Inner City Press: Federal Reserve Beat (FOIA, FOMC, CRA, Predatory Finance)

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December 15, 2025

Fed Rubber Stamps PNC Reciting Fair Finance Watch Comments But No Rebuttal So AI Next

by Matthew Russell Lee, Patreon Book Substack

FEDERAL COURTHOUSE, Dec 11 – As PNC Bank has grown it has become more disparate in its lending. After its CEO Bill Demchak announced a $4.1 billion proposal to buy FirstBank and bragged, "We just effectively bought Colorado," Fair Finance Watch prepared an early filing to the regulators demanding scrutiny and hearings. While preparing for PNC's sure to be coming next bank-grab as PNC expands in AI and crypto, FFW commented twice, as noted by the Fed:

"The Board received two timely adverse comments on the proposal, both from the same commenter.32 The commenter objected to the proposal, alleging that, based on data reported under the Home Mortgage Disclosure Act of 1975 (“HMDA”), 33 PNC Bank made fewer home loans to African American individuals as compared to white individuals nationwide, including in Pennsylvania, Michigan, Texas, Florida, Indiana, Maryland, New York, Alabama, Colorado, the District of Columbia, Illinois, Georgia, Arizona, Virginia, California, Missouri, New Jersey, North Carolina, Ohio, Tennessee, Delaware, Massachusetts, Kentucky, South Carolina, and Wisconsin in 2024. The commenter also alleged that PNC Bank denied home loan applications of African American individuals at a higher rate than those of white individuals. 34 The commenter requested that the Board consider and hold hearings regarding a consumer complaint submitted by an unknown customer of PNC Bank to the Consumer Financial Protection Bureau (“CFPB”) regarding an allegation that the consumer’s account was frozen by the bank without explanation, which was published on the CFPB’s consumer complaint database (“CFPB database”). The commenter also more generally requested that the Board review consumer complaints in the CFPB’s database regarding PNC Bank."

But there is no rebuttal. Game on - as PNC promotes crypto trading, orders staff back to the office only to fire then for AI - and to outsource decisions to AI. It will all be opposed.

On October 15 the OCC provided some responsive documents - but withheld in full 435 pages, while providing suborned letters from supportive commenters who have PNC on their Board of Directors (can you say, conflict of interest) or who name support. OCC responsive documents in Inner City Press' CloudDocument here.

In state after state, PNC for African Americans has (many) more denials than originations, while the opposite is true for white borrows. The pattern is striking:

In New York, where PNC recently and unceremoniously closed a deposit facility, PNC in 2024 denied 52 applications from African Americans while making fewer, only 28 loans - while it made fully 289 loans to whites and denied only 252 applications. This follows the same PNC pattern and is disparate.

In Colorado, which PNC CEO's says the bank has now "effectively bought," PNC in 2024 denied 12 applications from African Americans while making only 17 loans - while it made fully 422 loans to whites and denied only 244 applications. This is disparate.

In Arizona, where PNC lists 60 branches and now proposes to further expand, PNC in 2024 denied 15 applications from African Americans while making only 22 loans - while it made fully 796 loans to whites and denied only 466 applications. This is disparate. There are more states.

Watch this site.

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December 8, 2025

Federal Reserve Board Nixed Public Comments on Merger Now Cleveland Reserve Bank Spins

by Matthew Russell Lee, Patreon Book Substack

SDNY/SOUTH BRONX, Dec 5 – As US bank regulators loosen rules - including the FDIC moving to eliminate public comment altogether on branch expansion applications - more big banks are moving to get bigger.

And now Federal Reserve is rejecting public comments opposing mergers, here Fifth Third's already sued Comerica proposal, citing the "reputation" of the submitter. Inner City Press / Fair Finance Watch wrote to the Board Secretary:

Yesterday Fair Finance Watch emailed a timely comment opposing Fifth Third / Comerica as we have always done - and got back this (which I'm glad we saw) "This is the mail system at host www2.webmail.pair.com. I'm sorry to have to inform you that your message could not be delivered to one or more recipients. It's attached below.

"federalreserve.gov: Your access to this mail system has been rejected due to the sending MTA's poor reputation."

We ask that an explanation be provided - and that the Federal Reserve System check on this pending application and other applications, including going forward, that it has not rejected comments from the public. Awaiting Fed response, Matthew Lee, Esq., Executive Director, Fair Finance Watch / Inner City Press

The response, days later, came not from the Board but a Reserve Bank, that in Cleveland: "comments can also be sent electronically to Comments.applications@clev.frb.org.”1 In order to ensure proper receipt of electronic comments on an application, please use the email address provided in the Federal Register notice.2 As you noted in your correspondence, based on consideration of the initial server from which it was sent, your first email on November 28, 2025, was flagged for spam and other suspicious activity, and automatically rejected by the Board’s system prior to receipt. However, the subsequent message that you sent to the Board’s email address on November 29, 2025, was received, and that message included the comment emailed on November 28, 2025."

But what about Reserve Bank like in Kansas City that list no email address? What of the non-public nature of the Reserve Bank? Still no response from the Board or Governors (who recently denied Fair Finance Watch's petition for rulemaking to preserve public access to HMDA data. We've refiled via the FDIC, OCC and even NCUA with the FFIEC, what- and who ever that it...

December 1, 2025

Fed Rubber Stamps Pinnacle Synovus Merger Protested on Community Reinvestment Act

by Matthew Russell Lee, Patreon Book Substack

NASHVILLE, Nov 25 – Synovus Bank, with a track record of disparate lending and consumer complaints, aims to cash out and merge with Nashville-based Pinnacle.

But Pinnacle has its own disparities, and is under-regulated by the Tennessee Commissioner of Financial Institutions, who refuses to provide any documents to anyone but Tennessee "citizens" (not even those *in* Tennessee).

So Fair Finance Watch filed Community Reinvestment Act challenges with the Federal Reserve and the Georgia regulator (both have confirmed receipt and the Fed has sent to Pinnacle) as well as the recalcitrant Tennessee regulator, who refuses to give records or even confirm receipt of the challenge. Pinnacle has Tennessee in the palm of its hand, lock stock and barrel, regulator and media.

And now it has the Federal Reserve too, which on November 25 issued a rubber stamp approval, including that FFW "objected to the proposal, alleging that both Synovus Bank and Pinnacle Bank generally made proportionally fewer home loans to African American individuals as compared to white individuals in 2024

The Fed Order concedes as to FFW that "The data cited by this commenter corresponds to publicly available 2024 data reported by both Synovus Bank and Pinnacle Bank under the Home Mortgage Disclosure Act of 1975 (“HMDA”), 12 U.S.C. § 2801 et seq." - but the Fed doesn't care about disparities. It continues: "This commenter also alleged that Pinnacle Bank denied home loan applications of African American individuals at a higher rate than those of white individuals." But the Fed still approved.

Back on October 9 the Fed asked Pinnacle nine multi-part questions, including "A copy of the CRA policy to be used by the combined organization or, if one is not available, a projected timeline for completion. 4. Discuss the combined organization’s plans to manage third party partnership compliance risk exposure, including, but not limited to, BHG Financial and GreenSky, LLC. a. Include in your discussion anticipated key leadership positions and any individuals identified to fill them; plans for reporting/Management" - full letter here.

From the comment: Dear Chair Powell and others in the FRS:

... Fair Finance Watch has reviewed the just-released 2024 Home Mortgage Disclosure Act data of Synovus and finds that while it made 3.18 loans to whites for each denial to whites, it made only 1.7 loans to African Americans for each denial to African Americans.

Pinnacle is of even greater concern. In Virginia, where Pinnacle received a Low Satisfactory on the Lending Test in its most recently (May 2023) CRA performance evaluation, in 2024 it made 133 mortgage loans to whites, with 19 denials, but only 13 loans to African Americans, with fully eight denials...

This application should not be approved; particularly in light of the disparities, public evidentiary hearings are needed.

Watch this site.

***

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November 24, 2025

On Fifth Third Bid for Comerica CRA Protest Now Fed Asks of Branches and Direct Express

by Matthew Russell Lee, Patreon Book Substack

SDNY/SOUTH BRONX, Nov 18 – As US bank regulators loosen rules - including the FDIC moving to eliminate public comment altogether on branch expansion applications - now more big banks are moving to get bigger.

On October 6, Fifth Third announced it will apply to buy damaged Comerica Bank. On October 8-9, it was opposed, to the Fed and OCC. On November 10, after a contemptuous response by Fifth Third's Kala Gibson, Fair Finance Watch spread the fight spread to five more states.

On November 18 the Federal Reserve put 15 multi-part questions to Fifth Third, ranging from branch closures and the Community Reinvestment Act to potential shareholder litigation and, at last, the Direct Express program. Inner City Press is putting the Fed's question letter on its DocumentCloud here, as it will Fifth Third responses - after FOIA if necesary, though 53 is supposed to sent them to Fair Finance Watch.

Their application to the Fed discloses five states they are filing with: Michigan, Texas, California, Florida and Arizona. On November 10 Inner City Press filed with all five.

Fair Finance Watch filed:

Fair Finance Watch has long been concerned about Fifth Third. Fair Finance Watch has reviewed the just-released 2024 Home Mortgage Disclosure Act data of Fifth Third, not reviewed in any Community Reinvestment Act performance evaluation.

In state after state, Fifth Third for African Americans has (many) more denials than originations, while the opposite is true for white borrows. The pattern is striking, starting with two states Fifth Third and Comerica overlap in:

In Michigan, the state Comerica abandoned for Texas, Fifth Third in 2024 denied 249 applications from African Americans while making fewer, only 177loans - while it made fully 4189 loans to whites and denied only 1688 applications. This is disparate [there are more states]

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November 17, 2025

On Fifth Third Bid for Comerica Media Reruns Spin on Huntington Amid CRA Protests 5 States

by Matthew Russell Lee, Patreon Book Substack

SDNY/SOUTH BRONX, Nov 12 – As US bank regulators loosen rules - including the FDIC moving to eliminate public comment altogether on branch expansion applications - now more big banks are moving to get bigger.

On October 6, Fifth Third announced it will apply to buy damaged Comerica Bank. On October 8-9, it was opposed, to the Fed and OCC. Now on November 10, after a contemptuous response by Fifth Third's Kala Gibson, the fight has spread to five more states.

Meanwhile, how does today's business media work, or not work? On November 12 a pro-business consultancy based in Minneapolis put out a gushing press release entitled "Fifth Third’s Comerica Acquisition Unseats Top 10 Bank Competitors in Small Business and Middle Market," saying that Huntington had First Citizens (both proposing acquisitions) have been pushed out of the top 10. FOX 4 in Kansas City re-ran the press release, without change, presumably as "news," here And so it goes - that's where Inner City Press comes on, on this beat.

Fifth Third's EVP of "Corporate Responsibility" Kala Gibson wrote in urging a rubber stamp from the Federal Reserve Bank of Cleveland, saying that HMDA data proves nothing. He is speaking for CEO Tim Spence, who bragged on the day of announcement how fast he could obtain an approval. Well let's see.

Their application to the Fed discloses five states they are filing with: Michigan, Texas, California, Florida and Arizona. On November 10 Inner City Press filed with all five.

Fair Finance Watch filed:

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November 10, 2025

As Fifth Third Bids to Buy Comerica Disparities Raised by Fair Finance Watch and Tricolor Loss

by Matthew Russell Lee, Patreon Book Substack

SDNY/SOUTH BRONX, Nov 7 – As US bank regulators loosen rules - including the FDIC moving to eliminate public comment altogether on branch expansion applications - now more big banks are moving to get bigger.

On October 6, amid the pending PNC - FirstBank and Pinnacle - Synovus proposals, Fifth Third announced it will apply to buy damaged Comerica Bank. Starting October 8, Fair Finance Watch filed opposition, and Inner City Press FOIA requests, including for the Fed's sealed questions.

One of the damages to Comerica is that the Treasury Department took from Comerica its Direct Express contract - and awarded it to Fifth Third.

Now Fifth Third has applied to the Treasury Department's Office of the Comptroller of the Currency to buy Comerica. Talk about picking winners and losers.

And talking about losers, Fifth Third's nationwide lending in 2024, the most recent year for which data is available, was disparate: 26,121 mortgage loans to whites and only 11,566 denial to whites, versus only 1784 loans to African Americans and even more denials: 1970. These disparities continue in Fifth Third's other states, as Fair Finance Watch has demonstrated. On November 7 it filed this:

In the month since Fair Finance Watch commented to the agencies, the Federal Reserve has put some question to Fifth Third's outside counsel Rodgin Cohen - but has characterized them as entirely confidential. Inner City Press has submitted a FOIA request, and a second one for the over-withheld exhibits. For now, for the record: "Fifth Third Bank faces $200M in provisions from Tricolor ‘fraud’ - "potential loss of millions following subprime lender Tricolor Holdings’ bankruptcy filing. Fifth Third faces 'nearly $200 million of provision expense associated with the fraud at Tricolor.'" Public hearings are needed

Inner City Press, which has opposed the FDIC's moves to close itself to public scrutiny - American Banker op-ed here - has submitted FOIA requests on all this. The FDIC said it will eliminate public notices because it does not receive enough public comments. That is changing, starting now. Watch this site.

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November 3, 2025

Fed Asked PNC Why Response to FFW Was Late But Accepted It on Bid for FirstBank

by Matthew Russell Lee, Patreon Book Substack

FEDERAL COURTHOUSE, Oct 28 – As PNC Bank has grown it has become more disparate in its lending. After its CEO Bill Demchak announced a $4.1 billion proposal to buy FirstBank and bragged, "We just effectively bought Colorado," Fair Finance Watch prepared an early filing to the regulators demanding scrutiny and hearings.

This takes place as the regulators, led by the FDIC, are seeking to eliminate public notice and limit public comment. See, e.g., American Banker, Sept 10, 2025, "The FDIC is taking the 'community' out of CRA enforcement," by Matthew R. Lee, here

On September 13 Fair Finance Watch filed challenges with the Federal Reserve and OCC, and Inner City Press filed Freedom of Information Act requests, see below.

Compare OCC denial of expedited processing here to FRB grant of identical request here

Inner City Press appealed.

On October 20 the Federal Reserve belatedly asked PNC questions, now on Patreon here

On October 28, the Fed provided Fair Finance Watch with its email to PNC asking why did it did not respond to FFW's September 18 comment within the time granted. Instead, PNC late submitted a breezy letter saying it "welcomed hearing from the two commenters who expressed concerns regarding the Proposed Transaction: Matthew Lee, Esq. of Fair Finance Watch" then citing 15 suborned letters.

by Matthew Russell Lee, Patreon Book Substack

SDNY/SOUTH BRONX, Oct 31 – As US bank regulators loosen rules - including the FDIC moving to eliminate public comment altogether on branch expansion applications - now more big banks are moving to get bigger.

On October 6, amid the pending PNC - FirstBank and Pinnacle - Synovus proposals, Fifth Third announced it will apply to buy damaged Comerica Bank. On October 8-9, it was opposed, to the Fed and OCC.

Inner City Press submitted a Freedom of Information Act request to the Fed, the same it has used on other mergers, always resulting in expedited treatment.

But on October 16, the Fed for the first time denied expedited treatment on Fifth Third - Comerica and Direct Express. Inner City Press appealed, asking that the Governors answer: what changed?

The Federal Reserve explained it was because the application has not been filed yet. Fine. On October 30, the Fed send "Mathew Lee, Attached is a letter from the Federal Reserve Bank of Cleveland (the “Reserve Bank”) acknowledging receipt of the public comment you submitted (the “receipt letter”) regarding Fifth Third Bancorp’s, Cincinnati, Ohio, intended acquisition of Comerica Incorporated, Dallas, Texas. Also attached is a letter from this Reserve Bank to Fifth Third's retained counsel transmitting your comment and giving the company an opportunity to respond."

But at 4 pm on October 31, notice of the application was still not on the Fed's website. Inner City Press raised just this to Governor Michelle Bowman at the FRBKC's hearing on EGRPRA on October 30. Watch this site.

Fair Finance Watch filed:

Dear FRB Chair Powell, Comptroller Gould:

This is an early first comment on, the proposal and applications by Fifth Third to acquire Comerica. Beyond the lending disparities preliminarily identified below, the US government's Direct Express payment program was removed from Comerica, part of its weakening, and given to Fifth Third, which now applies to acquire Comerica. Public hearings are needed, and hereby required.

October 27, 2025

Fed Asks Questions after PNC Bid for FirstBank Challenged on CRA by Fair Finance Watch

by Matthew Russell Lee, Patreon Book Substack

FEDERAL COURTHOUSE, Oct 20 – As PNC Bank has grown it has become more disparate in its lending. After its CEO Bill Demchak announced a $4.1 billion proposal to buy FirstBank and bragged, "We just effectively bought Colorado," Fair Finance Watch prepared an early filing to the regulators demanding scrutiny and hearings.

On September 13 Fair Finance Watch filed challenges with the Federal Reserve and OCC, and Inner City Press filed Freedom of Information Act requests, see below.

Compare OCC denial of expedited processing here to FRB grant of identical request here

Inner City Press appealed.

On October 20 the Federal Reserve belatedly asked PNC questions, now on Patreon here

October 20, 2025

Rare Fed denial: "The Federal Reserve Board on Friday denied an application by Canandaigua National Corporation, of Canandaigua, New York. The firm provided a complementary activity notice to the Board proposing to engage in certain activity that would obligate it to acquire real property. Bank holding companies are generally prohibited from investing in real property under the Bank Holding Company Act. After reviewing the proposal and considering all the facts and circumstances, the Board has determined that the proposed activity is inconsistent with the factors the Board is required to evaluate by law. The Board's order will be released following a review for confidential information related to the firm" - this while the Fed for the first time denies the Press expedited treatment of FOIA about an announced merger (Fifth Third / Comerica) - Inner City Press immediately appealed and asked that it be presented to all Governors, watch this site. Also, asked the Fed to take back over HMDA data. No response.

October 13, 2025

As Pinnacle Bank Synovus Merger Protested Now Fed Asks About CRA and GreenSky

by Matthew Russell Lee, Patreon Book Substack

NASHVILLE, Oct 9 – Synovus Bank, with a track record of disparate lending and consumer complaints, now proposes to cash out and merge with Nashville-based Pinnacle.

So Fair Finance Watch filed Community Reinvestment Act challenges with the Federal Reserve and the Georgia regulator (both have confirmed receipt and the Fed has sent to Pinnacle) as well as the recalcitrant Tennessee regulator, who refuses to give records or even confirm receipt of the challenge. Pinnacle for now seems to think it has Tennessee in the palm of its hand, lock stock and barrel, regulator and media. But then there's Inner City Press, and other states...

On October 9 the Fed asked Pinnacle nine multi-part questions, including "A copy of the CRA policy to be used by the combined organization or, if one is not available, a projected timeline for completion. 4. Discuss the combined organization’s plans to manage third party partnership compliance risk exposure, including, but not limited to, BHG Financial and GreenSky, LLC. a. Include in your discussion anticipated key leadership positions and any individuals identified to fill them; plans for reporting/Management" - full letter here.

The Federal Reserve, while correctly granting expedited processing to Inner City Press' FOIA request about Pinnacle and Synovus, on October 1 wrote to say they need yet more time: "Pursuant to section (a)(6)(B)(i) of the FOIA, we are extending the period for our response until October 16, 2025, in order to consult with two or more components of the Board having a substantial interest in the determination of the request." Will processing of the application be stayed?

Dear Chair Powell and others in the FRS:

This application should not be approved; particularly in light of the disparities, public evidentiary hearings are needed.

Watch this site.

***

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October 6, 2025

As Pinnacle Bank Synovus Merger Protested Now Fed Extends Time on Expedited FOIA

by Matthew Russell Lee, Patreon Book Substack

NASHVILLE, Oct 1 – Synovus Bank, with a track record of disparate lending and consumer complaints, now proposes to cash out and merge with Nashville-based Pinnacle.

So Fair Finance Watch filed Community Reinvestment Act challenges with the Federal Reserve and the Georgia regulator (both have confirmed receipt and the Fed has sent to Pinnacle) as well as the recalcitrant Tennessee regulator, who refuses to give records or even confirm receipt of the challenge. Pinnacle for now seems to think it has Tennessee in the palm of its hand, lock stock and barrel, regulator and media. But then there's Inner City Press, and other states...

On September 15 the FRB of Atlanta sent Fair Finance Watch a list of question sent to Pinnacle and Synovus including "an analysis of CRA and fair lending impacts and the potential effect on the community and customers served by the branch, particularly distressed or underserved nonmetropolitan middle- income census tracts, majority-minority census tracts, LMI census tracts, and rural areas;" and "The Application identifies that The Vanguard Group, Inc., BlackRock, Inc., and FMR, LLC, would each hold more than 5 percent of the combined organization’s common stock. Explain in further detail why, as the Application represents, “[n]one of these parties would trigger any presumption of control” - full letter on Inner City Press' DocumentCloud here

Dear Chair Powell and others in the FRS:

... Fair Finance Watch has long been concerned about Synovus, as the Federal Reserve memorialized, noting "disparities in denial rates and home mortgage originations to African Americans and/or Hispanics, as compared to whites, in certain markets. The commenter also noted a complaint filed with the CFPB against Synovus Bank relating to collecting on a debt allegedly not owed."

In Alabama, where Pinnacle also received a Low Satisfactory on the Lending Test, in 2024 Pinnacle made 106 mortgage loans to whites, with 16 denials, but only 56 loans to African Americans, with fully nine denials.

In North Carolina, where Pinnacle also received a Low Satisfactory on the Lending Test, in 2024 Pinnacle made 653 mortgage loans to whites, with 178 denials, but only 202 loans to African Americans, with fully 82 denials.

Even in Tennessee, which conceals its records, Pinnacle was rated Low Satisfactory on the Lending Test in Knoxville and Chattanooga. Not in the exam:

In Florida in 2024 Pinnacle made 38 mortgage loans to whites, with 11 denials, but only five loans to African Americans, with fully NINE denials.

In Kentucky in 2024 Pinnacle made eleven mortgage loans to whites, with seven denials, but NO loans to African Americans. This application should not be approved; particularly in light of the disparities, public evidentiary hearings are needed.

Watch this site.

***

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September 29, 2025

First Security Bank Protest Moves to DC as FDIC Moves To Cut Notice of Branches

by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX / SDNY COURT, Sept 24 – The Community Reinvestment Act directs bank regulators to consider banks' records of lending in poor neighborhoods when they apply to expand with mergers or, right in the statute, branches ("deposit facilities").

But now the Federal Deposit Insurance Corporation is quietly moving to eliminate public notice of, and public comment on, banks' branch applications. While Inner City Press has Freedom of Information Act requests pending, Fair Finance Watch on August 30 commented to the FDIC, on the proposed change - and on sample current branch applications pending.

On August 21, in part to forestall the Federal Reserve using the same twisted logic of "few comments so let's eliminate public notice," Fair Finance Watch filed a branch comment with the Federal Reserve Bank of St. Louis on the pending application by Arkansas-based First Security Bank to open a branch at 4001 Rodney Parham Road in Little Rock, noting that First Security Bank in Arkansas in 2024 it made 1030 mortgage loans to whites and denied only 120 applications, 1 to 9. For African Americans, only 17 loans and fully 10 denials: approximately 1 to 1.7.

On September 11 First Security Bank vaguely responded, pointing to a 2023 CRA Performance Evaluation 1) that did not consider the 2024 HMDA data. 2) that PE states, inter alia, Distribution on loans in non-MSA Arkansas is "Poor" (id. at 10); on the Investment Test in Jonesboro, Hot Springs and Fort Smith is "Below" (id. at 13); in the same Jonesboro and Hot Springs communities, accessibility of delivery systems are "Below." Community Development Services in Jonesboro, also "Below." Fair Finance Watch reiterated its request for hearings, and denial.

On September 24 the Fed informed First Security Bank that the application is being transferred to the Board in DC and the time extended - but only into October. Watch this site.

See also, Inner City Press' op-ed in the American Banker here

There will be more.

This proposal to eliminate public notice and comment on branch applications must be withdrawn - or sued.

Watch this site.

***

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September 22, 2025

As Pinnacle Bank Synovus Merger Protested Now Fed Asks Fair Lending and Blackrock Qs

by Matthew Russell Lee, Patreon Book Substack

NASHVILLE, Sept 18 – Synovus Bank, with a track record of disparate lending and consumer complaints, now proposes to cash out and merge with Nashville-based Pinnacle.

So Fair Finance Watch filed Community Reinvestment Act challenges with the Federal Reserve and the Georgia regulator (both have confirmed receipt and the Fed has sent to Pinnacle) as well as the recalcitrant Tennessee regulator, who refuses to give records or even confirm receipt of the challenge. Pinnacle for now seems to think it has Tennessee in the palm of its hand, lock stock and barrel, regulator and media. But then there's Inner City Press, and other states...

Dear Chair Powell and others in the FRS:

Even in Tennessee, which conceals its records, Pinnacle was rated Low Satisfactory on the Lending Test in Knoxville and Chattanooga. Not in the exam:

In Florida in 2024 Pinnacle made 38 mortgage loans to whites, with 11 denials, but only five loans to African Americans, with fully NINE denials.

Watch this site.

***

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September 15, 2025

First Security Bank Protested As FDIC Moves To Cut Notice of Branches Citing Few Protests

by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX / SDNY COURT, Sept 12 – The Community Reinvestment Act directs bank regulators to consider banks' records of lending in poor neighborhoods when they apply to expand with mergers or, right in the statute, branches ("deposit facilities").

There will be more.

This proposal to eliminate public notice and comment on branch applications must be withdrawn - or sued.

Watch this site.

***

Your support means a lot. As little as $5 a month helps keep us going and grants you access to exclusive bonus material on our Patreon page. Click here to become a patron.

September 8, 2025

Filed with the Fed:

Federal Reserve Board and Federal Reserve Bank of St. Louis Re: Timely Comment on Branch Application for First Security Bank Dear Chair Powell, Secretary and FRBSL: On behalf of Fair Finance Watch and in my personal capacity this is a timely comment opposing the pending branch application by First Security Bank to establish a deposit facility at 4001 Rodney Parham Road, Little Rock, Arkansas. The application is listed in the FRB's H2A with a comment period running through September 1 - Labor Day. This August 31 comment is timely. FFW notes in the FDIC's pending proposal RIN 3064-AG10: "the FDIC has received a limited number of public comments in response to subpart C applications.... Therefore, the FDIC is proposing to eliminate the public notice and related public comment period from subpart C and to make conforming changes to subpart A of 12 CFR part 303 of the FDIC Rules." The Community Reinvestment Act specifies that "the appropriate Federal financial supervisory agency shall (1) assess the institution's record of meeting the credit needs of its entire community, including low- and moderate-income neighborhoods, consistent with the safe and sound operation of such institution; and (2) take such record into account in its evaluation of an application for a deposit facility by such institution." That is, the only enforcement mechanism of CRA is its consideration on applications for deposit facilities: branches. But now the Federal regulator(s) blithely propose(s) to eliminate public notice and public comment on branch applications. This is blatantly against the CRA. This proposal to eliminate public notice and comment on branch applications must be withdrawn. Ironically, the FDIC's reasoning is that few comments are filed. So, that is now changing. FFW has reviewed the 2024 HMDA data - not in any CRA evaluation - of First Security Bank in Arkansas in 2024 it made 1030 mortgage loans to whites and denied only 120 applications, 1 to 9. For African Americans, only 17 loans and fully 10 denials: approximately 1 to 1.7. This is disparate and a hearing is requested, timely opposition made. Again, the only enforcement mechanism of CRA is its consideration on applications for deposit facilities: branches. A hearing is requested, timely opposition made

September 1, 2025

Inner City Press live tweeted the Lisa Cook v. Trump hearing on August 29 - and the notice of non-admittance to the DDC of the Fed's lawyer, after. Resolved. We'll have more on this

August 25, 2025

The "new" Fed is asking questions - then bank(s) snailmail. From a consulting group in Little Rock, a velobound spin on CRA (while it was FedEZfiled to the Fed. Then last week: "Application by BancFirst Corporation, Oklahoma City, Oklahoma (BANF), pursuant to Section 3(a)(3) and 3(a)(5) of the Bank Holding Company (BHC) Act of 1956, as amended, to acquire and merge with AmeriBank Holding Company (AmeriBank), parent of American Bank of Oklahoma (ABOK), both of Collinsville, Oklahoma Dear Mr. Shadid: Mr. Matthew Lee has submitted an adverse comment regarding your filing; in accordance with the Board’s ex parte procedures described in a letter to you dated July 8, 2025, Mr. Lee and the agencies copied on this request are entitled to receive the nonconfidential/public portion of your response....

Non-Confidential/Public - Additional Items Requested 1. Provide all the financial statements requested below beginning as of June 30, 2025, and denote what date any subsequent projections may be referring to; for example, June 30, 2026 or December 31, 2026, etc. 2. Provide interim ABOK bank-level current and pro forma applicable capital ratios for the period of time in which BANF plans to hold ABOK as a separate bank subsidiary. 3. To the extent possible, provide the following current and pro forma bank level capital and asset quality ratios for BancFirst in which the pro forma scenario reflects the proposed bank merger of ABOK into and with BancFirst: a. Common Equity Tier 1, Tier 1 Leverage, Tier 1 Risk-based Capital, and Total Risk-based Capital ratios; and b. Non-performing Asset (“NPA”) ratio in which the NPA ratio should be calculated by dividing the sum of nonaccrual loans and leases, restructured or modified loans and leases, and other real estate owned, by the sum of total equity capital plus the allowance for credit losses (“ACL”). 4. To the extent possible, provide financial projections, including capital ratios, for the next three years for BANF parent-only, BANF consolidated, and BancFirst bank-only level reflecting the proposed bank merger of ABOK into and with BancFirst. a. If applicable, include payments and/or other financial obligations (if any) that may be related to the consent orders involving ABOK referenced in the prior request for additional items sent on August 1, 2025.

We'll have more on this.

August 18, 2025

Nevermind... The Federal Reserve Board on Friday announced that it will sunset its novel activities supervision program and return to monitoring banks' novel activities through the normal supervisory process. Since the Board started its program to supervise certain crypto and fintech activities in banks, the Board has strengthened its understanding of those activities, related risks, and bank risk management practices. As a result, the Board is integrating that knowledge and the supervision of those activities back into the standard supervisory process and is rescinding its 2023 supervisory letter creating the program.

August 11, 2025

Synovus Lending Disparities and CFPB Fine Bode Badly For Pinnacle Which Says Too Early

by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX/SDNY, Aug 4 – Synovus Bank, with a track record of disparate lending and consumer complaints, now proposes to cash out and merge with Nashville-based Pinnacle.

Pinnacle has said it's too early to say much: "Joe Bass, a spokesman for Pinnacle, noted that, when the merger closes, the combined bank would have $116 billion in assets, compared to $55 billion for Pinnacle today. “It’s way too soon to answer specific questions about specific programs." So when will it not be too early?

Fair Finance Watch, as the Federal Reserve memorialized, has noted "disparities in denial rates and home mortgage originations to African Americans and/or Hispanics, as compared to whites, in certain markets. The commenter also noted a complaint filed with the CFPB against Synovus Bank relating to collecting on a debt allegedly not owed."

Since then, Synovus showed up in the criminal "We Build the Wall" prosecution in the U.S. District Court for the Southern District of New York, covered by Inner City Press, and in NSF investigations.

Fair Finance Watch has reviewed the just-released 2024 Home Mortgage Disclosure Act data of Synovus and finds that while it made 3.18 loans to whites for each denial to whites, it made only 1.7 loans to African Americans for each denial to African Americans. We will have more on these troubling disparities, including under the Community Reinvestment Act. Watch this site.

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August 4, 2025

Federal Reserve Governor Adriana Kugler announces she will step down from her position on the central bank’s board, effective Aug. 8, so new nomination coming

July 28, 2025

Synovus Lending Disparities and CFPB Fine Bode Badly For Pinnacle Proposal FFW Details

by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX/SDNY, July 25 – Synovus Bank, with a track record of disparate lending and consumer complaints, now proposes to cash out and merge with Nashville-based Pinnacle.

Since then, Synovus showed up in the criminal "We Build the Wall" prosecution in the U.S. District Court for the Southern District of New York, covered by Inner City Press, and in NSF investigations.

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July 21, 2025

Cadence Bank Faced Fair Lending DOJ Charge Inner City Press Told Fed Now Industry Moves

By Matthew Russell Lee, Patreon

FEDERAL COURT / BRONX, July 16 -- How out of control is the merger rubber stamping of the U.S. Federal Reserve and other regulators, even as they are ostensibly working to improve?

It was reported that Cadence Bank is looking to settle with DOJ on lending discrimination. But Inner City Press / Fair Finance Watch protested Cadence to the Federal Reserve in 2018 - and the Fed approved the merger.

Inner City Press / Fair Finance Watch wrote: "timely first comment on, the Applications of Cadence Bancorporation, Houston, Texas; to acquire State Bank Financial Corporation, Atlanta, Georgia, and thereby indirectly acquire State Bank and Trust Company, Macon, Georgia 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 Cadence Bank: In 2017 in the Dallas, Texas MSA for convention home purchase loans, Cadence made 99 such loans to whites - and NONE, not a single origination, to African Americans. In 2017 in the Houston Texas MSA for convention home purchase loans, Cadence made 236 such loans to whites - and only 15 to African Americans, and only 23 to Latinos. This is not in keeping with the aggregate, which made 37,128 such loans to whites, 3151 to African Americans and 8215 to Latinos.

In 2017 in the Birmingham, Alabama MSA for convention home purchase loans, Cadence made 66 such loans to whites - and only ONE to African Americans. Even combining in Table 4-1, it was 79 home purchase loans to whites and only THREE to African Americans. This should also be address in this proceeding, including at the requested evidentiary hearing: “Cadence Bank - Racist manager 2800 Post Oak Blvd Suite 101, Houston, TX 77056, USA Oct 14, 2017 NOT RESOLVED I had my 2 business accounts at the Williams tower location, I tried talking to the manager about small business loans she always avoided me looking at me kind of weird whenever I done withdrawals she always asked me why I'm taking money out after 3 months she sent me a Leter saying she's going to be closing my account because I take money out ones a week for payroll and she didn't like that”

This was covered not only in Inner City Press, here on FOIA abuses the Fed did nothing about, but also, for example, Barron's, here.

And the Fed rubber stamped the merger.

Jump cut to July 2025 when the Fed let Cadence acquire scandal-plagued Industry Bancshares a mere two months after Cadence announced the proposed acquisition. The Fed then lifted its order against Industry Bancshares for "unsafe or unsound banking practices." Beyond rubber stamping... Watch this site.

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July 14, 2025

"The Board is also proposing to make similar changes to its supervisory rating framework for insurers regulated by the Board" - what, for fair insurnce? Doubtful...

July 7, 2025

Amid all the criminality in the financial sector, this was the Federal Reserve's enforcement action last week:

WHEREAS, the Board of Governors of the Federal Reserve System (the “Board of Governors”), pursuant to section 8(e) of the Federal Deposit Insurance Act, as amended (the “FDI Act”), 12 U.S.C. § 1818(e), issues this Order of Prohibition (the “Order”) upon the consent of Respondent Kendall Hickman (“Hickman”), a former employee and institution-affiliated party, as defined in sections 3(u) and 8(b)(3) of the FDI Act, 12 U.S.C. §§ 1813(u) and 1818(b)(3), of Jonah Bank of Wyoming (the “Bank”), a state member bank; WHEREAS, Hickman was an employee of the Bank from July 1, 2021, until her termination on June 15, 2023; WHEREAS, prior to and during the same period, Hickman served as a bookkeeper for a nonprofit organization; WHEREAS, from March 6, 2018, to June 16, 2023, Hickman embezzled a total of $33,212.84 from the nonprofit organization;

Huge.

June 30, 2025

Gov Barr: "As far as collecting data, I would also point to our Community Perspectives Survey and the Small Business Credit Survey, which the Cleveland Fed has conducted since 2020.2 Beyond collecting and analyzing data, the Federal Reserve's CD function also conducts qualitative research to understand the "why" behind the data" - then why is the Fed so dismissive of HMDA data? Now the 2024 is out...

June 23, 2025

on Friday, the Board announced the termination of the enforcement actions listed below: UniCredit, S.p.A., Milan, Italy, UniCredit Bank AG, Munich, Germany, and UniCredit Bank Austria AG, Vienna, Austria Cease and Desist Order dated April 15, 2019 (PDF) Terminated June 5, 2025 China Construction Bank Corporation, Beijing, People's Republic of China and China Construction Bank New York Branch, New York, New York. Yeah.

June 16, 2025

Gov Bowman: "to promote accountability, regulators must be transparent—both in supervision and regulation. Successful policymaking requires openness and humility, caution and a deliberate approach. I can assure the Committee that if I am confirmed as the Vice Chair for Supervision, I will be strongly committed to these values." We'll see, on FOIA and esp on mergers....

June 9, 2025

CFPB Double Kneecaps HMDA Analysis as Summary Table Search Spins and Spins

by Matthew R. Lee

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

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

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

On March 31 the CFPB cut back on how HMDA data is provided; on April 2 Fair Finance Watch petitioned the Fed "to take emergency measures to ensure public access to simply analyzable data under the Home Mortgage Disclosure Act (HMDA), including the 2024 data. Until now - for 2023 and before - CFPB has provided a filtering page for HMDA data, searchable by geography and applicant characteristics.

On March 31 the CFPB rather than adding 2024 data to the filtering site linked above put up only modified LARS by institution and a large raw data date for which it provided a warning.

The effect of this is to make it significantly more difficult for community groups to analyze and compare lenders' HMDA data.

On June 6, even for the 2023, a summary table search even for a small institution just spun and spun. The FRB should put a simple collating / analyzing web interface with the 2024 up forthwith.

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

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

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

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June 2, 2025

Thou dost protest too much: "At the President's invitation, Chair Powell met with the President today at the White House to discuss economic developments including for growth, employment, and inflation. Chair Powell did not discuss his expectations for monetary policy, except to stress that the path of policy will depend entirely on incoming economic information and what that means for the outlook. Finally, Chair Powell said that he and his colleagues on the FOMC will set monetary policy, as required by law, to support maximum employment and stable prices and will make those decisions based solely on careful, objective, and non-political analysis."

May 26, 2025

And there is is, or was: Reconsideration of Board action -- request for reconsideration of the Board's approval of (1) the application by Capital One Financial Corporation (Capital One), McLean, Virginia, to acquire Discover Financial Services (Discover), Riverwoods, Illinois, and (2) Capital One's notice to acquire certain of Discover's nonbanking companies. Denied: May 12, 2025

May 19, 2025

Governor Barr spoke at the 2025 Northeast / Mid-Atlantic Small Business Credit Symposium - but no 1071 update...

May 12, 2025

Friday was Fed day: "Governor Michael Barr speaks at the Reykjavik Economic Conference at 5:55 a.m., followed by Fed Governor Adriana Kugler at 6:45 a.m. … Richmond Fed President Tom Barkin will speak at the Loudoun County Chamber of Commerce at 8:30 a.m. … Fed Governors Christopher Waller and Lisa Cook, New York Fed President John Williams, Cleveland Fed President Beth Hammack, former Fed Governor Kevin Warsh (and Larry Summers) speak at a monetary policy conference hosted by the Hoover Institution.

All this and they can't respond to FOIA requests on a timely basis...

May 5, 2025

Keeping its head down? For the week April 28 to May 2, not a single piece of new went up on the Fed's website...

April 28, 2025

On April 24, this: "The Federal Reserve Board on Thursday announced the withdrawal of guidance for banks related to their crypto-asset and dollar token activities and related changes to its expectations for these activities. These actions ensure the Board's expectations remain aligned with evolving risks and further support innovation in the banking system. The Board is rescinding its 2022 supervisory letter establishing an expectation that state member banks provide advance notification of planned or current crypto-asset activities. As a result, the Board will no longer expect banks to provide notification and will instead monitor banks' crypto-asset activities through the normal supervisory process." Now what?

April 21, 2025

In Florida Disparate United Community Banks Granted ANB By Fed Amid Lending Disparities

by Matthew R. Lee, Patreon Substack

FEDERAL COURT, April 16 – In Florida, United Community Bank is trying to move into the Miami area via merger, with a disparate lending record. Fair Finance Watch with Inner City Press on the FOIA has filed a timely first comment on, the Application by UCB to acquire American National Bank.

But consider United Community Bank's disparate lending record:

In South Carolina in 2023, United Community Banks made 673 mortgage loans to whites with 282 denials. Meanwhile to African Americans in the state it made only FIFTY ONE loans, while denying fully 45 applications.

In Florida in 2023, United Community Banks made 240 mortgage loans to whites with 86 denials. Meanwhile to African Americans in the state it made only TWELVE loans, while denying five applications.

Nationwide, United Community Banks is scarcely better. In 2023 overall it made 5576 mortgage loans to whites with 4114 denials. Meanwhile to African Americans nationwide it made only 477 loans, while denying fully 1246 applications. That is to say, while UCB to whites had more loans then denial, to African Americans it had nearly three times as many denials as of loans.

On April 16 the Fed approved, calling Fair Finance Watch the commenter and noting, "The data cited by the commenter corresponds to publicly available 2023 data reported by both banks under the Home Mortgage Disclosure Act of 1975 (“HMDA”), 12 U.S.C. § 2801 et seq." - this while the Fed has refused to respond to FFW's petition that it ensure 2024 HMDA data is available as before. We'll have more on this.

Watch this site.

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April 14, 2025

Gov Bowman, April 10: "to promote accountability, regulators must be transparent—both in supervision and regulation. Successful policymaking requires openness and humility, caution and a deliberate approach. I can assure the Committee that if I am confirmed as the Vice Chair for Supervision, I will be strongly committed to these values." We'll see:

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

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

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

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

April 7, 2025

CFPB Kneecaps HMDA Analysis as Feds Drop CRA Rule as Fed Hides Talks with Capital One

by Matthew R. Lee

SOUTH BRONX / DC, April 2 – Before Capital One announced and applied to buy Discover, they and their law firm were allowed to meet secretly with the Federal Reserve, see below.

On March 31 the CFPB rather than adding 2024 data to the filtering site linked above put up only modified LARS by institution and a large raw data date for which it provided a warning.

The effect of this is to make it significantly more difficult for community groups to analyze and compare lenders' HMDA data. The FRB should put a simple collating / analyzing web interface with the 2024 up forthwith.

***

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March 31, 2025

Fed Snubs New BIS Study of Data and Antitrust Cited on Capital One Discover Merger by FFW

by Matthew R. Lee

SOUTH BRONX, March 25 – Before Capital One announced and applied to buy Discover, they and their law firm were allowed to meet secretly with the Federal Reserve.

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March 24, 2025

New BIS Study of Data and Antitrust Cited to Fed Against Capital One Discover Merger

by Matthew R. Lee

SOUTH BRONX, March 21 – Before Capital One announced and applied to buy Discover, they and their law firm were allowed to meet secretly with the Federal Reserve.

Inner City Press has filed a FOIA appeal to the Federal Reserve - and raised it in a March 21 comments, along with a new Bank for International Settlements study that cris out for denial of the merger. Who's in the OCC's and Fed's wallet, now?

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March 17, 2025

Stock Fraudster Sterling Bancorp OKed To Sell Bank with Weak CRA to Everbank Shirking NY

by Matthew R. Lee, Patreon Substack

FEDERAL COURT, March 14 – Sterling Bancorp, which settled with DOJ on securities fraud, it trying to sell its Sterling Bank & Trust including in New York, where it has a need to improve CRA Investment Test rating to Everbank. Fair Finance Watch with Inner City Press on the FOIA has filed a timely first comment on, the Applications

This is a request for a full copy of, and a timely first comment on, the Applications of EverBank to acquire Sterling Bank & Trust (with a rare Needs to Improve CRA rating on Investment Test in New York), and not scandal plagued Sterling Bancorp. Sterling Bancorp was recently prosecuted by DOJ; EverBank purports that by buying the bank portion it is not touched by the scandal. But what is the showing that the criminal conduct at the Bancorp was entirely insulated from the bank and those who work there, and its practices? As a CRA matter, militating for a hearing, Sterling Bank has a rare Needs to Improve rating on the investment test in NY.

On December 24 Everbank wrote in to the Fed stating that "EverBank maintains the following two office locations in New York, neither of which is a “branch”... Islandia, NY: Located at 11 Oval Drive, Suite 107, Islandia, NY 11749.11 This location consists of an approximately 31,000 square-foot facility... EverBank notes that its lease for the Islandia, New York location is due to expire in 2025, after which EverBank expects to move the back-office operations currently conducted at that location to another non-branch office location on Long Island, New York." Needs to improve...

Nevertheless on Friday, March 14 the Fed hauled off and approved it, noting that FFW - "the commenter criticized the CRA record of Sterling Bank with respect to its “Needs to Improve” rating on the investment test (“Investment Test”) component of the bank’s statewide ratings in Michigan, New York, and Washington" - then saying "EverBank intends to renovate many of Sterling Bank’s existing branches." Yeah.

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March 10, 2025

In Florida Disparate United Community Banks Wants ANB Now Fed Qs Including on CRA

by Matthew R. Lee, Patreon Substack

FEDERAL COURT, March 6 – In Florida, United Community Bank is trying to move into the Miami area via merger, with a disparate lending record. Fair Finance Watch with Inner City Press on the FOIA has filed a timely first comment on, the Application by UCB to acquire American National Bank.

But consider United Community Bank's disparate lending record:

In Florida in 2023, United Community Banks made 240 mortgage loans to whites with 86 denials. Meanwhile to African Americans in the state it made only TWELVE loans, while denying five applications.

To this, on February 11 UCB through outside counsel replied that while Fair Finance Watch "cites data for the Bank’s lending in South Carolina, Florida and 'nationwide,' the comment’s assertion that “nationwide” data is relevant is misplaced." What a surprise. They ignore their disparities.

In March the Fed asked questions, including on CRA (and a Confidential question), and "Discuss the purpose of each of the following provisions in the Merger Agreement and whether any provisions listed below would be considered to permit UCBI or United Community Bank to exercise prior control over the management or policies of Bank: i. ii. Article 5.1(u), which states that American Bank may not make or acquire or issue a commitment for (i) any commercial real estate Loan in an original principal amount in excess of $7,000,000, (ii) any residential Loan originated for retention in the Loan portfolio in an original principal amount in excess of $1,500,00 or (iii) any commercial or industrial Loan in an original principal amount in excess of $2,000,000."

Watch this site.

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March 3, 2025

Gov Philip Jefferson said in a speech last week, "Policymakers' approach to communication has evolved over time. In the past, policymakers were not focused on clarity and transparency in their communications as they are today. For example, former Fed Chair Alan Greenspan famously quipped in 1987, "If I seem unduly clear to you, you must have misunderstood what I said."" But how transparent is the Fed now? Long delays on FOIA, for example....

February 24, 2025

Federal Reserve Defended Terminating Master Accounts Now BSJI Cites Fed on Debanking

by Matthew Russell Lee, Patreon Book Substack

SDNY COURTHOUSE, Feb 17 – The Federal Reserve - both the Board of Governors in Washington and the FRBNY - have been sued by Banco San Juan International for the terminal of its master account(s).

On the motion to dismiss, oral arguments were held on December 12 before U.S. District Court for the Southern District of New York Judge John G. Koeltl. Inner City Press was there. Thread:

Fed's lawyers from Simpson Thacher law firm cite Custodia (crypto) case. Does this outside counsel rep raise conflicts of interest on mergers?

Note: Simpson Thacher represents many banks applying to the Fed for merger approvals - why did the Fed, which has many in house lawyers, have to hire them? And isn't there now a conflict of interest on the merger applications? Fed: The Reserve Banks are not govt

Plaintiff: The Fed never closed the master accounts of Deutsche Bank, despite wrongdoing - and what about "Toronto Dominion, which pled guilty to money laundering"?

[Note: TD's Leonardo Ayala is being prosecuted in the District of NJ]

On January 8, 2025 Judge Koeltl dismissed the amended complaint, setting a time to further amend: "the defendants' motions to dismiss are granted. All of BSJI's claims are dismissed without prejudice as discussed above. At oral argument, counsel for BSJI indicated that BSJI may wish to file a second amended complaint. Tr. 16. The time to file a motion to amend, attaching a copy of the second amended complaint and explaining how the second amended complaint solves the deficiencies noted in this opinion, is January 27, 2025. The defendants may respond by February 10, 2025. The plaintiff may reply by February 17, 2025. If the plaintiff does not file any such motion by January 27, 2025, the Court will issue an order directing that judgment be entered dismissing the Amended Complaint."

On February 17 BSJI through counsel Abbe Lowell wrote in citing Fed Chair Jerome Powell's recent testimony that he is (belatedly) troubled by de-banking by the Reserve Banks. Full letter on Patreon here

Inner City Press will stay on these cases.

This case is Banco San Juan Internacional, Inc. v. The Federal Reserve Bank of New York, et al., 1:23-cv-06414 (Koeltl)

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February 17, 2025

As CFPB Home Page Goes 404 HMDA Petition to Federal Reserve by Fair Finance Watch

by Matthew Russell Lee, Patreon Book Substack

Bronx / Federal Court, Feb 11 – When a "404: Page Not Found" message began on the homepage of the U.S. Consumer Financial Protection Bureau, a call went out among consumer advocates to dig deeper in the site and begin downloading data before it is deleted. Fine.

But the CFPB has become the platform on which new data under the Home Mortgage Disclosure Act is released. Simply downloading past years' data is not enough. Where will the 2024 data go, and be available to the public? Fair Finance Watch, with Inner City Press on the FOIA, filed a petition for rulemaking and emergency mitigation with the Federal Reserve Board:

Governor Powell, Ladies and Gentlemen:

Fair Finance Watch and Inner City Press are writing to petition the Board of Governors of the Federal Reserve System under section 553(e) of the Administrative Procedure Act to engage in rulemaking and, most immediately, to take emergency measures to ensure public access to data under the Home Mortgage Disclosure Act (HMDA), including the 2024 data.

When the Consumer Financial Protection Bureau was created, the hosting of HMDA data shifted from the FFIEC to CFPB website. Today February 10, 2025 the CFPB.gov website went dark. While portions of the site are as of this writing still available, it is foreseeable that the HMDA data site may be taken down. The Community Reinvestment Act, among other banking laws, is largely enforced by use and analysis of HMDA data. It is imperative that public access to HMDA data remain.

The FRB should begin a process to ensure access to HMDA data, on FFIEC or the FRB's own website - by rulemaking, if necessary long term, but immediate on an interim basis, if necessary mirroring the CFPB cite as long as it remains under threat.

This petition concerning the continued public access to HMDA data is also made with reference to Section 553(e) of the APA, and we respectfully request a response.

Watch this site. Others like NCRC are advocating. We aim to have more from DC

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February 10, 2025

Now the Fed has announced the termination of two enforcement actions with Wells Fargo - the one with the predatory lender Wells Fargo Financial...

February 3, 2025

Crime: John Harold Rogers, 63, a former Senior Adviser for the Federal Reserve Board of Governors was arrested on charges that he conspired to steal Federal Reserve trade secrets for the People’s Republic of China

Revolving door: Coinbase has added to its Global Advisory Council former New York Fed President Bill Dudley...

January 25, 2025

It was the Federal Reserve Bank of Atlanta that on January 23 asked "Provide a complete list of the non-branch offices of EverBank, National Association and Sterling Bank. " Watch this site.

January 20, 2025

On Capital One Discover OCC Doubled Down on FOIA Withholding Now Customers Cut Off

by Matthew R. Lee

SOUTH BRONX, Jan 17 – Capital One has applied to buy Discover, in an anticompetitive deal that should be rejected by regulators if they mean what they have been saying. After they applied late March 20, Inner City Press submitted a second Freedom of Information Act request to the Office of the Comptroller of the Currency (and to the Federal Reserve).

On May 14 - still without providing FOIA documents - the OCC and Fed set a July 19 virtual public meeting.

On the eve of it, Capital One announced a vague and less than credible plan - they previously violated their ING Direct pledge - including this time $75 billion in largely subprime auto loans. Fair Finance Watch testified for three minutes.

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

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

Nor does it seem the Fed has taken note of Capital One cutting off its own customers on January 16, then passing the buck to a third party vendor, Fidelity Information Services. Something is deeply wrong with Capital One, but the Fed and OCC don't seem to care.

Meanwhile Capitol One lobbying continues even now in 2024, from New Mexico even to Harlem by a social worker with bankers on the board. How is this Astroturfing organized?

Without approvals, now the banks have set shareholders' votes for February 18, 2025.

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. It grew worse in the just-out 2023 data.

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 denied. But will it be? Watch this site.

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January 13, 2025

UMB Bank Heartland Merger Hit on Disparties and Uninsured Deposits Now Rubber Stamped

by Matthew R. Lee, Patreon Substack

SOUTH BRONX / SDNY, Jan 10 – When First Republic Bank failed / was given to JP Morgan Chase, a small list of other regional banks came into focus as in danger. Among them was UMB - a bank whose lending Inner City Press and Fair Finance Watch had been scrutinizing, and now challenge.

UMB is asking its regulators to allow it to expand, buying Denver-based Heartland. The application, Fair Finance Watch on June 21 formally told the Fed, should not be approved. In 2022, the most recent year for which Federal data is available, UMB Bank, N.A. made over 2000 mortgage loans to whites, and only 117 loans to African Americans.

For every denial to an African American, it made only 2.02 loans. But for whites, for every denial it made 3.45 loans. It should be referred to DOJ.

There is litigation, there is also this, reported at the time of Silicon Valley Bank's failure: "UMB Bank, a regional bank headquartered in Kansas City, Missouri, and with branches across the Midwest, Southwest, and Western United States, has total assets of $38 billion and deposits totaling $32 billion, according to the FDIC. However, only 16% of deposits fall under the $250,000 FDIC insurance threshold, leaving 74.11% (equivalent to $28.36 billion) vulnerable to potential losses."

Why would regulators even consider approving its expansion? On June 21, Fair Finance Watch filed a formal Community Reinvestment Act challenge to UMB's application to the Federal Reserve, adding state by state data:

UMB Bank in 2022 in Missouri made 842 mortgage loans to whites, and only 76 loans to African Americans. Meanwhile it denied 41 applications from African Americans, and only 257 from whites.

UMB Bank in Colorado - in which it seeks to expand - in 2022 made 378 mortgage loans to whites, and only 13 loans to African Americans. Meanwhile it denied six applications from African Americans, and only 107 from whites.

UMB Bank in 2022 in Texas made 78 mortgage loans to whites, and only six loans to African Americans. Meanwhile it denied two applications from African Americans, and only 27 from whites.

These disparities cry out for a referral to DOJ, and public hearings on, and denial of, UMB's major expansion application.

On October 11 UMB's outside counsel Davis Polk sent the Fed a response but withheld branch closing, subsidiary, fintech and crypto information from Fair Finance Watch - so Inner City Press cc-ed them on a FOIA request.

On November 29, the Fed responded with the branch closing list and more - now on Inner City Press' DocumentCloud here.

Watch this site.

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January 6, 2025

If the Federal Reserve Banks are not the government, how can they give out approval like this?

"New York NBT Bancorp Inc., Norwich, New York—waiver of application to acquire Evans Bancorp, Inc., Williamsville, New York, and thereby acquire Evans Bank, National Association (Evans Bank), Angola, New York, in connection with the merger of Evans Bank with and into NBT Bank, National Association, Norwich, New York.* Granted: December 18, 2024."

December 30, 2024

The Fed is supposed to sent copies of its question letters to banking to the community groups which have commented on, particularly against, the proposed merger. But on Capital One - Discover, the Fed just stopped. Capital One disclosed the letter, but not the contents, in SEC filings. A new low.

December 23, 2024

Fraudster Sterling Bancorp Bid To Sell Bank with Weak CRA to Everbank Questioned on NY

by Matthew R. Lee, Patreon Substack

FEDERAL COURT, Dec 20 – Sterling Bancorp, which settled with DOJ on securities fraud, it trying to sell its Sterling Bank & Trust including in New York, where it has a need to improve CRA Investment Test rating to Everbank. Fair Finance Watch with Inner City Press on the FOIA has filed a timely first comment on, the Applications

On December 4 Everbank's outside counsel wrote in that FFW "selectively criticizes a single component of Sterling Bank’s most recent CRA performance evaluation from states in which Sterling Bank either no longer operates, will no longer operate upon completion of the Proposed Transaction, or maintains only a de minimis banking presence" -- that would be New York, no commitment to improve on the Needs to Improve. As to Michigan the outside counsel says, or brags, "EverBank intends to close Sterling Bank’s only Michigan branch following completion of the Proposed Transaction."

On December 19, the Federal Reserve asked Everbank questions including "Explain whether EverBank’s office in New York is a “branch” within the meaning of 12 U.S.C. 1841(o)(3) and indicate whether loan proceeds are disbursed at that New York office.

3. The FR Y-3 notes: “following the Proposed Transaction, the combined organization intends to leverage the CRA and consumer protection compliance strengths of both banks to create a strong and comprehensive combined compliance program.” The FR Y-3 subsequently states that “EverBank does not anticipate any structural changes to its CRA program, CRA leadership, organizational structure, or oversight as a result of the Proposed Transaction.” Clarify whether the combined organization intends to continue to utilize EverBank’s existing CRA and consumer compliance programs following consummation. If the combined organization intends to incorporate specific aspects of Sterling Bank’s CRA and consumer those programs the combined organization intends to leverage from Sterling Bank’s existing operations.

4. The FR Y-3 notes that Sterling Bank would use commercially reasonable efforts to close its Southfield, Michigan branch... Indicate whether a branch closure notice has been submitted under section 42 of the FDI Act."

The proposal should be denied.

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December 16, 2024

SouthState Lending Disparities Triggered CRA Protest But Fed OKs Admitting Weak Carolinas

by Matthew R. Lee, Patreon Substack

SOUTH BRONX / SDNY, Dec 13 – When First Republic Bank failed / was given to JP Morgan Chase, a small list of other regional banks came into focus as in danger, banks whose lending Inner City Press and Fair Finance Watch had been scrutinizing, even more so that the 2023 data is out.

This week Inner City Press filed with the Fed, a timely first comment on, the Applications of SouthState Corporation to merge with Independent Bank Group, Inc., and Independent Bank.

SouthState in South Carolina in 2023 - data not yet included in any CRA exam - made 5013 mortgage loans to whites, and only 228 loans to African Americans. Meanwhile it denied only 670 applications from whites, and fully 195 from African Americans. SouthState should be referred to DOJ.

SouthState in North Carolina in 2023 - data not yet included in any CRA exam - made 1334 mortgage loans to whites, and only FIFTY SEVEN loans to African Americans. Meanwhile it denied only 173 applications from whites, and fully 20 from African Americans.

SouthState in Georgia in 2023 - data not yet included in any CRA exam - made 1176 mortgage loans to whites, and only 318 loans to African Americans. Meanwhile it denied only 304 applications from whites, and fully 88 from African Americans.

Nationwide in 2023, SouthState made 7798 mortgage loans to whites, and only 947 loans to African Americans. Meanwhile it denied only 2491 applications from whites, and fully 558 from African Americans.

Why would regulators even consider approving its expansion?

On August 9, SouthState submitted to the Fed a response - that deals only with Independent Bank.

On September 18, the Fed asked SouthState questions including "Confirm that no consumer products or community development programs or services offered by either organization will be discontinued by the combined organization as a result of the proposed transaction, other than those identified in Confidential Exhibit 18 to the application."

Inner City Press has submitted a FOIA request with the Fed for that obviously CRA-material Exhibits.

No thanks to the Fed, Inner City Press got the exhibit - SouthState just withdrew its request for confidential treatment, of this: "CONFIDENTIAL SouthState Bank, N.A. Independent Bank Discontinued Independent Bank Products and Services June 2024 SSC and IBTX currently plan on discontinuing Independent Bank’s mortgage warehouse program and selling its Shared National Credits (SNC) portfolio. Almost all purchased SNCs are in Independent Bank’s commercial loan portfolio, with the largest single industry concentration in energy."

But there is more being withheld. SouthState filed on September 30: "Please see Confidential Exhibit 1 to the Confidential Appendix for additional information on branch actions SouthState may plan to take that are unrelated to the proposed transaction."

On December 13 the Fed rubber stamped the deal, even as it admitted it is order poor performance in South Carolina and poor geographic distribution of SouthState's loans in North Carolina. This is today's Fed.

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December 9, 2024

First Busey $1B Bid For CrossFirst Hit by Fair Finance Watch Now Fed Asks Sealed Question

by Matthew R. Lee, Patreon Substack

FEDERAL COURT, Dec 5 – In the Midwest, Busey Bank is trying to move into the Kansas City area via merger, with a disparate lending record. Fair Finance Watch with Inner City Press on the FOIA has filed a timely first comment on, the Applications

Van Dukeman, First Busey's CEO called it a "great fit from a cultural perspective." But consider Busey Bank's culture - including contempt for CRA, its disparate lending record:

First Busey's Busey Bank in Illinois in 2023 - data not yet included in any CRA exam - made 1163 mortgage loans to whites, and only 772 loans to African Americans. Meanwhile it denied only 216 applications from whites, and fully 24 from African Americans. Busey Bank should be referred to DOJ.

Busey Bank in Missouri in 2023 - data not yet included in any CRA exam - made 49 mortgage loans to whites, and only seven loans to African Americans. Meanwhile it denied only 21 applications from whites, and fully eight from African Americans

Busey Bank in Indiana in 2023 - data not yet included in any CRA exam - made 22 mortgage loans to whites, and only two loans to African Americans.

Busey Bank in Florida in 2023 - data not yet included in any CRA exam - made 80 mortgage loans to whites, and only ONE loan to an African American.

Rather than provide CRA info, First Busey's Monica L. Bowe, Executive Vice President & Chief Risk Officer of First Busey Corporation - and of the Risk Management Association- submitted a letter saying CRA conditions are never attached - false, and telling.

Now after questions Busey's outside counsel has disclosed that Busey "has been the target of multiple law firms’ efforts to solicit customers via the internet to bring a mass arbitration based on overdraft and NSF fees, specifically Authorize Positive, Settle Negative and Representment fees, both of which Busey Bank stopped charging in 2022. Busey Bank first became aware of these solicitations in February, 2024. Representatives of Busey have spoken with representatives of some of these law firms and have received demands for attorneys’ fees and potential refunding of certain fees and Busey management is currently discussing the path forward with counsel."

On December the Federal Reserve cc-ed Inner City Press on its question to Busey Bank - but the question was entirely withheld.

That's today Fed.

The merger should be denied. Watch this site.

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December 2, 2024

UMB Bank Application for Heartland Hit on Disparties Info Withheld Now Won Under FOIA

by Matthew R. Lee, Patreon Substack

SOUTH BRONX / SDNY, Nov 29 – When First Republic Bank failed / was given to JP Morgan Chase, a small list of other regional banks came into focus as in danger. Among them was UMB - a bank whose lending Inner City Press and Fair Finance Watch had been scrutinizing, and now challenge.

For every denial to an African American, it made only 2.02 loans. But for whites, for every denial it made 3.45 loans. It should be referred to DOJ.

UMB Bank in 2022 in Missouri made 842 mortgage loans to whites, and only 76 loans to African Americans. Meanwhile it denied 41 applications from African Americans, and only 257 from whites.

UMB Bank in 2022 in Texas made 78 mortgage loans to whites, and only six loans to African Americans. Meanwhile it denied two applications from African Americans, and only 27 from whites.

These disparities cry out for a referral to DOJ, and public hearings on, and denial of, UMB's major expansion application.

On November 29, the Fed responded with the branch closing list and more - now on Inner City Press' DocumentCloud here.

Watch this site.

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November 25, 2024

First Busey $1B Bid For CrossFirst Hit by Fair Finance Watch Now They Disclose Legal Threat

by Matthew R. Lee, Patreon Substack

FEDERAL COURT, Nov 20 – In the Midwest, Busey Bank is trying to move into the Kansas City area via merger, with a disparate lending record. Fair Finance Watch with Inner City Press on the FOIA has filed a timely first comment on, the Applications

Van Dukeman, First Busey's CEO called it a "great fit from a cultural perspective." But consider Busey Bank's culture - including contempt for CRA, its disparate lending record:

Busey Bank in Missouri in 2023 - data not yet included in any CRA exam - made 49 mortgage loans to whites, and onlyseven loans to African Americans. Meanwhile it denied only 21 applications from whites, and fully eight from African Americans

Busey Bank in Indiana in 2023 - data not yet included in any CRA exam - made 22 mortgage loans to whites, and only two loans to African Americans.

Busey Bank in Florida in 2023 - data not yet included in any CRA exam - made 80 mortgage loans to whites, and only ONE loan to an African American.

The merger should be denied. Watch this site.

November 18, 2024

UMB Bank Application for Heartland Hit on Disparties Info Withheld Now FOIA Delay

by Matthew R. Lee, Patreon Substack

SOUTH BRONX / SDNY, Nov 12 – When First Republic Bank failed / was given to JP Morgan Chase, a small list of other regional banks came into focus as in danger. Among them was UMB - a bank whose lending Inner City Press and Fair Finance Watch had been scrutinizing, and now challenge.

For every denial to an African American, it made only 2.02 loans. But for whites, for every denial it made 3.45 loans.

On June 21, Fair Finance Watch filed a formal Community Reinvestment Act challenge to UMB's application to the Federal Reserve, adding state by state data:

UMB Bank in 2022 in Missouri made 842 mortgage loans to whites, and only 76 loans to African Americans. Meanwhile it denied 41 applications from African Americans, and only 257 from whites.

UMB Bank in 2022 in Texas made 78 mortgage loans to whites, and only six loans to African Americans. Meanwhile it denied two applications from African Americans, and only 27 from whites.

These disparities cry out for a referral to DOJ, and public hearings on, and denial of, UMB's major expansion application.

This is a formal FOIA request for the withheld exhibits to UMB's October 11 submission to the Federal Reserve in connection with its protested application to acquire Heartland Financial, in particular "Confidential" Exhibits A and B, including about fintech and branch closings and all activities engaged in by corporate subsidiaries. This is presumptively public; if any is withheld, all reasonably segregable portions should be provided.

UMB recites and responds: 1. Provide a description of the activities conducted by the following UMB subsidiaries: a. UMBCDC, Inc., Kansas City, Missouri; b. UMB Financial Services, Inc., Kansas City, Missouri; c. UMB Management Equity Holdings Inc., Kansas City, Missouri; d. UMB Merchant LLC, Kansas City, Missouri; and e. UMB Asset Management, LLC, Kansas City, Missouri The requested information is included in AIR Confidential Exhibit A. Convenience and Needs 2. Provide an update on UMB Bank’s branch consolidation analysis and confirm whether any of the branches listed in Public Exhibit 3 of the Additional Information Response, dated August 5, 2024 (“August AI Response”) would be consolidated, following consummation of the proposed transaction. The requested information is included in AIR Confidential Exhibit B. Discuss any plans to engage in crypto-asset-related activities or fintech partnerships. The requested information is included in AIR Confidential Exhibit A.

Again, this is both important for the public to know and is presumptively public; if any is withheld, all reasonably segregable portions should be provided.

On November 12 - a month after the request - the Fed wrote that it was unilaterally extending its time to respond to November 26.

Watch this site.

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November 11, 2024

First Busey $1B Bid For CrossFirst Hit by Fair Finance Watch Info Hidden Now FOIA Delay

by Matthew R. Lee, Patreon Substack

FEDERAL COURT, Nov 4 – In the Midwest, Busey Bank is trying to move into the Kansas City area via merger, with a disparate lending record. Fair Finance Watch with Inner City Press on the FOIA has filed a timely first comment on, the Applications

Van Dukeman, First Busey's CEO called it a "great fit from a cultural perspective." But consider Busey Bank's culture - including contempt for CRA, its disparate lending record:

Busey Bank in Missouri in 2023 - data not yet included in any CRA exam - made 49 mortgage loans to whites, and onlyseven loans to African Americans. Meanwhile it denied only 21 applications from whites, and fully eight from African Americans

Busey Bank in Indiana in 2023 - data not yet included in any CRA exam - made 22 mortgage loans to whites, and only two loans to African Americans.

Busey Bank in Florida in 2023 - data not yet included in any CRA exam - made 80 mortgage loans to whites, and only ONE loan to an African American.

There is litigation, for example under the FCRA, here - dropped without explanation, presumable settled, the FRB should ask First Busey about all outstanding consumer litigation.

And there was the First Busey board member, Elisabeth Kimmel, caught in the college admissions scandal, here.

When the Fed provided the application, the banks had withheld their CRA data. So, "This is a formal FOIA request for the withheld exhibits to the First Busey / CrossFirst application, in particular "Confidential" Exhibits 9 ("First Busey Community Reinvestment Act Data") and 10 ("CrossFirst Community Reinvestment Act data"). This is presumptively public."

Rather than provide the CRA info, First Busey's Monica L. Bowe, Executive Vice President & Chief Risk Officer of First Busey Corporation - and of the Risk Management Association- submitted a letter saying CRA conditions are never attached - false, and telling.

Inner City Press' FOIA request? The Fed on November 4 extended its time to reply - and unlike other less arrogant banks, First Busey has provided nothing. Watch this site.

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November 4, 2024

Today's FRB gives out gifts to redliners in secret. Consider: St. Louis German American Bancorp, Inc., Jasper, Indiana—waiver of application to acquire Heartland BancCorp, Whitehall, Ohio, and simultaneously merge Heartland Bank, Whitehall, Ohio, with and into German American Bank, Jasper, Indiana. Granted: October 22, 2024

From September, ongoing: Fair Finance Watch has been concerned for some time with German American Bank's outreach / image and lending. In Indiana in 2023 - in HMDA data not yet taken into account in any CRA exam - German American Bank based on its marketing made 1743 mortgage loans to whites, and only SIXTEEN loans to African Americans. Meanwhile it denied 11 applications from African Americans, and only 356 from whites

October 28, 2024

From the FRB of Chicago: "Dear Matthew: This is in reference to the filing by First Busey Corporation, Champaign, Illinois, to merge with CrossFirst Bankshares, Inc., Leawood, Kansas (“Applicant”), and thereby indirectly acquire CrossFirst Bank, Leawood, Kansas. This will acknowledge receipt of your comment email dated October 15, 2024. Your comment has been accepted by the Federal Reserve Bank of Chicago (“Reserve Bank”) relative to this filing and will be made a part of the record. A copy of your comment has been forwarded to Applicant for an opportunity to respond and if Applicant responds, you will be provided a copy of the response. To the extent the comment letter and request for a hearing dated October 15, 2024, also seeks records under the Freedom of Information Act (“FOIA”), it does not comply with section 261.11(a)(2) of the Board’s Rules relating to the submission of FOIA requests because you have combined a request for records with comments on an application and a hearing request, 12 CFR 261.11(a)(2). This correspondence, therefore, will not be processed as a FOIA request. Accordingly, if you seek information under the FOIA, you may submit a separate request to the Board’s Freedom of Information Office that complies with the requirements of section 261.11 of the Board’s Rules."

But on FOIA requests, even when the Board grants expedited processing, no records are received on a timely basis...

October 21, 2024

Expedited? From the Fed: This is in response to your electronic message dated and received by the Board on October 11, 2024. Pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, you request: the withheld exhibits to UMB’s October 11 submission to the Federal Reserve in connection with its protested application to acquire Heartland Financial, in particular “Confidential” Exhibits A and B, including about fintech and branch closings and all activities engaged in by corporate subsidiaries. You have requested expedited processing ... I have determined to grant your request for expedited processing because (1) you are primarily engaged in disseminating information, and (2) the application you seek is pending with the Board. Accordingly, your request will be processed as soon as practicable and ahead of other FOIA requests.

We'll see.

October 14, 2024

On First Busey, Inner City Press has been granted expedited processing: "I have determined to grant your request for expedited processing because (1) you are primarily engaged in disseminating information, and (2) the application you seek is open for" comment...

October 7, 2024

First Busey $1B Bid For CrossFirst Hit by Fair Finance Watch As CRA Exhibits Withheld

by Matthew R. Lee, Patreon Substack

FEDERAL COURT, Oct 4 – In the Midwest, Busey Bank is trying to move into the Kansas City area via merger, with a disparate lending record. Fair Finance Watch with Inner City Press on the FOIA has filed a timely first comment on, the Applications

Van Dukeman, First Busey's CEO called it a "great fit from a cultural perspective." But consider Busey Bank's culture, its disparate lending record:

Busey Bank in Missouri in 2023 - data not yet included in any CRA exam - made 49 mortgage loans to whites, and onlyseven loans to African Americans. Meanwhile it denied only 21 applications from whites, and fully eight from African Americans

Busey Bank in Indiana in 2023 - data not yet included in any CRA exam - made 22 mortgage loans to whites, and only two loans to African Americans.

Busey Bank in Florida in 2023 - data not yet included in any CRA exam - made 80 mortgage loans to whites, and only ONE loan to an African American.

There is litigation, for example under the FCRA, here - dropped without explanation, presumable settled, the FRB should ask First Busey about all outstanding consumer litigation.

And there was the First Busey board member, Elisabeth Kimmel, caught in the college admissions scandal, here.

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September 30, 2024

The Fed has granted expedited processing, they say, to Inner City Press' SouthState FOIA - but still no documents...

September 23, 2024

SouthState Lending Disparities Triggered CRA Challenge Now after FOIA Withheld Exhibit 18

by Matthew R. Lee, Patreon Substack

SOUTH BRONX / SDNY, Sept 19 – When First Republic Bank failed / was given to JP Morgan Chase, a small list of other regional banks came into focus as in danger, banks whose lending Inner City Press and Fair Finance Watch had been scrutinizing, even more so that the 2023 data is out.

This week Inner City Press filed with the Fed, a timely first comment on, the Applications of SouthState Corporation to merge with Independent Bank Group, Inc., and Independent Bank.

Why would regulators even consider approving its expansion?

On August 9, SouthState submitted to the Fed a response - that deals only with Independent Bank.

Inner City Press has submitted a FOIA request with the Fed for that obviously CRA-material Exhibits.

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

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September 16, 2024

The Fed is a paper tiger? Not only still nothing on the Porticoes application - on September 11 the Fed issued an enforcement action against Fieldpoint, which immediately put out "“We have a strong partnership with our regulators,” said H. Russell Holland, President and CEO of Fieldpoint Private. "Private Holdings, Inc., is the holding company of Fieldpoint Private Bank & Trust, a boutique private banking firm headquartered in Greenwich, Connecticut, with offices in New York City, Atlanta and Orlando/Winter Park. Fieldpoint Private was established at the onset of the Great Financial Crisis by 31 individuals, including former Chairmen and CEOs of some of the most well-known and successful financial and consumer firms in America."

September 9, 2024

More from the FRB Chicago, but from FRBNY, *still* nothing on the Porticoes application...

September 2, 2024

The Fed *still* hasn't sent the request Porticoes / "blank check" bank application. But from the FRB Chicago, this: "Pursuant to your email request, attached is the public portion of the below filing: ChoiceOne Financial Services, Inc., Sparta, Michigan to merge with Fentura Financial, Inc., and thereby indirectly acquire The State Bank, both of Fenton, Michigan Please confirm receipt of this email after verifying that the document could be opened." We confirmed; OOO

August 26, 2024

And SouthState's response - much of it confined to a "Confidential" exhibit:

Provide the IBTX Disclosure Schedule referenced in the Merger Agreement. A copy of the IBTX Disclosure Schedule is attached as Confidential Exhibit 1. 3. Describe in greater detail the purpose and activities of the various trusts held by SouthState and IBTX that are described in the application. Both SouthState and IBTX have formed or acquired statutory business trusts (the “Trusts”) for the purpose of issuing trust preferred securities to investors. These entities do not otherwise conduct any business activities. Each of the Trusts has issued capital and common securities and invested the proceeds thereof in an equivalent amount of junior subordinated debentures (the “Debentures”) issued by either SouthState or IBTX. The interest rate payable on and the payment terms of the Debentures are the same as the distribution rate and payment terms of the respective issues of capital and common securities issued by the Trusts. The Debentures are subordinated and junior in right of payment to all present and future senior indebtedness. SouthState and IBTX have fully and unconditionally guaranteed the obligations of their respective Trusts with respect to the capital and common securities. Except under certain circumstances, the common securities issued to SouthState or IBTX by their respective Trusts possess sole voting rights with respect to matters involving those entities. Under certain circumstances, SouthState and IBTX may, from time to time, defer the debentures' interest payments, which would result in a deferral of distribution payments on the related trust preferred securities. The Debentures are callable after five years from the date of issuance, therefore all Debentures formed or acquired by SouthState and IBTX are callable as of June 30, 2024. SouthState and IBTX have $118.6 million and $57.3 million of Debentures, respectively, outstanding as of June 30, 2024. It is SouthState’s intent to assume all Trusts outstanding at IBTX and treat the Debentures as Tier 2 capital for regulatory capital purposes. 4. Indicate whether SouthState or any of its subsidiaries are subject to any state community reinvestment laws. If applicable, explain how the proposed transaction complies with such law(s). SouthState confirms that neither SouthState nor any of its subsidiaries are subject to any state community reinvestment laws. 5. Confidential Appendix. For our responses to the information requested in the Confidential Appendix of the AIR, please see the Confidential Annex, which also contains Confidential Exhibits 1 and 2.

August 19, 2024

The Fed has asked SouthState, "4. Indicate whether SouthState or any of its subsidiaries are subject to any state community reinvestment laws. If applicable, explain how the proposed transaction complies with such law(s)." That's it?

August 12, 2024

Back on June 26 on a smaller merger, Inner City Press requested records - and was granted expedited treatment, explicitly with reference to the July 25 expiration of the public comment period. But no records were given - and on July 26, this: "Pursuant to section (a)(6)(B)(i) of the FOIA, we are extending the period for our response until August 9, 2024, in order to consult with two or more components of the Board having a substantial interest in the determination of the request." And no response to the timely request to exetnd the comment period...

But even on August 9 by 10 pm, no documents, nothing. Meanwhile the underlying bank urges delegated rubber stamp. This is today's Fed.

August 5, 2024

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

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

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

July 29, 2024

The Fed's FOIA scam is no limited to Capital One / Discovery. On June 26 on a smaller merger, Inner City Press requested records - and was granted expedited treatment, explicitly with reference to the July 25 expiration of the public comment period. But no records were given - and on July 26, this: "Pursuant to section (a)(6)(B)(i) of the FOIA, we are extending the period for our response until August 9, 2024, in order to consult with two or more components of the Board having a substantial interest in the determination of the request." And no response to the timely request to exetnd the comment period...

July 22, 2024

From Testimony Opposing Capital One's Bid to Acquire Discover July 18, 2024

The day the banks announced the proposed merger, Inner City Press submitted Freedom of Information Act requests to both the Federal Reserve and the Office of the Comptroller of the Currency. The Fed, as has become a pattern, granted Inner City Press' FOIA request expedited treatment - and then did not provide any of the responsive documents, claiming it needed more time.

July 15, 2024

On Capital One Discover 3 Minutes Each OCC Withholds 185 Pages Inner City Press Appeals - Still Nothing from the Fed

by Matthew R. Lee

SOUTH BRONX, July 9 – Capital One has applied to buy Discover, in an anticompetitive deal that should be rejected by regulators if they mean what they have been saying. After they applied late March 20, Inner City Press submitted a second Freedom of Information Act request to the Office of the Comptroller of the Currency (and to the Federal Reserve).

On May 14 - still without providing FOIA documents - the OCC and Fed set a July 19 virtual public meeting.

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

At the July 19 public meeting, "each speaker will be allotted three minutes to speak at the meeting," the OCC and Fed on July 9 said.

Meanwhile Capitol One lobbying continues, for example with a Pennsylvania state legislator extolling Capital One's subprime, here.

July 8, 2024

Now belatedly the Federal Reserve has fined Silvergate $43 million - previously,

Inner City Press submitted to the Federal Reserve a Freedom of Information Act request including: "This is a FOIA request for all record regarding the FRS' approval for the application / request for membership in the Federal Reserve System by Farmington State Bank (giving rise to FRBSF president Daly's approval on a delegated basis in 2021), and the subsequent renaming of the bank to Mooonstone and taking of a stake by FTX/Alameda. Also, for Silvergate with its FTX connections, record reflecting any review by the FRS of Silvergate's (and Provident Bancorp Inc., Metropolitan Commercial Bank, Signature Bank, Customers Bancorp Inc.) of the banks' connections with crypto-currency firms... This is a request for expedited treatment, in light of the indictment of FTX / Alameda's Sam Bankman-Fried and Caroline Ellison (cooperating), and an upcoming January 3, 2023 hearing."

The Federal Reserve has so far acknowledged receipt: "Your request has been assigned number FOIA-2023-00178. Please reference this number in all future correspondence. Request description: This is a FOIA request for all record regarding the FRS' approval for the application / request for membership in the Federal Reserve System by Farmington State Bank [also] any review by the FRS of Silvergate's (and Provident Bancorp Inc., Metropolitan Commercial Bank, Signature Bank, Customers Bancorp Inc.) of the banks' connections with crypto-currency firms."

There is also a lawsuit in Federal court in California asserting that

"Silvergate, a publicly traded and federally regulated bank catering to cryptocurrency customers, maintained both FTX and Alameda accounts. It directly aided and abetted FTX’s fraud and breaches of fiduciary duty via first-hand participation in the commingling of funds, improper transfers, and lending out of customer money. Silvergate processed billions in transfers from FTX’s client account at Silvergate to the Alameda accounts. Silvergate also accepted deposits from FTX investors—intended to be stored, traded, or cashed out—that at Bankman-Fried’s direction were wired straight to Alameda bank accounts and misused."

July 1, 2024

Governor Bowman on June 27, thou dost protest too much: The processing timelines we see also seem inconsistent with a process that is operating truly as a rubber stamp. To be clear, I think we have room to do better when it comes to timely regulatory action, while maintaining a rigorous review of applications. But extended review periods are not uncommon, particularly when you include preliminary discussions and pre-filings with regulators in the published processing timelines.

June 24, 2024

Bowman in Salzburg: "Regulators must also understand, to the extent possible, the consequences of specific innovations. Take, for example, the increasing interest in tokenization. There is a risk that tokenized products and platforms could duplicate existing bank deposits and payment rails, potentially creating parallel systems. How would these parallel systems interact with, or even replace, current systems? Will the products and platforms that duplicate these deposit and payment functions provide the same legal protections for customers and the overall financial system that they currently receive?" Crypto....

June 17, 2024

While we *still* wait for documents under FOIA request purported to approve for expedited treatment, this: "Dear Matthew, We appreciate your interest in watching and testifying at the public meeting regarding the proposal by Capital One Financial Corporation, McLean, Virginia, to acquire Discover Financial Services, Riverwoods, Illinois, pursuant to the Bank Holding Company Act; and to merge Discover Bank, Greenwood, Delaware, into Capital One, National Association, McLean, Virginia, pursuant to the Bank Merger Act. The public meeting will start at 9:00 a.m. ET on Friday, July 19, 2024, and will be hosted virtually on an online meeting platform. The Federal Reserve Board and the Office of the Comptroller of the Currency have received your request to testify and are reviewing your request." Reviewing?

June 10, 2024

This month Inner City Press has received two letters from the FRB-Dallas, one responding to CRA protest filed in March, and only now transferred from FRB-KC to Dallas (but not the Board?) and the other to the Board. Why the delay?

June 3, 2024

Conflict of interest? Revolving door? "Numisma Bank in Greenwich, Conn., has received conditional approval for a Federal Reserve master account. Numisma, which focuses on banknote distribution, is a tier 3 institution that is state-chartered but isn’t backed by the Federal Deposit Insurance Corp. The Fed has rejected applications by other financial institutions, including Custodia Bank and The Narrow Bank, on the grounds that granting access would present an “undue risk.” NOTE: Numisma was co-founded by former Fed Vice Chair for Supervision Randal Quarles...

May 27, 2024

Fed sez: SVB lost $40 billion in deposits in a single day, with management expecting $100 billion more in outflows the next day. Together, these outflows represented about 85 percent of the bank's deposits. In contrast, both the failure of Wachovia and Washington Mutual in 2008 involved less severe outflows that evolved over more than a week (the failure of Wachovia in 2008 included about $10 billion in outflows over 8 days while the failure of Washington Mutual in 2008 included outflows of $19 billion over 16 days). Return to text 4. Signature Bank received in one day more than 1,600 withdrawal requests totaling approximately $18.6 billion, representing 20 percent of its deposits. Return to text 5. First Republic lost around 20 percent of its deposits in a single day

May 20, 2024

Capital One Should Discover Merger Dead July 19 Public Meeting Inner City Press FOIAed Fed

by Matthew R. Lee

SOUTH BRONX, May 14 – Capital One has applied to buy Discover, in an anticompetitive deal that should be rejected by regulators if they mean what they have been saying. While they applied late March 20, as of 1 pm on March 22 there was no notice of the Federal Reserve's or OCC's websites. Inner City Press submitted second FOIA requests to each agency. Public hearings should be held, not only on antitrust but also lending disparities at both companies.

On April 24 the Fed extended its comment period to May 31 - without (yet?) granting public hearings, nor providing the FOIA documents.

On May 14 - still without providing FOIA documents - the Fed and OCC set a July 19 virtual public meeting: "The public meeting will be held virtually on July 19, 2024, at 9:00 a.m. EDT. Members of the public seeking to present oral comments must register by 12:00 p.m. EDT on June 28, 2024, through the online registration webpage, which will be posted on the Board's Capital One-Discover Application Reading Room by May 28, 2024."

On April 19 the Fed wrote to extended its time to respond to Inner City Press' February 19 FOIA to May 3

The OCC first put its application in its reading room. And it is an outrage, Capital One gaming the CRA system. For example "the Proposed Transaction would result in CONA establishing a new assessment area in Delaware, which will include all census tracts in Sussex County and seven contiguous census tracts in Kent County."

That for a nationwide card and subprime auto lender...

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.

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May 13, 2024

Fed Disappeared CRA Linkbancorp Condition on Approval Now NJ Branches out of CRA

By Matthew Russell Lee, Patreon Maxwell Book

SOUTH BRONX, May 10 – The Federal Reserve Board in considering the proposed merger on the rebound between New York-based Link Bank and Partners Bancorp omitted at the eleventh hour - or apparently the thirteenth hour - language about a Community Reinvestment Act condition imposed by the FDIC.

Now the Fed and its Governors have been asked Why - and when.

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.

But Link kept spinning, issuing a press release about these partial approvals without mentioning the condition, and concluding it "remains subject to the approval of the Board of Governors of the Federal Reserve System and other customary closing conditions. LINK anticipates closing the Merger in the fourth quarter of 2023." We asked, How do they know?

Well, they know that the Fed has boiler plate ready, ready to say it is concerned with HMDA disparities without acting on them, ready to say they conferred with the FDIC without acknowledging the condition the FDIC required.

The "Corrected" Fed approval emailed to Inner City Press on November 16 did not acknowledge the CRA condition. But the approval order first posted - and voted on?- did. We on November 16 filed:

Dear Chair Powell, Secretary Misback and others in the FRS: This is a formal request for reconsideration under 12 CFR Part 262.3(k) of the Board's "corrected" -- dropping the reference to FDIC's CRA Condition - Approval of the above-captioned applications by LINKBANCORP, Inc..

The Board's website currently says, of this order, that "Note: The initial version of this order was incorrect and inadvertently posted. A corrected version was posted on November 15, 2023."

Meanwhile, Deputy Associate Secretary Fennell's letter to me dated November 16 states that "today the Board of Governors of the Federal Reserve System has approved the proposal." If the approval was "today" / November 16, how was it corrected on November 15? The copy emailed to us on November 16 is entitled "Corrected."

It's worse, much worse. The original (real? approved?) version of the order stated "The FDIC’s approval of the merger of Bank with the Bank of Delmarva and Virginia Partners Bank includes a condition requiring the resultant institution to develop an action plan, including a marketing plan and additional outreach, to be submitted to the FDIC for approval, for monitoring and improving the extent of home mortgage applications from, and originations to, African American applicants in the resultant institution’s assessment areas. This condition will help ensure that the resultant institution continues to help in meeting the credit needs of the African American population in the resultant institution’s assessment areas."

It is true that the FDIC imposed a CRA condition, after receiving comments from Fair Finance Watch / Inner City Press. The FDIC sent the order with condition to us and we posted it online.

So why - and when - did the Federal Reserve, which claims to have conferred with the FDIC as primary supervisor, abruptly take out of its already-posted approval order the language about the CRA condition? Was it after the Board's approval? Who decided that the CRA condition language should be removed? Why? To make it unenforceable?

The "corrected" approval order, with the CRA language removed, is said to be: "Voting for this action: Chair Powell, Vice Chair Jefferson, Vice Chair for Supervision Barr, Governors Bowman, Waller, Cook, and Kugler." When did each vote? Were they made aware of, and is each Governor responsible for, the removal of the CRA condition language?

These are clearly facts that we could not present during the official comment period, or even prior to approval (or at least, "correction"). And they militate for reconsideration, for airing to each Governor and an explanation, given the Governors' claims and statements about their commitment to CRA.

On November 21 past 5 pm, a Federal Reserve staff attorney left Inner City Press a voicemail reading a script that the Fed General Counsel - without showing even this to the Board members - determined there was nothing new in the request. But Inner City Press didn't know about the removal of the condition language until after the Fed said it approved it - it could NOT have been shown before. UNreal. And the new(ish) Governnors? What do they think or do?

We still don't know. But now LINKBANCORP is selling branches that it acquired to a credit union, American Heritage Credit Union, and thereby taking more than $100 million of deposits out from the Community Reinvestment Act. We'll stay on this

May 6, 2024

Bowman watch, May 3 she said "the inflow of new immigrants to some geographic areas could result in upward pressure on rents, as additional housing supply may take time to materialize."

April 29, 2024

Capital One Should Discover Merger Dead FRB Extends to May 31 Inner City Press FOIAed Fed

by Matthew R. Lee

SOUTH BRONX, April 24 – Capital One has applied to buy Discover, in an anticompetitive deal that should be rejected by regulators if they mean what they have been saying. While they applied late March 20, as of 1 pm on March 22 there was no notice of the Federal Reserve's or OCC's websites. Inner City Press submitted second FOIA requests to each agency. Public hearings should be held, not only on antitrust but also lending disparities at both companies.

On April 24 the Fed extended its comment period to May 31 - without (yet?) granting public hearings, nor providing the FOIA documents.

On April 19 the Fed wrote to extended its time to respond to Inner City Press' February 19 FOIA to May 3

April 22, 2024

Capital One Should Discover Merger Dead Inner City Press FOIAed Fed Now Delay to May 3

by Matthew R. Lee

SOUTH BRONX, April 19 – ...On April 19, with the Fed's comment period coming to a close, the Fed wrote to extended its time to respond to Inner City Press' February 19 FOIA to May 3 - AFTER the close of the comment period.

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.

April 15, 2024

Fair lending be damned? 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.

April 8, 2024

Capital One Should Discover Merger Dead As Inner City Press FOIAs Fed Barr Talks Basel 3

by Matthew R. Lee

SOUTH BRONX, April 3 – Capital One has applied to buy Discover, in an anticompetitive deal that should be rejected by regulators if they mean what they have been saying. While they applied late March 20, as of 1 pm on March 22 there was no notice of the Federal Reserve's or OCC's websites. Inner City Press submitted second FOIA requests to each agency. Public hearings should be held, not only on antitrust but also lending disparities at both companies.

While the OCC has yet to provide some records requested under FOIA, it put its application in its reading room. And it is an outrage, Capital One gaming the CRA system. For example "the Proposed Transaction would result in CONA establishing a new assessment area in Delaware, which will include all census tracts in Sussex County and seven contiguous census tracts in Kent County."

That for a nationwide card and subprime auto lender...

Still no records from the Fed, so this:

This is a FOIA request for the entirety of Capital One's applications for regulatory approval of its Discover proposal, including all portions for which Capital One has requested confidential treatment, and all communications by your agency with the banks since February 19. As of March 22 at 1 am, the Fed's most recent H2A is from March 15

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.

On April 3 speaking at NCRC's Just Economy conference Barr said the Fed will not follow the OCC and FDIC with merger processing reform proposals; then he walked Basel III endgame but not explanation why the Fed can't or won't give Capital One documents requested on Feb 19, as to which they purported to grant expedited processing. Watch this site.

April 1, 2024

On the Capital One / Discover merger application, the Fed has granted Inner City Press expedited FOIA processing - but as of March 29 had not provided a single document....

March 25, 2024

Backsliding? The Fed and the other agencies "extended the applicability date of the facility-based assessment areas and public file provisions from April 1, 2024, to January 1, 2026. Therefore, banks will not have to make changes to their assessment areas or their public files as a result of the 2023 CRA final rule until January 1, 2026." Meanwhile the Fed had not provided a single record, as of March 23, in response to Inner City Press' February 19 FOIA request about Capital One / Discover...

March 18, 2024

"The Federal Reserve Board on Thursday issued an enforcement action against JPMorgan Chase & Co. and fined the firm approximately $98.2 million for an inadequate program to monitor firm and client trading activities for market misconduct. The Board's action requires JPMorgan Chase to review and take corrective action to address the firm's inadequate monitoring practices, which occurred between 2014 and 2023" - but how many of JPM Chase's acquisition has the Fed rubber stamped during the time period?

March 11, 2024

Governon Bowman in New Jersey on March 7 bemoaned that "policy reforms may make bank M&A transactions more difficult for regulators to approve and slow the application processing timeline."

March 4, 2024

The Federal Reserve is getting worse and worse on FOIA, including on banks sued by DOJ for discrimination. They wrote to Inner City Press, you requested "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 …. Staff searched Board records and located the documents that are responsive to your request. I have determined, however, that the withheld portions of the January 18, 2024, Additional Information submission that are responsive to your request contain confidential commercial and financial information (e.g., nonpublic business plans and strategies concerning compliance and lending). This information is subject to withholding and will be withheld from you pursuant to Exemption 4 of the FOIA, 5 U.S.C. § 552(b)(4). I have also determined that the information should be withheld because it is reasonably foreseeable that disclosure would harm an interest protected by an exemption described in subsection (b) of the FOIA, 5 U.S.C. § 552(b). The responsive documents have been reviewed under the requirements of subsection (b), but no reasonably segregable nonexempt information was found. Accordingly, approximately 18 pages of information will be withheld from you in full." In full...

February 26, 2024

The Fed just keeps extending its time on FOIA, and not only on Capital One / Discover: On February 20: "This is in response to your electronic message dated January 19, 2024, and received by the Board’s Information Disclosure Section on January 22. Pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, you request: 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[.] Pursuant to section (a)(6)(B)(i) of the FOIA, we are extending the period for our response until March 5, 2024, in order to consult with two or more components of the Board having a substantial interest in the determination of the request. If a determination can be made before March 5, 2024, we will respond to you promptly." Yeah.

February 19, 2024

Here's a question: What may have been the role of a Federal Reserve Governor in the lawsuit against the CRA regulation?

February 12, 2024

Before FNB Settled on Fair Lending Its Yadkin Merger Was Challenged But Fed Approved It

by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX, NY Feb 5 – When 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

On January 19 Inner City Press submitted a FOIA request; on January 31 the Federal Reserve wrote back: Pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, you request: 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[.] You also seek expedited processing for your request. In support of your request for expedited treatment, you state that “[t]his information was submitted, unilaterally withheld in full, late in the application process – there is a need to release it for public knowledge BEFORE the Board acts on the application.” I have determined to grant your request for expedited processing. Accordingly, your request will be processed as soon as practicable and ahead of other FOIA requests." But still no documents...

January 29, 2024

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

Lakeland Bank DOJ Deal Left Disparities So Protest & Fed Asks of DOJ Settlement Withheld

by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX, NY, Jan 19 – 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 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.) Inner City Press / Fair Finance Watch is a timely protestant to the application; this is also again request that the FRB begin putting all applications online, since the Fed has a new electronic system for applicants. What is the rationale for not doing this, and allowing for delay for the public and community organizations? In these contexts, this comment period should be extended."

Watch this site.

January 15, 2024

This is what the Fed is focused on: The Federal Reserve Board on Thursday announced the execution of the enforcement actions listed below: Consent prohibition order against John Freeze Former employee of Bank of Jackson Hole, Jackson, Wyoming Misappropriation of documents, including confidential supervisory information Consent cease and desist order and civil money penalty against Randy Johnson Former employee of Farmers and Merchants Savings Bank, Manchester, Iowa Misappropriation of confidential bank records

January 8, 2024

Corporate Fed, Dallas edition: Thomas J. Falk, retired chairman and chief executive officer, Kimberly-Clark Corporation, Dallas, Texas, renamed Chair.

January 1, 2024

The Federal Reserve is on Threads, UNlike even the United Nations....

December 25, 2023

Why not the Fed? 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

From Basel III endgame to climate, the Fed has its finger in the wind. But on protests from low income areas of banks' redlining? Not so much.

December 11, 2023

The Fed didn't even ask Atlantic Union about this issues, which Inner City Press raised in September:

Re: Second Comments Opposing the Applications by Atlantic Union to acquire American National Bankshares - after Atlantic Union is fined by CFPB for exact issue raised in first comment

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

This is a second comment opposing Applications of Atlantic Union Bankshares Corporation, Richmond, Virginia to acquire American National Bankshares Inc., and American National Bank & Trust Company. Given the CFPB's December 7 fine and statement against Atlantic Union, on a precise issues raised in our first comment (and dismissed in AU's law firm's response, and not asked about by the FED in its AI letter), this comment must be considered timely.

See, "CFPB Finds Atlantic Union Bank Misled Customers About Fees The Consumer Financial Protection Bureau (CFPB) has ordered Atlantic Union Bank to pay $6.2 million, saying the bank misled customers and improperly enrolled them into paying overdraft fees. The $6.2 million in payments includes refunding at least $5 million to consumers and paying a $1.2 million penalty to the CFPB’s victim relief fund, the regulator said in a Thursday (Dec. 7) press release. The CFPB found that Atlantic Union Bank violated federal law when enrolling thousands of customers in checking account overdraft programs by phone, according to the release. Specifically, the bank charged fees without proper consent and misled customers about the terms and costs of overdraft coverage, the release said. “Atlantic Union Bank harvested millions of dollars in overdraft fees through a host of illegal practices,” CFPB Director Rohit Chopra said in the release. “Americans are fed up with junk fee scams and the CFPB will continue its work to ensure families are treated fairly.” https://www.pymnts.com/news/cfpb/2023/cfpb-finds-atlantic-union-bank-misled-customers-about-fees/

The comment period should be extended; evidentiary hearings should be held; and on the current record, the application should not be approved

December 4, 2023

On December 1 Fed Government Michael Barr said, "Foreign banks that have branches in the United States have access to the discount window. Outside the United States, some of these firms also have access to dollar liquidity from their own central banks" -- which as Argentina moves to disband its central bank....

November 27, 2023

Fed Dropped CRA Condition on Linkbankcorp Approval after Posting now Governors Not Told

By Matthew Russell Lee, Patreon Maxwell Book

SOUTH BRONX, Nov 21 – The Federal Reserve Board in considering the proposed merger on the rebound between New York-based Link Bank and Partners Bancorp omitted at the eleventh hour - or apparently the thirteenth hour - language about a Community Reinvestment Act condition imposed by the FDIC.

Now the Fed and its Governors have been asked Why - and when. But the Fed General Counsel dismissed the request for reconsideration without the Governors even seeing it.

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.

A "Corrected" Fed approval emailed to Inner City Press on November 16 did not acknowledge the CRA condition. But the approval order first posted - and voted on?- did. We on November 16 filed a request for reconsideration, on this site.

Watch this site.