Welcome to Inner City Press’ CRA Report. Our other Reporters cover the financial services industry, human rights, the Federal Reserve, and other beats. ICP has published a book about the CRA-relevant topic of predatory lending - click here for sample chapters, a map, and ordering information. CBS MarketWatch of April 23, 2004, says the the novel has "some very funny moments," and that the non-fiction mixes "global statistics and first-person accounts." The Washington Post of March 15, 2004, calls Predatory Bender: America in the Aughts "the first novel about predatory lending;" the London Times of April 15, 2004, "A Novel Approach," said it "has a cast of colorful characters." See also, "City Lit: Roman a Klepto [Review of 'Predatory Bender']," City Limits, Oct. 2004. The Pittsburgh City Paper says the 100-page afterword makes the "indispensable point that predatory lending is now being aggressively exported to the rest of the globe." Click here for that review; click here to Search This Site Click here for Inner City Press' weekday news reports, from the United Nations and elsewhere.
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here
December
4, 2023
PA Merger Partner FNCB Admits Disparities As Link Was Hit by Fair Finance Watch Now Plan
By
Matthew Russell Lee, Patreon Maxwell
Book
SOUTH
BRONX, Dec 1 – Pennsylvania, Delaware and
Virginia are portrayed as diverse and ever
progressive places. But their banks, not so
much.
Consider
for example the merger on the rebound between
New York-based Link Bank and Partners Bancorp,
which recently broke off its proposed deal with
OceanFirst.
Inner
City Press and Fair Finance Watch have long
exposed redlining - and in this vein, on May 6
they filed a Community Reinvestment Act
challenge with the FDIC and Federal Reserve.
In
October, the FDIC required from LINKBANK a plan
to improve its lending to African Americans,
which Inner City Press has published on its
DocumentCloud
here.
On
November 10, Fair Finance Watch commented on an
even more disparate combination, Peoples
Security Bank and Trust Company bid to acquire
and merge with FNCB Bank, noting that on
Pennsylvania in 2022, Peoples Security Bank and
Trust Company made 532 HMDA-reported loans to
whites - and only FOUR to African Americans,
while denying five applications.
FNCB Bank in Pennsylvania in 2022 made 247
HMDA-reported loans to whites - and only ONE to
an African Americans, while denying three
applications. A referral should be made to the
DOJ for fair lending violations.
Now the banks have admitted to the FDIC: "FNCB
Bank’s preliminary HMDA data from the first
three quarters of 2023 reveals a significant
decrease in loan volume due to an unexpected and
unplanned change in FNCB Bank’s mortgage
processing system. In early 2022, FNCB Bank
partnered with a third party, Promontory
MortgagePath (“PMP”), to provide mortgage
fulfillment services. However, in October 2022,
PMP Deputy Regional Director Scott D.
Strockoz Federal Deposit Insurance Corporation
December 1, 2023 Page 6 unexpectedly
announced closure of the company due to the
unprecedented and rapid deterioration of the
mortgage market. PMP did not provide FNCB Bank
with advance notice of its decision. In order to
continue to serve the needs of its communities
during 2023, FNCB Bank brokered residential
mortgage loan applications to a third-party
lender pending the establishment of a new
processing system. Consequently, FNCB Bank
recorded a total of 42 brokered loan
applications through September 30, 2023, which
resulted in 32 loans originated by its
third-party lender partner. Because these
brokered loans were not closed in FNCB Bank’s
name, the loans are not included in FNCB Bank’s
2023 HMDA data. Accordingly, a review of FNCB
Bank’s preliminary 2023 HMDA data will indicate
that it did not meet 2022 peer benchmarks for
loan originations in MMCTs and loan applications
generated in LMI tracts when reviewed in FNCB
Bank’s assessment areas (which, for peer
comparison, includes only those institutions in
its assessment area with an application volume
between 50% and 200% of FNCB Bank’s). Due to
PMP’s withdrawal from its partnership with FNCB
Bank, the following trends are evident based on
a total of 45 mortgage applications and 33
originations reported by FNCB Bank as HMDA loans
during this period: • Applications from MMCTs
were 2.22% of total applications. •
Majority-Minority loan originations were 0%."
Zero. Watch this site.
November
27, 2023
CRA Challenged to Burke & Herbert on Summit Is Deemed Protest by FDIC despite Bogus Reply
By
Matthew Russell Lee, Patreon Maxwell
Book
SOUTH
BRONX, Nov 20 – Virginia and Delaware portrayed
as diverse and ever progressive places. But
their banks, not so much.
Consider
for example the proposed acquisition by
Viriginia-based Burke & Herbert Bank &
Trust Company of Summit Community Bank. Despite
a showing of disparities at Burke & Herbert
even worse than at Linkbank, which the FDIC
imposed a condition on, Burke on November 15
issued a vacuous response. They drop an
ad-hominen footnote which ignores that the
evidence put forward in a litigation survives
the suit's withdrawal.
On
November 20, the FDIC overruled Burke &
Herbert's position: "
Matthew Lee,
Esquire Executive Director Inner City Press/Fair
Finance Watch P.O. Box 20047 New York, New York
10017 Dear Mr. Lee: We received your e-mail
dated November 10, 2023, regarding the
application for Peoples Security Bank and Trust
Company to merge with FNCB Bank. We reviewed
your correspondence in accordance with the
guidelines of 12 C.F.R. Section 303.2(c) and
303.2(l), and we consider it a protest... Any
future comments should be sent to the applicant
and to this office."
Inner
City Press and Fair Finance Watch have long
exposed redlining - and in this vein, on October
28 they filed a Community Reinvestment Act
challenge with the FDIC:
"In
Virginia in 2022, Burke & Herbert Bank &
Trust Company made 104 mortgage loans to whites,
but only 12 to African Americans. This is out of
keeping with the demographics of its footprint,
and its competitors.
November
20, 2023
CRA Response by Burke & Herbert on Summit Merger Ignores FDIC Conditioning Linkbank
By
Matthew Russell Lee, Patreon Maxwell
Book
SOUTH
BRONX, Nov 15 – Virginia and Delaware portrayed
as diverse and ever progressive places. But
their banks, not so much.
Consider
for example the proposed acquisition by
Viriginia-based Burke & Herbert Bank &
Trust Company of Summit Community Bank. Despite
a showing of disparities at Burke & Herbert
even worse than at Linkbank, which the FDIC
imposed a condition on, Burke on November 15
issued a vacuous response. They drop an
ad-hominen footnote which ignores that the
evidence put forward in a litigation survives
the suit's withdrawal.
Inner
City Press and Fair Finance Watch have long
exposed redlining - and in this vein, on October
28 they filed a Community Reinvestment Act
challenge with the FDIC:
"In
Virginia in 2022, Burke & Herbert Bank &
Trust Company made 104 mortgage loans to whites,
but only 12 to African Americans. This is out of
keeping with the demographics of its footprint,
and its competitors.
Beyond
Virginia, Burke & Herbert Bank & Trust
Company is scarcely better. In 2022, Burke &
Herbert Bank & Trust Company overall made
119 mortgage loans to whites, but only 16 to
African Americans.
Summit Community Bank is also of concern. In
West Virginia in 2022 it made 403 mortgage loans
to whites, and only EIGHT to African Americans.
Meanwhile it denied 3 applications from African
Americans, and only 97 from whites (compared to
403 originations). This is disparate, and
more disparate both than the aggregate in West
Virginia.
And that's not even getting into Burke &
Herbert's overdraft fee abuses. More on that to
follow - more than conditions, this application
should be denied.
In
October, after a similar challenge by Fair
Finance Watch on data and complaints not even as
bad, the FDIC required from LINKBANK a plan to
improve its lending to African Americans, which
Inner City Press has published on its
DocumentCloud
here.
November
13, 2023
Fair
lending beat,
filed in the
Pennsylvania
edition: "
Fair
Finance Watch
has been
reviewing
Peoples
Security Bank
and Trust
Company and
FNCB Bank
including
their 2022
HMDA data not
taken into
account in any
CRA exam and
finds it
troubling.
In
Pennsylvania
in 2022,
Peoples
Security Bank
and Trust
Company made
532
HMDA-reported
loans to
whites - and
only FOUR to
African
Americans,
while denying
five
applications.
A referral
should be made
to the DOJ for
fair lending
violations.
FNCB Bank in
Pennsylvania
in 2022 made
247
HMDA-reported
loans to
whites - and
only ONE to an
African
Americans,
while denying
three
applications.
A referral
should be made
to the DOJ for
fair lending
violations."
November 6, 2023
Atlantic Union CRA Protested on American National Replies 2.4 Disparities Is Fine
by
Matthew Russell Lee, Patreon Book
Substack
SOUTH
BRONX NY, Nov 4 – Two of 2023's largest US
proposed bank mergers were announced this
summer: Atlantic Union applying to buy Atlantic
National in Virginia, and Banc of California to
buy PacWest. Fair Finance
Watch had been monitoring the banks, and on
September 25 commented to the Federal Reserve on
and against Atlantic Union - American National,
below.
On
October 6, mailed October 11, Atlantic Union's
counsel claims that it's fine that Atlantic
Union, in Virginia in 2022, made 2819 mortgage
loans to whites, and only 197 to African
Americans. Meanwhile it denied 159 applications
from African Americans, and only 944 from
whites.
Atlantic Union has told the Federal Reserve
that's fine.
That
is to say, beyond the 2.4 denial rate disparate,
American Union made fully 14 mortgage loans to
whites for every loan to an African
American. Statewide in Virginia for the
aggregate, the ratio was five to one.
This
is outrageous; again, American Union should be
referred by the FRB to the Department of
Justice.
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 we
timely request public hearings.
We'll have more on this.
***
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October
30, 2023
CRA Challenge to Burke & Herbert Summit Merger After Linkbank Conditioned by FDIC
By
Matthew Russell Lee, Patreon Maxwell
Book
SOUTH
BRONX, Oct 28 – Virginia and Delaware portrayed
as diverse and ever progressive places. But
their banks, not so much.
Consider
for example the proposed acquisition by
Viriginia-based Burke & Herbert Bank &
Trust Company of Summit Community Bank.
Inner
City Press and Fair Finance Watch have long
exposed redlining - and in this vein, on October
28 they filed a Community Reinvestment Act
challenge with the FDIC:
"In
Virginia in 2022, Burke & Herbert Bank &
Trust Company made 104 mortgage loans to whites,
but only 12 to African Americans. This is out of
keeping with the demographics of its footprint,
and its competitors.
Beyond
Virginia, Burke & Herbert Bank & Trust
Company is scarcely better. In 2022, Burke &
Herbert Bank & Trust Company overall made
119 mortgage loans to whites, but only 16 to
African Americans.
Summit Community Bank is also of concern. In
West Virginia in 2022 it made 403 mortgage loans
to whites, and only EIGHT to African Americans.
Meanwhile it denied 3 applications from African
Americans, and only 97 from whites (compared to
403 originations). This is disparate, and
more disparate both than the aggregate in West
Virginia.
See also, as to proposed acquirer Burke &
Herbert, this "civil action seeking monetary
damages, restitution and declaratory relief from
Defendant Burke & Herbert Bank & Trust
Company (“Burke & Herbert”), arising from
the unfair and unconscionable assessment and
collection of “overdraft fees” (“OD Fees”) on
accounts that were never actually overdrawn. 2.
This practice breaches contract promises made in
Burke & Herbert’s adhesion contracts. 3. In
plain, clear, and simple language, the checking
account contract documents discussing OD Fees
promise that Burke & Herbert will only
charge OD Fees or Non-Sufficient Funds Fees
(“NSF Fees”) on transactions where there are
insufficient funds to cover them. 4. As happened
to Plaintiff, however, Burke & Herbert
charges OD Fees even when there are sufficient
funds to cover a debit card transaction,"
citation, etc.
Earlier
in October, after a similar challenge by Fair
Finance Watch on data and complaints not even as
bad, the FDIC required from LINKBANK a plan to
improve its lending to African Americans, which
Inner City Press has published on its
DocumentCloud
here.
October
23, 2023
Linkbankcorp
Bid To Buy
Partners
Bancorp
Conditioned by
FDIC Now
Linkbank Spins
By
Matthew Russell Lee, Patreon Maxwell
Book
SOUTH
BRONX, Oct 21 – Pennsylvania, Delaware and
Virginia are portrayed as diverse and ever
progressive places. But their banks, not so
much.
Consider
for example the proposed merger on the rebound
between New York-based Link Bank and Partners
Bancorp, which recently broke off its proposed
deal with OceanFirst.
Inner
City Press and Fair Finance Watch have long
exposed redlining - and in this vein, on May 6
they filed a Community Reinvestment Act
challenge with the FDIC and Federal Reserve.
Now in October, the FDIC has required from
LINKBANK a plan to improve its lending to
African Americans, which Inner City Press has
published on its DocumentCloud
here.
The ABA's Rob
Nichols,
formerly of
the Treasury
Department,
has attacked
the reporting
of
demographics
in small
business
lending,
saying it will
be painting
“an incomplete
and
potentially
misleading
picture of
small business
lending to
underserved
groups." Then
there are the
lawsuit trying
to stop any
reporting.
Because,
apparently, no
picture is
better than a
supposedly
incomplete
one. Mean
while the ABA
is an
investor: the
"American
Bankers
Association, a
trade group
for U.S.
banks, said on
Friday that
[it] had
joined a $30
million
investment
round in
Finxact, a
startup." How
does that
work?
October
16, 2023
Who can get
into banking
in the USA?
Well, bunq is
trying,
despite being
fined in
Benelux for
using AI as
their anti
money
laundering
screen. And
how would that
work for fair
lending? Watch
this site.
October
9, 2023
Link Bank Bid To Buy Partners Bancorp Was Hit by Fair Finance Watch Now Plan Required
By
Matthew Russell Lee, Patreon Maxwell
Book
SOUTH
BRONX, Oct 7 – Pennsylvania, Delaware and
Virginia are portrayed as diverse and ever
progressive places. But their banks, not so
much.
Consider
for example the proposed merger on the rebound
between New York-based Link Bank and Partners
Bancorp, which recently broke off its proposed
deal with OceanFirst.
Inner
City Press and Fair Finance Watch have long
exposed redlining - and in this vein, on May 6
they filed a Community Reinvestment Act
challenge with the FDIC and Federal Reserve.
October
2, 2023
Deutsche Bank Fined for Greenwashing Scam, Next Should Be Fine for False CRA Claims
By
Matthew Russell Lee, Patreon Maxwell
book
SDNY
COURTHOUSE, Sept 25 – Deutsche
Bank was sued
for their enabling of Jeffrey
Epstein, in lawsuits filed on
Thanksgiving 2022 in the U.S.
District Court for the
Southern District of New York,
where Inner City Press found
them in the docket.
September
25, 2023
CRA Challenge to Atlantic Union - American National Proposed Merger on Loan Disparities
by
Matthew Russell Lee, Patreon Book
Substack
SOUTH
BRONX NY, Sept 23 – Two of 2023's largest
US proposed bank mergers were announced this
summer: Atlantic Union applying to buy Atlantic
National in Virginia, and Banc of California to
buy PacWest. Fair Finance
Watch had been monitoring the banks, and on
September 25 commented to the Federal Reserve on
and against Atlantic Union - American
National:
Dear
Chair Powell, Secretary Misback and others in
the FRS: This is a timely first comment
on, the Applications of Atlantic Union
Bankshares Corporation to acquire American
National Bankshares.
Atlantic Union, in Virginia in 2022, made 2819
mortgage loans to whites, and only 197 to
African Americans. Meanwhile it denied 159
applications from African Americans, and only
944 from whites.
This is disparate, and more disparate both than
the aggregate in Virginia, and than American
National Bank and Trust.
That
is to say, beyond the 2.4 denial rate disparate,
American Union made fully 14 mortgage loans to
whites for every loan to an African
American. Statewide in Virginia for the
aggregate, the ratio was five to one.
This
is outrageous; American Union should be referred
by the FRB to the Department of Justice.
In
Maryland in 2022, American Union denied the
applications of African Americans 4.31 times
more frequently than those of whites.
In
North Carolina in 2022, American Union made 17
loans to whites for every loan to an African
American. Again, this is outrageous; American
Union should be referred by the FRB to the
Department of Justice.
We
also note the issues in the overdraft class
action that Atlantic Union settled, but on
information and belief did not fully address, in
2021. See, MARTY HINTON, individually and on
behalf of all others similarly situated,
Plaintiff, v. ATLANTIC UNION BANK, Defendant.
Civil Action No. 3:20-cv-651-JAG (Complaint)
and (Order
denying Atlantic Union's motion to
dismiss) Inner City Press is requesting an
extension of the public comment period, public /
virtual evidentiary hearings and that, on the
current record, the applications not be
approved
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 we
timely request public hearings.
September
18, 2023
Citigroup has
been rightly
targeted with
protest for
years (see for
example
Predatory
Bender) - but
last week the
ongoing
lending
protest turned
environmental,
and a
Citigroup
staffer showed
the bank's
attitude,
pushing and
yelling and it
seems
splashing
coffee, video
here.
More next
week, after
UNGA...
September
11, 2023
Schwab Moved Bank and CRA Duty to Desert SW After TD Ameritrade Buy, Now Challenge
by
Matthew Russell Lee, Patreon Book
Substack
SOUTH
BRONX, Sept 8 – There are largely non-bank
company which buy or charter a bank to serve
them, but barely if at all comply with the
Community Reinvestment Act.
On
September 8, 2023, Fair Finance Watch called out
Charles Schwab's two banks, to the Federal
Reserve:
On
behalf of Fair Finance Watch, this is a timely
comment on the CRA performance and plans of
Charles Schwab, including as impacted by the TD
Ameritrade acquisition.
That acquisition raised a number of issues
adverse for consumers, but there was not FRB
comment period. However, this
is a timely comment on the CRA PE of the two
Charles Schwab banks, Charles Schwab Bank, SSB
and Charles Schwab Premier Bank, SSB, which have
in connection with the acquisition moved their
headquarters to Texas, with an amorphous
additional service area of "the desert
Southwest."
Significantly,
looking at the top 100 banks regulated by the
Federal Reserve, Charles Schwab has the lowest
ratio of CRA lending and investments as a % of
total assets. It cannot pass
its CRA exam, and its CRA plan cannot continue
to be accepted or approved, on this
basis.
September
4, 2023
Link Bank Bid To Buy Partners Bancorp On the Ocean Rebound has More Fed CRA Questions
By
Matthew Russell Lee, Patreon Maxwell
Book
SOUTH
BRONX, Sept 1 – Pennsylvania, Delaware and
Virginia are portrayed as diverse and ever
progressive places. But their banks, not so
much.
Consider
for example the proposed merger on the rebound
between New York-based Link Bank and Partners
Bancorp, which recently broke off its proposed
deal with OceanFirst.
Inner
City Press and Fair Finance Watch have long
exposed redlining - and in this vein, on May 6
they filed a Community Reinvestment Act
challenge with the Federal Reserve.
August
28, 2023
Lakeland Bank DOJ Deal Left Disparities in NY So Protest now Fed Asks of DOJ Settlement
by
Matthew Russell Lee, Patreon Book
Substack
SOUTH
BRONX, NY, Aug 26– 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
August 22, the Fed asked the banks: "Department
of Justice Consent Order (“Consent Order”) 1.
Provide an update to all action items included
in the Consent Order, reflecting those items
which have been completed and any other
pertinent updates." As of August 26, no response
received from these banks...
Watch this site.
***
August
21, 2023
Credit Union Associations Demand Stay of CFPB 1071 Rule As They Also Move to Merge
By
Matthew Russell Lee, Patreon Maxwell
Book
SOUTH
BRONX, August 14 – The Texas Bankers
Association and ABA managed to finagle a Federal
court ruling allowing its and the ABA's members'
non-compliance with the Consumer Financial
Protection Bureau's small business data
collection rules, pending Supreme Court decision
on CFPB's structure and funding. Order here.
On
August 3, the ABA wrote to demand the CFPB
extend the stay to its non-members, here.
On
August 11 the two credit union associations
wrote it to get a stay - while they themselves
try to merger. The letter
was signed by NAFCU Vice President of Regulatory
Affairs Ann Petros and CUNA Deputy Chief
Advocacy Officer and Managing Counsel Alexander
Monterrubio.
August
14, 2023
Banks Downgraded as Regulators Encourage Mergers But Link Bid To Buy Partners is Litmus