphy "Commissioner" that it's clear they were coordinated. The banks are having / forcing borrowers to sing

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

July 11, 2022

To Community Reinvestment Act Challenge to United Community Bank - Progress, A Dodge

By Matthew Russell Lee, Patreon Maxwell Book
BBC-Guardian UK - Honduras - ESPN NY Mag

SDNY COURTHOUSE, July 8 – Will the Community Reinvestment Act actually be enforced against banks with disparate lending records?

Fair Finance Watch, with Inner City Press on the FOIA, is raising the issue to regulators, on June 22 to the Federal Reserve and FDIC on United Community Bank

Dear Chair Powell, Secretary Misback and others in the FRS:

  This is a request for a full copy of, and a timely first comment on, the Applications of United Community Banks, Inc., to merge with Progress Financial Corporation, and subsidiary, Progress Bank and Trust, both of Huntsville, Alabama.  As an initial matter, this is a request that the FRS immediately send by email to Inner City Press all non-exempt portions of the applications / notices for which the Applicants have requested confidential treatment.  Fair Finance Watch has been tracking United Community Bank and finds it lending patterns, including in the newly released 2021 HMDA data not taken into account in CRA exams, troubling.

  In South Carolina in 2021, United Community Banks made 1482 mortgage loans to whites with 310 denials. Meanwhile to African Americans in the state it made only THIRTY NINE loans, while denying fully sixteen applications. A referral should be made to the DOJ for fair lending violations.    Nationwide, United Community Banks is scarcely better. In 2021 overall it made 9252 mortgage loans to whites with 1852 denials. Meanwhile to African Americans nationwide it made only 362 loans, while denying fully 131 applications. A referral should be made to the DOJ for a pattern and practice of fair lending violations.    Public evidentiary hearings are needed, at least like the public meeting the Fed has belatedly set on two Canadian banks' acquisition proposals in the US.  

   FFW and Inner City Press have been deeply concerned about the rush by the Federal Reserve to rubber-stamp mergers by redliners. This has been killing the Community Reinvestment Act and 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

On June 23, the Fed wrote to the applicant's lawyers: June 23, 2022  Lee Kiser Nelson Mullins Riley & Scarborough LLP  2 W. Washington Street, Suite 400  Greenville, South Carolina 29601  Lee.kiser@nelsonmullins.com Dear Mr. Kiser: This refers to the application by United Community Banks, Inc., Blairsville, Georgia, to merge  with Progress Financial Corporation, and thereby acquire Progress Bank and Trust (Bank), both  of Huntsville, Alabama, pursuant to section 3(a)(5) of the Bank Holding Company Act.  Enclosed is a copy of a letter received from Matthew Lee, Esq., Executive Director Inner City  Press/Fair Finance Watch, commenting on the application.  A response to the comments should be received by this Reserve Bank within eight business days  from the date of this letter. In order to expedite processing of your application, please send  copies of your response to the Reserve Bank, the Board of Governors, the protestant, and to the  supervisory agencies that initially received copies of the application.

  And when United Community Banks responded, calling it Project Artemis, they argued "Mr. Matthew R. Lee of Inner City Press/Fair Finance  Watch submitted a comment in opposition to the merger of United and Progress on June 22, 2022.  This letter provides United’s response to the concerns raised by Mr. Lee.  The comment submitted by Mr. Lee requests that the Application not be approved in light  of concerns related to the Bank’s 2021 mortgage lending record, and requests that the comment  period be extended and evidentiary hearings be held regarding the Application.  I. Mortgage Lending Record  Mr. Lee cites 2021 Home Mortgage Disclosure Act (“HMDA”) data, particularly the  volume of mortgage loans made by the Bank to African-American borrowers. Specifically, Mr. Lee asserts that the Bank denied mortgage loan applications of African-American borrowers more  frequently than those of white borrowers in South Carolina and “nationwide.” United respectfully confirms for the reader that the Bank has a Southeastern—not nationwide—mortgage lending  footprint consisting of locations in South Carolina, Georgia, North Carolina, Florida, and Tennessee.  2 Mr. Lee’s comment letter attempts to evaluate United’s lending performance nationwide. Nationwide aggregates  can provide a distorted picture of a bank’s lending practices and have limited value because lenders’ geographic  footprints include differing proportions of racial or ethnic minorities. Accordingly, we understand that regulators do  not rely on aggregated nationwide data as a basis on which to assess a bank’s far lending performance in multiple  geographies.  United appreciates the opportunity to respond to the comments made on the Application  and believes that all substantive issues raised by Mr. Lee have been addressed." Well, no.

Watch this site.

July 4, 2022

Community Reinvestment Act Challenge to United Community Bank - Progress, Test Case

By Matthew Russell Lee, Patreon Maxwell Book
BBC-Guardian UK - Honduras - ESPN NY Mag

SDNY COURTHOUSE, June 24 – Will the Community Reinvestment Act actually be enforced against banks with disparate lending records?

Fair Finance Watch, with Inner City Press on the FOIA, is raising the issue to regulators, on June 22 to the Federal Reserve and FDIC on United Community Bank

Dear Chair Powell, Secretary Misback and others in the FRS:

  This is a request for a full copy of, and a timely first comment on, the Applications of United Community Banks, Inc., to merge with Progress Financial Corporation, and subsidiary, Progress Bank and Trust, both of Huntsville, Alabama.  As an initial matter, this is a request that the FRS immediately send by email to Inner City Press all non-exempt portions of the applications / notices for which the Applicants have requested confidential treatment.  Fair Finance Watch has been tracking United Community Bank and finds it lending patterns, including in the newly released 2021 HMDA data not taken into account in CRA exams, troubling.

  In South Carolina in 2021, United Community Banks made 1482 mortgage loans to whites with 310 denials. Meanwhile to African Americans in the state it made only THIRTY NINE loans, while denying fully sixteen applications. A referral should be made to the DOJ for fair lending violations.    Nationwide, United Community Banks is scarcely better. In 2021 overall it made 9252 mortgage loans to whites with 1852 denials. Meanwhile to African Americans nationwide it made only 362 loans, while denying fully 131 applications. A referral should be made to the DOJ for a pattern and practice of fair lending violations.    Public evidentiary hearings are needed, at least like the public meeting the Fed has belatedly set on two Canadian banks' acquisition proposals in the US.  

   FFW and Inner City Press have been deeply concerned about the rush by the Federal Reserve to rubber-stamp mergers by redliners. This has been killing the Community Reinvestment Act and 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

On June 23, the Fed wrote to the applicant's lawyers: June 23, 2022  Lee Kiser Nelson Mullins Riley & Scarborough LLP  2 W. Washington Street, Suite 400  Greenville, South Carolina 29601  Lee.kiser@nelsonmullins.com Dear Mr. Kiser: This refers to the application by United Community Banks, Inc., Blairsville, Georgia, to merge  with Progress Financial Corporation, and thereby acquire Progress Bank and Trust (Bank), both  of Huntsville, Alabama, pursuant to section 3(a)(5) of the Bank Holding Company Act.  Enclosed is a copy of a letter received from Matthew Lee, Esq., Executive Director Inner City  Press/Fair Finance Watch, commenting on the application.  A response to the comments should be received by this Reserve Bank within eight business days  from the date of this letter. In order to expedite processing of your application, please send  copies of your response to the Reserve Bank, the Board of Governors, the protestant, and to the  supervisory agencies that initially received copies of the application.

Watch this site.

June 27, 2022


Community Reinvestment Act Challenge to United Community Bank - Progress, Test Case

By Matthew Russell Lee, Patreon Maxwell Book
BBC-Guardian UK - Honduras - ESPN NY Mag

SDNY COURTHOUSE, June 24 – Will the Community Reinvestment Act actually be enforced against banks with disparate lending records?

Fair Finance Watch, with Inner City Press on the FOIA, is raising the issue to regulators, on June 22 to the Federal Reserve and FDIC on United Community Bank

Dear Chair Powell, Secretary Misback and others in the FRS:

  This is a request for a full copy of, and a timely first comment on, the Applications of United Community Banks, Inc., to merge with Progress Financial Corporation, and subsidiary, Progress Bank and Trust, both of Huntsville, Alabama.  As an initial matter, this is a request that the FRS immediately send by email to Inner City Press all non-exempt portions of the applications / notices for which the Applicants have requested confidential treatment.  Fair Finance Watch has been tracking United Community Bank and finds it lending patterns, including in the newly released 2021 HMDA data not taken into account in CRA exams, troubling.

  In South Carolina in 2021, United Community Banks made 1482 mortgage loans to whites with 310 denials. Meanwhile to African Americans in the state it made only THIRTY NINE loans, while denying fully sixteen applications. A referral should be made to the DOJ for fair lending violations.    Nationwide, United Community Banks is scarcely better. In 2021 overall it made 9252 mortgage loans to whites with 1852 denials. Meanwhile to African Americans nationwide it made only 362 loans, while denying fully 131 applications. A referral should be made to the DOJ for a pattern and practice of fair lending violations.    Public evidentiary hearings are needed, at least like the public meeting the Fed has belatedly set on two Canadian banks' acquisition proposals in the US.  

   FFW and Inner City Press have been deeply concerned about the rush by the Federal Reserve to rubber-stamp mergers by redliners. This has been killing the Community Reinvestment Act and 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

On June 23, the Fed wrote to the applicant's lawyers: June 23, 2022  Lee Kiser Nelson Mullins Riley & Scarborough LLP  2 W. Washington Street, Suite 400  Greenville, South Carolina 29601  Lee.kiser@nelsonmullins.com Dear Mr. Kiser: This refers to the application by United Community Banks, Inc., Blairsville, Georgia, to merge  with Progress Financial Corporation, and thereby acquire Progress Bank and Trust (Bank), both  of Huntsville, Alabama, pursuant to section 3(a)(5) of the Bank Holding Company Act.  Enclosed is a copy of a letter received from Matthew Lee, Esq., Executive Director Inner City  Press/Fair Finance Watch, commenting on the application.  A response to the comments should be received by this Reserve Bank within eight business days  from the date of this letter. In order to expedite processing of your application, please send  copies of your response to the Reserve Bank, the Board of Governors, the protestant, and to the  supervisory agencies that initially received copies of the application.

Watch this site.

June 20, 2022

Bank of America Is Sued for Not Fulfilling CRA Pledge in Hawai'i As Fed Rubberstamps Mergers

By Matthew Russell Lee, Patreon Maxwell Book
BBC-Guardian UK - Honduras - ESPN NY Mag

SOUTH BRONX / SDNY, April 11 –    With the mega-merger horse largely out of the barn in the US, Citibank too big to question for its business in Russia even as JPMorgan Chase admits gambling a billion dollars they while closing branches in NYC, the smallest of regulators had started a review.  But where is the Community Reinvestment Act in mergers? And where is the follow up on and enforcement of CRA commitments?

  Bank of America has been sued for not following through: "Nā Po‘e Kōkua, a Hawaii nonprofit corporation, on behalf of native Hawaiians filed a Complaint for Damages, Injunctive, and Equitable Relief, Racketeer Influenced and Corrupt Organizations Act (RICO), filed pursuant to 18 U.S.C.§1962(c), 18 U.S.C. §§ 1964 (a)(c), and 18 U.S.C.§§1341,1343; The Ku Klux Klan Act, 42 U.S.C. § 1983; and for the Establishment of a Hawaii Constructive Trust RE: $150 Million FHA-247 Loan Commitment against Bank of America Corporation for decades of discriminatory practices and its open and notorious denial of a $150 Million FHA-247 originated loan commitment made to federal banking regulators in 1994 for the benefit of native Hawaiians, which was due to be completed in 1998, and remains unfulfilled.

"Sandra Perez, former Bank of America, N.A. Community Investment Officer, Affidavit4. On May 4, 2022, Nā Po‘e Kōkua obtained an Affidavit from Sandra Perez, former Vice President, Community Investment Officer at Bank of America, N.A. , who worked at BANA during the years 1994-2000. 5. Ms. Perez was part of the dedicated executive team assigned to handle 1 Bank of America, N.A. (“BANA”) is an indirect wholly owned subsidiary of Bank of America Corporation (“BAC”), which through its predecessor entity, BankAmerica Corporation, operated retail banks in Hawaii from 1992–1997, and is therefore implicated in the loan commitment allegations although not specifically named as a party defendant hereto. 3 Case 1:22-cv-00238 Document 1 Filed 05/31/22 Page 3 of 106 PageID #: 3 BANA’s response to Nā Po‘e Kōkua’s inquiry in 1997 about the status of the unfulfilled $150 Million FHA-247 mortgage loan commitment. [Exhibit 1, ¶ 18] 6. As stated in the Perez Affidavit: “By 1997, BANA decided to leave its retail presence in Hawaii. However, BANA had not fulfilled the Commitment made to the Federal Regulators.” [Exhibit 1, ¶ 15] 7. Ms. Perez reviewed the 2020 federal case filings in Bank of America, et al., v. County of Maui, Case No.: 1:20-cv-00310-JMS-WRP2020 (DHI), and stated that “BANA’s argument was laced with the truth but polluted with lies”, noting its “calculated use of terminology” in replacing Commitment with its words of choice being “goal, initiative, pledge, or aspiration” used to describe its $150 million dollar FHA-247 mortgage loan commitment made to native Hawaiians. Perez concluded that BANA’s lawsuit against Maui County “at its core presents a false narrative.” [Exhibit 1, ¶¶ 2, 3] 8. “The genesis of the $150 Million Commitment was not because BANA was feeling philanthropic, it was because BANA was being accused of discrimination and violations of federal law”, Perez said in her Affidavit." We'll have more on this.

June 13, 2022

Former FDIC Boss and Bank Shill McWilliams Cashes Out to Cravath in DC, Bad Banks Line Up

By Matthew Russell Lee, Patreon Maxwell Book
BBC-Guardian UK - Honduras -