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June 19, 2017


Regulators Said Sterling's CRA Data Unreliable, ICP on FOIA Games, Sterling Response Here

By Matthew R. Lee, New Platform

NEW YORK, June 17 – Sterling Bank, which is applying for approvals to acquire Astoria Bank, is known by its regulators to have filed unreliable Community Reinvestment Act data from at least 2014 through 2016, a document obtained by Inner City Press shows. The story, and outrage, has been picked up by the American Banker newspaper here, by Paul Davis and Allison Prang, crediting Inner City Press - and Sterling Bank had no comment. Instead, Sterling's outside counsel Wachtel Lipton chose to snail-mail its response to the wrong address, and not e-mail it to Fair Finance Watch. Via here, with envelope re-submitted to Fed and OCC. The OCC has now put up a roadblock to releasing the records Inner City Press has requested under the Freedom of Information Act, writing: "The purpose of this letter is to seek additional information pertaining to your recent request for information from the Office of the Comptroller of the Currency. Your request dated May 13, 2017 was received in my office on May 15, 2017. You requested any and all records related to Sterling Bank's application(s) to acquire Astoria and Sterling Bank's CRA data. Upon further review, we determined that we need clarification on the date range for search of Sterling Bank’s CRA data. If I have not received this information by COB June 19th I will assume that you no longer seek this information and consider your request closed." Inner City Press has responded: "   In response to Inner City Press' now month-old FOIA request concerning the CRA data the OCC knew and knows to be unreliable, you have asked that by June 19 ICP specify the date range for the request. While not understanding the OCC's delay in requesting this, we hereby timely specify that the date range is from three years ago to the date of your response. Please confirm receipt of this (including explaining your letter since you wrote “we need clarification on the date range for search”) and please provide the records as we intend to comment on them, for obvious reasons. Thank you." Meanwhile, Sterling's lawyers at Wachtell Lipton chose to snail mail their response to Fair Finance Watch, putting it in the mail three days after it was dated (now online via Patreon here.)

June 12, 2017 

On Brazil Land Grabs & CRA Flaws, Fed Parrots TIAA, Which Alludes To Confidential Info

By Matthew Russell Lee

UNITED NATIONS, June 8 – The lack of seriousness in US bank regulation, the mechanical repeating of whatever a challanged bank says, is exemplified by the Federal Reserve Board's June 7 approval of TIAA's application to acquire Everbank of Florida, which Inner City Press / Fair Finance Watch on October 29, 2016 challenged. After Inner City Press' challenge, the Fed asked some questions, and TIAA defended its investments in land grabs in Brazil. On this, the Fed's approval order repeats word for word, apparently without inquiry, the bank's law firm's defense. The bank wrote: "We are grateful for this opportunity to respond to the comment letter filed by Inner City Press / Fair Finance Watch on 29 October 2016 regarding the application submitted by TCT Holdings, Inc., Teachers Insurance and Annuity Association of America (“TIAA”)... that TIAA has engaged in improper business practices in Brazil should be considered by the Federal Reserve Board as a factor when considering the managerial resources of the Applicants. The news article cited in the Comment Letter does not provide a complete or accurate portrayal of how TIAA conducts business in Brazil and other markets... TIAA is a signatory to the U.N. Principles for Responsible Investment." The Fed's approval order also cites these UN "principles." On June 1, just before the approval, TIAA's law firm David Polk wrote in: You have asked us to supplement our responses to certain allegations made in protests by Inner City Press/Fair Finance Watch regarding the lending practices of TIAA-CREF Trust Company, FSB (“TIAA FSB”) and EverBank.  As you are aware, we have provided substantial information in response to the allegations. We have received the following information from TIAA FSB: While the allegation of discriminatory lending focuses on the St. Louis MSA by TIAA FSB, we wish to make three important points in response. First, the allegation, using HMDA data for the St. Louis MSA, focuses on a small number of loans made in the MSA.  We do not think the small sample, when analyzed, demonstrates a pattern or practice of discrimination. Second, TIAA, FSB operates no brick and mortar branches in the St. Louis MSA.  Its participation in the MSA primarily results from the use of internet offerings as well as other broader-based channels.  To focus on the results in the St. Louis MSA where there are no physical locations does not fairly reflect the nature of TIAA, FSB’s business strategy or its overall record of non-discriminatory lending. Third, as reflected above, the TIAA FSB mortgage offerings are nationwide in scope using the internet and other broad-based distribution channels.  Focusing on a single market, regardless of its location, does not fairly reflect or represent TIAA FSB’s business strategy or its overall record. On May 25, 2017, TIAA FSB received the results from its Fair Lending Examination by the OCC.  While the results of that examination constitute confidential supervisory information, it would be useful for the Federal Reserve to obtain a copy of the results of the examination.  If you wish, TIAA FSB would be pleased to seek approval to share the results of the examination with you." How cozy. We'll have more on this.

June 5, 2017

Regulators Said Sterling's CRA Data Unreliable, Fed Expedites Now Delays ICPs FOIA, OCC Cover Up

By Matthew R. Lee, New Platform

NEW YORK, June 3 – Sterling Bank, which is applying for approvals to acquire Astoria Bank, is known by its regulators to have filed unreliable Community Reinvestment Act data from at least 2014 through 2016, a documentobtained by Inner City Press shows. The story, and outrage, has been picked up by the American Banker newspaper here, by Paul Davis and Allison Prang, crediting Inner City Press - and Sterling Bank had no comment. Instead, Sterling's outside counsel Wachtel Lipton chose to snail-mail its response to the wrong address, and not e-mail it to Fair Finance Watch. Via here, with envelope re-submitted to Fed and OCC. This while the Federal Reserve has granted Inner City Press' request for expedited treatment of its FOIA request for all records, promising the responsive documents by June 1. But now the Fed, in a June 1 letter, has unilaterally extended its time to June 22: "Dear Mr. Lee, This correspondence is to provide you with an update on the status of your FOIA request. The search for records is being completed and staff is beginning to review the search results for responsiveness and releasability.  We will continue to process your request as quickly as possible.  Accordingly, the Board hopes to be able to respond to your request, or provide a status update, on or before June 22, 2017.  Very truly yours, Jeanne M. McLaughlin Manager, Freedom of Information Office." Why expedite and then extend? Why did the OCC rush a cover-up "Satisfactory" rating? We'll have more on this. First Fed letter on Scribd, here.

May 29, 2017

After Fair Finance Watch Protested Synovus - Cabela, Federal Reserve Asks Synovus 7 Questions

By Matthew R. Lee

NEW YORK, May 22 –  The Federal Reserve has asked  Synovus more than a half dozen questions on May 22, on its (straw-man)  application to acquire Cabela's World's Foremost Bank, the questions annexed on May 22 here. Two months after Inner City Press reported  Capital One failing in its  proposal to acquire this   "World's Foremost Bank," a way  to try to avoid the regulators  and Capital One's Community  Reinvestment Act record  emerged. The scam involves Synovus buying the bank then passing one the credit card   receivables to Capital One, while keeping the deposits, so  Capital One wouldn't be  reviewed under CRA. The Fair Finance Watch has now opposed this, in a filing to the Federal Reserve. NCRC has commented as well. We'll have more on this.

May 22, 2017

Regulators Said Sterling's CRA Data Unreliable, Sterling Mis-Sends Response, Fed Expedites ICPs FOIA

By Matthew R. Lee, New Platform

NEW YORK, May 20 – Sterling Bank, which is applying for approvals to acquire Astoria Bank, is known by its regulators to have filed unreliable Community Reinvestment Act data from at least 2014 through 2016, a document obtained by Inner City Press shows. The story, and outrage, has been picked up by the American Banker newspaper here, by Paul Davis and Allison Prang, crediting Inner City Press - and Sterling Bank had no comment. Instead, Sterling's outside counsel Wachtel Lipton chose to snail-mail its response to the wrong address, and not e-mail it to Fair Finance Watch. Via here, with envelope re-submitted to Fed and OCC. This while the Federal Reserve has granted Inner City Press' request for expedited treatment of its FOIA request for all records, promising the responsive documents by June 1. Fed letter on Scribd, here.

Regulators Said Sterling's CRA Data Unreliable, Sterling Mis-Sends Response, Fed Expedites ICPs FOIA, Here by Matthew Russell Lee on Scribd

Fair Finance Watch has asked both the Fed and OCC to extend their comment periods past this date. Watch this site. Sterling has issued a press release ("covered" without any analysis by Reuters) that "the Federal Reserve inadvertently made public confidential supervisory information.. Because of the legal constraints relating to disclosure of confidential supervisory information, we are working closely with our regulators to craft a more detailed public response." Sterling is working WITH the regulators - the judges in this case - to spin its inaccurate data? After on its last acquisition, challenged by ICP, having to make a CRA compliance plan? Inner City Press has submitted Freedom of Information Act requests (a response here) and Fair Finance Watch has filed additional comments to the Federal Reserve and OCC, demanding public hearings into the unreliable data AND into how the regulators were dealing with (or covering up) the issue, in stealth. We'll have more on this: the US Federal Reserve denied Fair Finance Watch's request to extend the comment period on Sterling's application, in which even the Fed suspects there is incorrect CRA data.

On May 11, the Federal Reserve Bank of New York along with questions about about branch closures and a CRA plan required after Fair Finance Watch's previous challenge to Sterling asked: "In a letter dated December 23, 2016, from the OCC to Sterling Bank regarding the OCC's data integrity review, the OCC stated that Sterling Bank's 2014-2016 CRA data is not reliable and that Sterling Bank lacks an effective process for collecting, verifying and reporting such data. To the extent that any of the CRA data in the notice is incorrect, submit the corrected data. In addition, describe Sterling Bank's efforts to address its CRA data compliance management deficiencies."

So on April 26 in Sterling's analysts' call, did CEO Jack Kopnisky or Senior EVP Luis Massiani disclose the “unreliable” CRA data to, among others, Dave Bishop – FIG Partners, Casey Haire – Jefferies, Alex Twerdahl – Sandler O'Neill,, Collyn Gilbert – KBW, Matthew Breese – Piper Jaffray and Erik Zwick – Stephens Inc? Questions about this deal (here) and the Fed's commitment to public scrutiny are raised by its simultaneous denial of FFW's request for a hearing and to extend the comment period. There is no indication that the "corrected" CRA data would ever be made available to the public, or that this issue would not have been swept under the US bank regulators' carpet, like so many others. We'll have more on this. 

May 15, 2017

Regulators Said Sterling Bank's CRA Data Unreliable, ICP Exposed It, FFW Demands Hearing

By Matthew R. Lee, New Platform

NEW YORK, May 12 – Sterling Bank, which is applying for approvals to acquire Astoria Bank, is known by its regulators to have filed unreliable Community Reinvestment Act data from at least 2014 through 2016, a document obtained by Inner City Press shows. The story, and outrage, has been picked up by the American Banker newspaper here, by Paul Davis and Allison Prang, crediting Inner City Press - and Sterling Bank has "no comment." But Fair Finance Watch has filed additional comments to the Federal Reserve and OCC, demanding public hearings into the unreliable data AND into how the regulators were dealing with (or covering up) the issue, in stealth. We'll have more on this: the US Federal Reserve denied Fair Finance Watch's request to extend the comment period on Sterling's application, in which even the Fed suspects there is incorrect CRA data.

On May 11, the Federal Reserve Bank of New York along with questions about about branch closures and a CRA plan required after Fair Finance Watch's previous challenge to Sterling asked: "In a letter dated December 23, 2016, from the OCC to Sterling Bank regarding the OCC's data integrity review, the OCC stated that Sterling Bank's 2014-2016 CRA data is not reliable and that Sterling Bank lacks an effective process for collecting, verifying and reporting such data. To the extent that any of the CRA data in the notice is incorrect, submit the corrected data. In addition, describe Sterling Bank's efforts to address its CRA data compliance management deficiencies."

So on April 26 in Sterling's analysts' call, did CEO Jack Kopnisky or Senior EVP Luis Massiani disclose the “unreliable” CRA data to, among others, Dave Bishop – FIG Partners, Casey Haire – Jefferies, Alex Twerdahl – Sandler O'Neill,, Collyn Gilbert – KBW, Matthew Breese – Piper Jaffray and Erik Zwick – Stephens Inc? Questions about this deal (here) and the Fed's commitment to public scrutiny are raised by its simultaneous denial of FFW's request for a hearing and to extend the comment period. There is no indication that the "corrected" CRA data would ever be made available to the public, or that this issue would not have been swept under the US bank regulators' carpet, like so many others. We've submitted FOIA requests. We'll have more on this. 

May 8, 2017


After Capital One Failed on Cabela, Synovus Applies & FFW Protests to Federal Reserve, Here

By Matthew R. Lee

NEW YORK, May 6 – Two months after Inner City Press reported Capital One failing in its proposal to acquire Cabela's "World's Foremost Bank," a way to try to avoid the regulators and Capital One's Community Reinvestment Act record emerged. The scam involves Synovus buying the bank then passing one the credit card receivables to Capital One, while keeping the deposits, so Capital One wouldn't be reviewed under CRA. The Fair Finance Watch has now opposed this, in a filing to the Federal Reserve: "On behalf of Inner City Press / Fair Finance Watch (FFW), this is a timely first comment opposing and requesting an extension of the FRS' public comment period on the Application by Synovus - and, we contend, CAPITAL ONE NA, to acquire the “WORLD'S FOREMOST BANK.”This comment is timely. For the record, there was initially filed with the OCC an application by Capital One to buy this “Foremost Bank.” When the compliance problems of that proposal became clear, this sham transaction was devised: for Synovus (also dubious) to make the initial acquistion, and then pass much of it on to Capital One, thereby evading review of Capital One, including but not limited to CRA review. This should not be countenanced. This applications is not even listed in the FRB's H2A, but only the H2, thusly: “* 18C Not applicable Synovus Bank, Columbus, Georgia, to acquire 05/19/2017 certain assets and to assume the deposits of World's Foremost Bank Sidney, Nebraska” It does not mention the role of Capital One. In the New York City MSA in 2015, the most recent year for which HMDA data is available, for conventional home purchase loans Capital One denied the applications of whites 23% of the time, while denying African Africans fully 45% of the time, and Latinos even more, 46% of the time. This is unacceptable.
Meanwhile, Capital One is “closing branches in Laurel, Gaithersburg, Frederick and Merrifield.”
As to Synovus' Bank, in 2015 in the Atlanta GA MSA it made 53 home purchase loans to whites and only seven to African Americans, NONE to Latinos. In the Birmingham Alabama MSA it made 45 home purchase loans to whites and only three to African Americans. If the bank cites Synovus Mortgage, note that in the Charlotte NC MSA in 2015 for home purchase loans, it lend to whites but not African Americans much less Latinos. Fair Finance Watch will submit further comments in the extended comment period. On the current record, the application(s) should be denied."

May 1, 2017

After FFW Protest, Fed Cites Community Bank OCC Deal & Disparities, Rubber-stamps Merger

By Matthew R. Lee

NEW YORK, April 26 – At what point does bank executives' spin to investors and the media become more than misleading? Take Community Bank System (NYSE: CBU), which received on March 13 consumer lending questions on top of the nine earlier questions from the Federal Reserve on its proposal to acquire Merchants, after its CEO derided issues Fair Finance Watch raised about the proposal. Despite scanty responses and records, the Federal Reserve six weeks later on April 26 approved the application, reciting that "a commenter objected to the proposal on the basis of alleged disparities in the number of conventional home purchase loans, refinance home purchase loans, or home improvement loans offered to African American or Hispanic borrowers, as compared to white borrowers, by Community Bank in the Buffalo-Cheektowaga Niagara Falls, New York, Metropolitan Statistical Area (“Buffalo/Niagara MSA”) and
the Syracuse, New York, Metropolitan Statistical Area (“Syracuse MSA”) as reflected in data reported under the Home Mortgage Disclosure Act (“HMDA” for 2015." The disparities were and are extreme. The Fed's order claims "The Board is concerned when HMDA data reflect disparities in the rates of loan applications, originations, and denials among members of different racial or ethnic groups in local areas. These types of disparities may indicate weaknesses in the adequacy of policies and programs at an institution for meeting its obligations to extend credit fairly." The Fed even recites that "Community Bank’s
compliance with conditions imposed by the OCC in connection with Community’s 2015
acquisition of Oneida and the related merger of Oneida Savings Bank into Community
Bank.33 As a condition of approval of the bank merger application, the OCC required
that Community Bank create a CRA AA Delineation Policy and modify its AAs in
accordance with that policy." And? Finally, the Fed uses its illegitimate rule change slipped into the People's United order, to limit merger review. This is today's Fed. We'll have more on this.

April 24, 2017

Better late than never: "The Federal Reserve on Thursday announced two enforcement actions against Deutsche Bank AG that will require the bank to pay a combined $156.6 million in civil money penalties."

April 17, 2017

  Following the protest by Fair Finance Watch, the Federal Reserve has asked TIAA-CREF a fifth round of questions: "Provide an update on EverBank’s CRA activities since its last publicly available CRA Performance Evaluation. Your response should include any significant CRA initiatives undertaken, particularly with respect to credit and deposit products and retail banking services targeted toward low-to-moderate income geographies and individuals. In addition, provide information regarding community development lending, investments, and services in EverBank’s CRA assessment area since the last evaluation period, including the total number and dollar amount (except for community development services) and a brief description of the most significant community development loans, investments, and services." We'll have more on this.

April 10, 2017

 How sleazy is today's Federal Reserve? After they slipped a major reduction in merger reviews into a bank merger approval order, when Inner City Press / Fair Finance Watch formally challenged it in a Request for Reconsideration, the response was a voice mail that the Board has voted against the request. A phone call to ask what that meant was not returned. We'll have more on this.

April 3, 2017

ICP Timely Requests Reconsideration of Federal Reserve Loosening Merger Reviews Without Comment

By Matthew R. Lee

MAIN STREET, March 27 – The US Federal Reserve Board, which bears more than a little responsibility for the global financial crash from 2008 due to inattention to predatory lending including on mergers, has now further reduced its scrutiny of bank mergers, with little notice to date. Now Fair Finance Watch and Inner City Press has timely challenged the Federal Reserve's stealth reduction of scrutiny, in a timely request for reconsideration filed with the Federal Reserve on the evening of March 27, below. FFW and others including NCRC protested, and Inner City Press has Freedom of Information Act requests pending regarding, the application by People's United to acquire Suffolk County National Bank.

FFW showed that  in the the New York City MSA, "People's United made 82 home purchase loans to whites and NONE to African Americans or Latinos. This is redlining; this proposed acquisition could not legitimately be approved and People's United should be referred for prosecution for redlining by the Department of Justice and CFPB."

When the Fed ruled on People's application, it added this: "In 2012, in its order approving Capital One Financial Corporation’s acquisition of certain U.S. operations of ING, the Board stated that a proposal that involves an acquisition of less than $2 billion in assets, that results in a firm with less than $25 billion in total assets, or that represents a corporate reorganization may be presumed not to raise material financial stability concerns absent evidence that the transaction would result in a significant increase in interconnectedness, complexity, cross-border activities, or other risk factors.  Since establishing this presumption, the Board’s experience has shown that proposals involving an acquisition of less than $10 billion in assets, or that result in a firm with less than $100 billion in total assets, are generally not likely to create institutions that pose systemic risks. Transactions below either of these asset thresholds have typically not involved, or resulted in, firms with activities, structures, and operations that are complex or opaque. Such transactions have also not materially increased the interconnectedness or complexity of the financial system. Accordingly, the Board now presumes that a proposal does not raise material financial stability concerns if the assets involved fall below either of the aforementioned size thresholds, absent evidence that the transaction would result in a significant increase in interconnectedness, complexity, cross-border activities, or other risk factors." Why wasn't this subject, at least, to notice and comment rulemaking? Why now? FFW and ICP have filed a "timely request for reconsideration, on behalf of timely commenters Fair Finance Watch and Inner City Press (ICP) of the Approval and Stealthy Announced Change in Financial Stability Review Presumptions in the Board's March 16 Approval of Application by People's  United Financial to acquire 100 percent of the voting shares of, and thereby merge with, Suffolk Bancorp, and thereby indirectly acquire voting shares of The Suffolk County National Bank, both in Riverhead, New York. While there are many portions of the approval order crying for reconsidering, to be clear ICP will herein have the following focus, on the Federal Reserve Board's misuse of this proceeding and approval order to purport to change its review of future applications, on the financial stability and inevitably related factors. What is the basis of the Federal Reserve determining that post-crisis scrutiny should be reduced? The above quoted portion of the order must be reconsidered, stripped out, and made subject to public comment. On fair lending issues, the Order does not appropriately address or take into account that in 2015 in the New York City MSA, People's United made 110 home purchase loans to whites and only ONE to an African American and only four to Latinos.
Again, this is systematic redlining; this proposed acquisition could not legitimately be approved and People's United should be referred for prosecution for redlining by the Department of Justice and CFPB. ICP said that a hearing was needed, and now after the Fed's insertion of a policy change into the Order, reiterates that." We'll have more on this.

March 27, 2017

  The Federal Reserve has chosen to make it nearly impossible to track open comment periods, still listing as pending such applications as that by NY Community Bank to acquire Astoria (since superseded by Sterling). We'll have more on this.

March 20, 2017

From the Fed: "This will acknowledge receipt of your electronic message dated and received by the Board's Freedom of Information Office on March 7, 2017, in which you request, pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, the entirety of the March 7, 2017 submission in connection with the application by Community Bank System to acquire Merchants Bank. The Board makes every effort to fulfill requests in a timely manner; however, there may be delays in fulfilling complex requests or those that require consultation."

And nothing since.

March 13, 2017

The Federal Reserve has asked Simmons:

"1. The preamble to the Agreement and Plan of Merger by and between Simmons and Hardeman dated November 17, 2016 (“Agreement”), provides that certain directors and
executive officers of Hardeman have entered into voting agreements in connection with the merger. Provide copies of the voting agreements referenced as Exhibit A to the
Agreement.

2. Provide the Target’s Disclosure Memorandum and the Buyer’s Disclosure Memorandum as referenced in the Agreement.

3. Page 1 of Simmons’s additional information response dated February 22, 2017, provide that, upon consummation of the holding company merger, Messrs. Ed Woodside, Hunter
Simmons, Mike McGregor, and Kirk Goehring would join the Simmons organization as senior management officials. Discuss whether, upon joining the Simmons organization,
any of these individuals would also serve as a director or senior management official at any other banking organization, and if so, indicate the position(s) and organization(s) at
which the individual would serve. "

March 6, 2017

We note long time Board Secretary Robert deV. Frierson, with whom Inner City Press has exchanged many FOIA and merger comment letters, is retiring - enjoy and Ann Misback taking over April 2, 2017. The FOIAs and comments will continue!


After FFW Protest, Fed Sends Community Bank System 9 Questions, CEO Tryniski Trashes CRA

By Matthew R. Lee

NEW YORK, March 2 – At what point does bank executives' spin to investors and the media become more than misleading? Take Community Bank System (NYSE: CBU), which has now received nine additional questions from the Federal Reserve on its proposal to acquire Merchants, after its CEO derided issues Fair Finance Watch raised about the proposal.

  On its last proposal, CBSI bad-mouthed a Community Reinvestment Act protest even as it had to delay its Oneida deal. First, CBSI's "Hal Wentworth said that Inner City Press is not a local group and pointed out that letter was the only one filed on the Oneida deal. 'This activist does not do business with either Oneida or Community Bank, but nonetheless made vague allegations regarding Community,' Wentworth said. 'These allegations were entirely without merit and will be fully addressed by Community Bank and Oneida Savings in the application process.'" Then the deal was significantly delayed, with CBSI pushing the date back.

  More spin:  CFO Scott Kingsley told the media that FFW's protest "is not the sole reason. We have other things that have to sequentially happen to get to the technological conversion in July. When we did not have a definitive answer from the Fed or other parties last week, that put the technological conversion at risk, so we opted not to go ahead.”

  This time, it went to the CEO Mark Tryniski, who in January 2017 told stock analysts that "despite the baseless protest filed with the Fed Reserve by a serial activist, we expect to close in the second" question. We'll see. Among the nine questions: "Community Bank states that, to the extent it does not intend to continue to offer certain loan products and services offered by Merchants Bank post-merger, it does not believe that not offering such products and services would have a significant impact on the target bank's communities. As an example, Community Bank cites the fact that Merchants Bank would no longer accept applications for FHA/VA loans (on behalf of a mortgage company), but that Community Bank would offer loan products and programs which are not currently offered by Merchants Bank that Community Bank believes are comparable and 'equally valuable' to its communities, such as FNMA's Home Ready Program, Community Bank's Affordable Housing Program, and the USDA loan program. Compare the features of FHA and VA loans for which applications are presently taken by Merchants Bank with the features of the products and programs that Community Bank asserts are comparable, including any features of FHA and VA loans that are not covered by Community Bank's offerings."  Watch this site.

February 27, 2017

   The Federal Reserve, confronted even with court settlements by banks, says it was without admission of guilt. From February 24: "FNB’s overdraft practices were found to be unfair trade practices resulting in unjust enrichment as part of a class-action litigation, Ord v. First National Bank of Pennsylvania, No. 2:12-cv-00766-AJS (W.D. Pa. dismissed June 21,
2013). The case was settled without any admission of wrongdoing by the parties. Final Judgment & Order of Dismissal with Prejudice at 4–5, Ord (No. 2:12-cv-00766-AJS). " We'll have more on this.

February 20, 2017

Coulda shoultd woulda will; the Fed barely reviews unless comments received. So...

 "First Bancorp (NASDAQ - FBNC), the parent company of First Bank, reports that it has received notification from the Federal Reserve Bank of Richmond that the Company's merger application to acquire Carolina Bank Holdings, Inc. ("Carolina Bank Holdings") has been approved. All regulatory approvals have now been received, and the holding company merger date is expected to be March 3, 2017."

February 13, 2017

Governor Tarullo will leave the Fed by April 5. And who will take his place? There are still FOIA improvements needed...

February 6, 2017

The Federal Reserve has asked United Bankshares, on its protested application to buy Cardinal,

"In its January 13, 2017, Letter Responding to the Request for Additional Information, United indicates there are currently two pending litigation matters against UB WV in  which allegations have been made involving consumer protection laws. Please provide additional information about these matters, including, at a minimum, the identity of the parties, the nature of the claims, the specific consumer protection laws implicated, the current posture of the litigation, and the anticipated time frame for disposition."

January 30, 2017

The Federal Reserve's anti-money laundering enforcement action against BB&T is far to vague. We'll have more on this.

January 23, 2017

  Among other comments, Fair Finance Watch has filed this:

On behalf of Inner City Press/Fair Finance Watch (ICP), this is a timely first comment opposing and requesting an extension of the FRB's public comment period on the Application of Community Bank System to acquire Merchants Bancshares, Inc. and Merchants Bank. This first comment is timely:

Community Bank System proposes to acquire Merchants. But in the the Buffalo and Syracuse MSAs in 2015, the most recent year for which Home Mortgage Disclosure Act data is publicly available, Community Bank NA dramatically excluded people of color.

For conventional home purchase loans in the Buffalo MSA in 2015, Community Bank NA made 58 such loans to whites and NONE to African Americans. It denied the only application it received from an African American.

For refinance home purchase loans in the Buffalo MSA in 2015, Community Bank NA made 19 such loans to whites and NONE to African Americans or Latinos.

For home improvement loans in the Buffalo MSA in 2015, Community Bank NA made 100 such loans to whites and NONE to African Americans or Latinos.

This is outrageous.

In the Syracuse MSA in 2015, Community Bank NA made 155 conventional home purchase loans to whites and NONE to African Americans.

For refinance loans in the Syracuse MSA in 2015, Community Bank NA made 121 such loans to whites and NONE to African Americans. It denied the only application it received from an African American.

This is outrageous.

Also, “Vermont still has 6 other state-chartered banks, but they all serve small regions of the state.... The last state-chartered bank to merge with a federally-chartered bank was Chittenden Bank, which became part of the Connecticut-based People’s United Bank on Jan. 1, 2008.”

In this context, the comment period should be extended so that public evidentiary hearings can be held, and the application should be denied.

Nor should Community Bank Systems be permitted to acquire Northeast Retirement Services...


January 16, 2017

This was some questioning to / of the Federal Reserve...

January 9, 2017

The Federal Reserve has asked, after comments, about branches closings and consolidations:

"In response to Question 10 of the Bank Merger Act application, United indicates that it anticipates consolidating six UBVA branches into six Cardinal Bank branches and six Cardinal Bank branches into six UBVA branches, and is considering consolidating two additional branches. Exhibit L to Form 2070 indicates that United plans to consolidate six UBVA branches into six Cardinal Bank branches and seven Cardinal Bank branches into seven UBVA branches, and is considering consolidating two additional branches. Please provide clarification as to the number and location of branches to be consolidated or closed following the merger."
 
  We'll have more on this.

January 2, 2017

After Inner City Press / Fair Finance Watch requested TIAA's withheld fair lending exhibits under FOIA, the Fed between Christmas and New Years emailed a document - with the entire fair plan redacted...

December 26, 2016

This is UNacceptable:

December 22, 2016
 
Mr. Matthew R. Lee
Inner City Press / Fair Finance Watch

Re:       Freedom of Information Act Request No. F-2017-0058
 
Dear Mr. Lee,
 
This will acknowledge receipt of your electronic message dated December 10, 2016, and received by the Board's Freedom of Information Office on December 12, in which you request, pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, the entirety of the December 9, 2016 submission in connection with the Application by TIAA et al to acquire EverBank.
 
The Board makes every effort to fulfill requests in a timely manner; however, there may be delays in fulfilling complex requests or those that require consultation.

  The FFW-challenged application is still pending...

December 19, 2016

These are ones to watch:

Federal Reserve:

Chair: Janet L. Yellen, Term Expires February 3, 2018 (as Chair), January 31, 2024 (as Gov.)
Vice Chair: Stanley Fischer, Term Expires June 12, 2018 (as Vice Chair), January 31, 2020 (as Gov.)
Governor: Daniel K. Tarullo, Term Expires January 31, 2022
Governor: Jerome H. Powell, Term Expires January 31, 2028
Governor: Lael Brainard, Term Expires January 31, 2026
2 Governor Seats Currently Vacant

December 12, 2016

  The TIAA fight goes on - now they are trying to withhold fair lending information, which on December 10 we challeged:

or the entirety of the December 9, 2016 submission in connection with the Application by TIAA et al to acquire EverBank. As provided under the FRB's ex parte rules, the submission refers to “confidential” portions the withholding of which we are challenging with this FOIA request on, for example, “consumer compliance and fair lending compliance, as well as the Resultant Institution’s Fair and Responsible Practices Program.”

December 5, 2016

After ICP Challenges TIAA-Everbank, Fed's 3d Round of Qs, CRA Included

By Matthew R. Lee

NEW YORK, November 29 -- The lack of seriousness in US bank regulation grows from the relatively smaller to the largest banks like Goldman Sachs - down to People's United Bank now trying to buy Suffolk County National Bank while barely lending to people of color in New York. 

  Then there are cross-industry proposals like TIAA's attempt to acquire Everbank of Florida, which Inner City Press / Fair Finance Watch on October 29 challenged, and attempts from overseas to buy Genworth.

The Federal Reserve has asked a third round of questions of TIAA, which we publish here in full, including one on CRA:

"In connection with the request for the Board’s prior approval pursuant to section 10(e)(1)(A)(iii) of the Home Owners’ Loan Act, as amended, 12 U.S.C. 1467a(e)(1)(A)(iii), and 12 CFR 238.11(e) by TIAA Board of Overseers, Teachers Insurance and Annuity Association of America (“TIAA”), and TCT Holdings, Inc., each of New York, New York, to acquire control of EverBank Financial Corp., a savings and loan holding company, and EverBank, a federal stock savings association, both of Jacksonville, Florida, the following information is requested. Supporting documentation should be provided as appropriate.

1. If the transaction is consummated as proposed, describe in detail any authority that the New York Department of Financial Services (“DFS”) or any other regulatory entity (apart from the Federal Reserve Board) may have to:

a. Prevent TIAA from down streaming funds or otherwise acting as a source of financial strength to a subsidiary, including a subsidiary depository institution;

b. Directly or indirectly prevent the Surviving Intermediate HoldCo (as that term is defined and used in the application) from down streaming funds or otherwise serving as a source of financial strength to the resultant subsidiary depository institution;

c. Directly or indirectly require Surviving Intermediate HoldCo to dividend or otherwise distribute funds to TIAA; or

d. Directly or indirectly require a subsidiary depository institution to dividend or otherwise distribute funds to TIAA. For each of the scenarios described above, include a detailed discussion of the circumstances in which the regulator could exercise such authority, and include citations as appropriate.

2. Indicate any dollar amount or percentage thresholds or limitations on transactions that TIAA may conduct with a subsidiary or affiliate, including with the Surviving Intermediate HoldCo, without prior approval of DFS, and provide any statutory or regulatory authority that addresses this limitation.

3. To the extent not previously disclosed in the application, and to the extent known with respect to EverBank, discuss any pending or recently resolved litigation with or investigations by regulators, including, but not limited to, those pertaining to consumer protection laws and regulations, against TIAA-CREF Trust Company, FSB (“TIAA FSB”) or EverBank.

4. Clarify the extent to which the consumer compliance, fair lending compliance, and Community Reinvestment Act programs of the resultant depository institution will consist of the current programs of TIAA FSB or EverBank. Discuss any aspects of these programs that differ from those currently in place at TIAA FSB or EverBank."

Earlier, some of TIAA's answers were provided to Inner City Press on November 10 and are published here (here and embedded below in full)

"We are grateful for this opportunity to respond to the comment letter filed by Inner City Press  /Fair Finance Watch on 29 October 2016 (the “Comment Letter”), regarding the application submitted by TCT Holdings, Inc., Teachers Insurance and Annuity Association of America (“TIAA”)... The Comment Letter makes a series of assertions regarding the lending practices of TIAA-CREF Trust Company, FSB (“TIAA FSB”) and EverBank by referencing certain Home Mortgage Disclosure Act (“HMDA”) data for 2015. It also suggests that TIAA does not satisfy the requisite managerial standards consistent with approval. Finally, the Comment Letter requests an extension of the public comment period and a public hearing on the Application...

EverBank has advised the Applicants that it has carefully evaluated and investigated the allegations and it has provided the Applicants with information following its manual review of each of the eight declined applications underlying the data cited in the Comment Letter...

The commenter also suggests that allegations in a dated news article that TIAA has engaged in improper business practices in Brazil should be considered by the Federal Reserve Board as a factor when considering the managerial resources of the Applicants. The news article cited in the Comment Letter does not provide a complete or accurate portrayal of how TIAA conducts business in Brazil and other markets... TIAA is a signatory to the U.N. Principles for Responsible Investment."

  Ah, the United Nations... We'll have more on this.

November 28, 2016

Inner City Press has just filed: "This is a FOIA request for the entirety of the November 22, 2016 submission in connection with the Application by TIAA et al to acquire EverBank. As provided under the FRB's ex parte rules, the submission refers to “confidential” exhibits the withholding of which we are challenging with this FOIA request for, for example, “Please see Confidential Exhibit 7 for an explanation of the uncommitted $300 million credit line;” “the Resultant Institution will continue to satisfy the QTL test under prong (iv), as demonstrated in Confidential Exhibit 2;”" etc...

November 21, 2016

Of BOK, the Fed said last week of ICP's comment, " a commenter objected to the proposal on the basis of alleged disparities in the number of residential real estate loans made to minority borrowers, as compared to white borrowers, by BOK Bank in the Kansas City, Missouri-Kansas, Metropolitan Statistical Area (“Kansas City MSA”); the Houston, Texas, MSA (“Houston MSA”); and the Phoenix, Arizona, MSA (“Phoenix MSA”), as reflected in data reported under the Home Mortgage Disclosure Act (“HMDA”) for 2014.25 The
commenter further alleged that BOK Bank confined African American and Hispanic borrowers to government loan programs instead of conventional loan products in the
Kansas City MSA. Also, the commenter criticized the rate at which BOK Bank denied applications by African Americans and/or Hispanics, compared to the rate of denials for
whites, for home refinance loans in the Houston and Phoenix MSAs, as reported under HMDA for 2014. In addition, the commenter generally alleged that BOK Bank has a
weak record of lending to people of color and low-income individuals and a weak record of consumer compliance."

And we maintain that - and note the Fed accepting that "On September 9, 2016, the Securities and Exchange Commission (“SEC”) announced that it had settled charges against BOK regarding allegations that BOK Bank’s Corporate Trust Department, primarily through a senior executive, concealed problems and red flags from investors in certain bond offerings for which BOK Bank served as indenture trustee and dissemination agent between 2007 and 2015. See BOK Bank, SEC Order Instituting Cease-and-Desist Proceedings, File No. 3-17533 (September 9, 2016)"

November 14, 2016

After ICP Challenges TIAA-Everbank, Defense of Lending, Land Grabs

By Matthew R. Lee

NEW YORK, November 10 -- The lack of seriousness in US bank regulation grows from the relatively smaller to the largest banks like Goldman Sachs - down to People's United Bank now trying to buy Suffolk County National Bank while barely lending to people of color in New York. 

  Then there are cross-industry proposals like TIAA's attempt to acquire Everbank of Florida, which Inner City Press / Fair Finance Watch on October 29 challenged, and attempts from overseas to buy Genworth.

The Federal Reserve has asked questions of TIAA, some of whose answers were provided to Inner City Press on November 10 and are published here (here and embedded below in full)

"We are grateful for this opportunity to respond to the comment letter filed by Inner City Press  /Fair Finance Watch on 29 October 2016 (the “Comment Letter”), regarding the application submitted by TCT Holdings, Inc., Teachers Insurance and Annuity Association of America (“TIAA”)... The Comment Letter makes a series of assertions regarding the lending practices of TIAA-CREF Trust Company, FSB (“TIAA FSB”) and EverBank by referencing certain Home Mortgage Disclosure Act (“HMDA”) data for 2015. It also suggests that TIAA does not satisfy the requisite managerial standards consistent with approval. Finally, the Comment Letter requests an extension of the public comment period and a public hearing on the Application...

EverBank has advised the Applicants that it has carefully evaluated and investigated the allegations and it has provided the Applicants with information following its manual review of each of the eight declined applications underlying the data cited in the Comment Letter...

The commenter also suggests that allegations in a dated news article that TIAA has engaged in improper business practices in Brazil should be considered by the Federal Reserve Board as a factor when considering the managerial resources of the Applicants. The news article cited in the Comment Letter does not provide a complete or accurate portrayal of how TIAA conducts business in Brazil and other markets... TIAA is a signatory to the U.N. Principles for Responsible Investment."

  Ah, the United Nations... We'll have more on this.

After ICP Challenges TIAA-Everbank, Here's TIAA's Defense to Federal Reserve of Lending Disparities, Land G... by Matthew Russell Lee on Scribd

November 7, 2016

After ICP Challenges People's United Bank's Suffolk Bid, Fed Asks 13 More Questions

By Matthew R. Lee

NEW YORK, October 31 -- The lack of seriousness in US bank regulation grows from the relatively smaller to the largest banks like Goldman Sachs - down to People's United Bank now trying to buy Suffolk County National Bank while barely lending to people of color in New York.  Inner City Press / Fair Finance Watch on August 13 challenged this application and People's United, as it did Bancorp South in 2014, which led to redlining charges by the Department of Justice and Consumer Financial Protection Bureau.

Now the Federal Reserve, as released to Inner City Press on October 31, has asked People's United a series of questions, including for Community Reinvestment Act information from 2013, 2014, 2015 and 2016 year to date, it's (lack of) lending to African Americans and small businesses, its claims about  RBS Citizens Bank branches and restrictions imposed in connection with the still only proposed - and opposed - merger. We'll have more on this.

And on this: People's United Bank, if allowed to acquire Suffolk National Bank, would layoff at least 76 workers, according to a Worker Adjustment and Retraining Notification under the WARN Act, to the NYS Dep't of Labor....

October 31, 2016

Challenge to TIAA's Attempt To Buy Everbank, Citing Landgrab in Brazil

By Matthew R. Lee

NEW YORK, October 29 -- The lack of seriousness in US bank regulation grows from the relatively smaller to the largest banks like Goldman Sachs - down to People's United Bank now trying to buy Suffolk County National Bank while barely lending to people of color in New York. 

  Then there are cross-industry proposals like TIAA's attempt to acquire Everbank of Florida, which Inner City Press / Fair Finance Watch on October 29 has challenged. Inner City Press / Fair Finance Watch has written to the Federal Reserve:

On behalf of Inner City Press/Fair Finance Watch (ICP), this is a timely first comment opposing and requesting public hearings and an extension of the FRB's public comment period on the Applications of TCT Holdings Inc., Teachers Insurance and Annuity Association of America and TIAA Board of Overseers, all of New York, New York; to acquire EverBank Financial Corp and thereby indirectly acquire EverBank. This first comment is timely.

This is in essence a proposal for a major cross-industry acquisition, in which TIAA (accused among other things of land grabs in Brazil, see below), which has limited experience in banking and a limited and highly disparate record in mortgage lending, seeks to acquire the largest Florida-based bank, with its own issues. Public hearings are needed.

In the St. Louis MSA, TIAA-CREF Trust in 2015, the most recent year for which Home Mortgage Disclosure Act data is available, reported data but lent only to whites.

Meanwhile Everbank, in the Miami MSA in 2015 for home mortgage loans in HMDA Table 4-1 had a 77% denial rate for African Americans, versus a 36% denial rate for whites. In Tampa for Table 4-1 it had a 100% denial rate for African Americans. Public hearings are required.

For the record, under the Managerial Resources and integrity factors, consider this:

TIAA-CREF, U.S. Investment Giant, Accused of Land Grabs in Brazil NOV. 16, 2015

SÃO PAULO, Brazil — As an American investment giant that manages the retirement savings of millions of university administrators, public school teachers and others, TIAA-CREF prides itself on upholding socially responsible values, even celebrating its role in drafting United Nations principles for buying farmland that promote transparency, environmental sustainability and respect for land rights.

But documents show that TIAA-CREF’s forays into the Brazilian agricultural frontier may have gone in another direction.

The American financial giant and its Brazilian partners have plowed hundreds of millions of dollars into farmland deals in the cerrado, a huge region on the edge of the Amazon rain forest where wooded savannas are being razed to make way for agricultural expansion, fueling environmental concerns.

In a labyrinthine endeavor, the American financial group and its partners amassed vast new holdings of farmland despite a move by Brazil’s government in 2010 to effectively ban such large-scale deals by foreigners.”

For obvious reasons anticipating regulatory push-back against this proposal, TIAA got a clause to withdraw if too much questions are asked or restrictions proposed.

What is the public benefit? The fact that TIAA is run by a former FRB vice chairman militates even more strongly for the requested public hearings."

October 24, 2016

Lending Discrimination Kills Mergers as BancorpSouth Withdraws, ICP Proceeds on People's United

By Matthew R. Lee

NEW YORK, October 22 -- The lack of seriousness in US bank regulation grows from the relatively smaller to the largest banks like Goldman Sachs - down to People's United Bank now trying to buy Suffolk County National Bank while barely lending to people of color in New York.  Inner City Press / Fair Finance Watch on August 13 challenged this application and People's United, as it did BancorpSouth in 2014, which led to redlining charges by the Department of Justice and Consumer Financial Protection Bureau.

After BancorpSouth settled the redlining charges, Inner City Press / Fair Finance Watch immediately wrote to the Federal Reserve urging that its pending merger applications be denied or withdrawn. Now the latter has happened. The Fed has informed Inner City Press of the formal withdrawal of BancorpSouth's application; we've published the letter here, and will stay on this, to December 2017, as long as it takes.

As to People's United, using the just-released 2015 Home Mortgage Disclosure Act data. Inner City Press has now commented to the Federal Reserve:

 "in 2015 in the New York City MSA, People's United made 110 home purchase loans to whites and only ONE to an African American and only four to Latinos...  In 2015, for refinance loans in the New York City MSA, People's United made 103 loans to whites, only five to African Americans and only two to Hispanics.

   People's United record is scarcely better on Long Island, where it snapped up Bank of Smithtown and Citizen's Bank as it now proposes to do to Suffolk County National Bank. In 2015 for home purchase loans on Long Island People's United made 49 home purchase loans to whites, only four to African Americans and only four to Latinos. For refinance loans it mad 70 loans to whties, only one to an African American and only four to Latinos. Again, this is systematic redlining; this proposed acquisition could not legitimately be approved and People's United should be referred for prosecution for redlining by the Department of Justice and CFPB."

  Responding to ICP and NCRC, People's claims that acquiring another suburban bank would improve this disparate record in New York City. How?

October 17, 2016

ICP Challenges FNB's Reach into the Carolinas for Yadkin Bank, Disparities in Baltimore & Ohio, Insiders

By Matthew R. Lee

NEW YORK, October 15 -- The lack of seriousness in US bank regulation grows from the relatively smaller to the largest banks like Goldman Sachs - down to FNB / First National Bank of Pennsylvania now trying to buy Yadkin Bank in the Carolinas while barely lending to people of color in Baltimore, Cleveland or Akron.

 Inner City Press / Fair Finance Watch on October 15 challenged this application and FNB, as it did Bancorp South in 2014, which led to redlining charges by the Department of Justice and Consumer Financial Protection Bureau.

Using the just-released 2015 Home Mortgage Disclosure Act data, Inner City Press has commented to the Federal Reserve in Washington and Cleveland:

 "On behalf of Inner City Press/Fair Finance Watch (ICP), this is a timely first comment opposing and requesting an extension of the FRB's public comment period on the Application of F.N.B. Corporation to acquire Yadkin Financial and Yadkin Bank. This first comment is timely.

F.N.B. Corporation's lead bank, First National Bank of PA, has a disparate record of lending, for example in the Baltimore and Cleveland MSAs, below. Yadkin is an amalgam of banks slapped together by private equity investors, who would be the primary beneficiaries of this proposed deal. But what is the public benefit?

In the Baltimore MSA in 2015, the most recent year for which Home Mortgage Disclosure Act data is publicly available and not taken into account in any FNB CRA example, FNB made 86 home purchase loans to whites and only 3 to African Americans, only two to Latinos. This is inconsistent with the demographics of Baltimore, to put it mildly. FNB's denial rate for African Americans was 2.75 times higher than for whites; it was 3.13 times higher than for whites. This is redlining; this proposed acquisition could not legitimately be approved and FNB should be referred for prosecution for redlining by the Department of Justice and CFPB.

People's United record is scarcely better in the Cleveland MSA, another out-of-Pennsylvania market that would be a predictor of how FNB would (under) perform in the Carolinas. In the Cleveland MSA in 2015, FNB made 297 home purchase loans to whites and only 12 to Africans and only 3 to Latinos, applications from which it denied 4.13 times more frequently than whites.

In the Akron, Ohio MSA in 2015, FNB made 41 home purchase loans to whites, only one to an African American (in Table 4-1) and none to Latinos.

In this context, the comment period should be extended so that public evidentiary hearings can be held, and the application should be denied.

Please also note for the record: “Using Tuesday’s closing price on the NYSE, here’s how much more the top 10 individual backers’ stakes will be worth at close, according to FactSet Research:

Adam Abram, lead independent director: $14,298,826.15

Michael Patterson, director: $6,969,354.35

Scott Custer, CEO: $3,836,876.80

Harry Spell, board member: $3,453,074.25

Joseph Towell, chairman: $2,705,434.65

David Brody, board member: $1,645,403.35

Steven Lerner, board member: $1,311,405.15

Steven Jones, chief banking officer: $1,285,450.00

Barry Dodson, board member: $1,117,767.15

Terry Earley, CFO: $1,030,739.45

Insiders currently own about 12 percent of Yadkin, with the bulk, at 67 percent, owned by institutional investors.”

See also:

"The prominent level of private-equity ownership in the Raleigh bank had many analysts and financial experts convinced that it would be sold sooner than later, even though Yadkin just completed on March 1 its $456 million purchase of Greensboro-based NewBridge Bancorp. NewBridge went on a three-bank buying spree after securing $56 million in new private-equity capital in November 2012.

Meanwhile, Yadkin gained $45 million in private-equity capital in October 2012 and subsequently bought VantageSouth Bancshares Inc. of Raleigh and NewBridge. Those private-equity infused deals provided Yadkin with a sufficient branch coverage of North Carolina’s three urban areas to convince FNB Corp. executives to leapfrog over Virginia to make its $1.4 billion offer.

Stone Point Capital LLC, LY Holdings LLC and Lightyear Capital LLC each own 4.46 percent of Yadkin’s 50.84 million outstanding shares. Stone Point and Lightyear were provided with a representative on Yadkin’s board of directors. At $27.35 a share, the sale could be worth $61.2 million for each firm.”

This is a proposal driven by these private equity investors: but what is the public benefit?
 

October 10, 2016

After ICP Challenges Its Suffolk Bid, People's United 2015 Data Even Worse

By Matthew R. Lee

NEW YORK, October 5 -- The lack of seriousness in US bank regulation grows from the relatively smaller to the largest banks like Goldman Sachs - down to People's United Bank now trying to buy Suffolk County National Bank while barely lending to people of color in New York.  Inner City Press / Fair Finance Watch on August 13 challenged this application and People's United, as it did Bancorp South in 2014, which led to redlining charges by the Department of Justice and Consumer Financial Protection Bureau.

This is even more true upon review of the just-released 2015 Home Mortgage Disclosure Act data. Inner City Press has now commented to the Federal Reserve:

 "in 2015 in the New York City MSA, People's United made 110 home purchase loans to whites and only ONE to an African American and only four to Latinos...  In 2015, for refinance loans in the New York City MSA, People's United made 103 loans to whites, only five to African Americans and only two to Hispanics.

   People's United record is scarcely better on Long Island, where it snapped up Bank of Smithtown and Citizen's Bank as it now proposes to do to Suffolk County National Bank. In 2015 for home purchase loans on Long Island People's United made 49 home purchase loans to whites, only four to African Americans and only four to Latinos. For refinance loans it mad 70 loans to whties, only one to an African American and only four to Latinos. Again, this is systematic redlining; this proposed acquisition could not legitimately be approved and People's United should be referred for prosecution for redlining by the Department of Justice and CFPB."

  Responding to ICP and NCRC, People's claims that acquiring another suburban bank would improve this disparate record in New York City. How?
 
 And the Federal Reserve calls this "untimely"??

October 3, 2016

The Fed on September 30 said, "Of the 42 proposals withdrawn in the first half of 2016, 20 proposals were withdrawn at the initiative of the applicant. The remainder were withdrawn after consultation with staff for technical or procedural reasons or because the proposals raised significant issues regarding the statutory factors that must be considered by the Federal Reserve. Specifically, 13 of these proposals raised financial and managerial issues as well as regulatory compliance and CRA and fair lending issues."

  So what about BancorpSouth? Or a Spanish bank down the pike?The Fed on September 30 said, "Of the 42 proposals withdrawn in the first half of 2016, 20 proposals were withdrawn at the initiative of the applicant. The remainder were withdrawn after consultation with staff for technical or procedural reasons or because the proposals raised significant issues regarding the statutory factors that must be considered by the Federal Reserve. Specifically, 13 of these proposals raised financial and managerial issues as well as regulatory compliance and CRA and fair lending issues."

  So what about BancorpSouth? Or a Spanish bank down the pike?

 The Federal Reserve has responded to Inner City Press' FOIA request about BNC - but has, tellingly, redacted everything about "Enforcement Actions." We are not convinced.

September 26, 2016

And now more questions from the Fed to BNC:

"on Bank of North Carolina, Thomasville, North Carolina (“BNC Bank”), to acquire High Point Bank Corporation (“HPBC”), parent of High Point Bank and Trust Company (“High Point Bank”), both of High Point, North Carolina, pursuant to section 3(a)(5) of the Bank Holding Company Act of 1956, as amended (“BHC Act”), the following additional information, including the information in the confidential appendix, is requested. Supporting documentation should be provided as appropriate.
1. Given BNC’s rapid expansion, describe in detail BNC’s merger and acquisition processes for targeting, acquiring, and integrating acquired businesses. Include the level of board and senior management oversight and reporting, due diligence activities, audit coverage, and the involvement of risk control groups as appropriate.
2. Describe how BNC governs significant project activities and whether there is an independent oversight function that oversees project changes that occur when BNC makes an acquisition.
3. Regarding BNC’s current enterprise risk management, respond to the following:
a. Discuss the impact that the integration of Southcoast has had to BNC’s risk management framework.
b. Indicate whether risk reporting includes information regarding integration activities. If so, describe how this information could be used by senior management to allocate the necessary resources to address integration concerns, should any arise.
c. Describe how BNC’s risk management framework would change upon consummation of the proposed transaction.
4. Provide a pro forma list of shareholders who will own, control, or hold with the power to vote 5 percent or more of the voting shares of BNC upon consummation of the proposed transaction. Your response should indicate whether any identified shareholder is a bank or bank holding company. In calculating the voting ownership, include any warrants, options, and other convertible instruments, and show all levels of ownership on both a fully diluted and on an individually diluted basis. Aggregate the interests of any related shareholders."September 19, 2016

So Bank of Oklahoma, after Inner City Press' protest, was asked by the OCC in what markets it will improve. It has now named cities in six states. But will the Federal Reserve even take note of this? Watch this site.

September 12, 2016

The Fed wrote to ICP: "Please see the attached letter and non-confidential enclosure submitted to the Federal Reserve by BancorpSouth, Inc., Tupelo, Mississippi, as additional information related to its applications to acquire, through merger, Ouachita Bancshares Corporation, Monroe, Louisiana, and Central Community Corporation, Temple, Texas.  This information is being provided to you in accordance with the Federal Reserve’s policies on ex parte communications."

ICP replied: "We contest whether some of the withheld information is not subject to the ex parte rules / exempt from disclosure under FOIA" - and after being so directed, filed a FOIA request. Watch this site....

September 5, 2016

Now Bank of New Carolina has acknowledged to the Fed being below average in fair lending in, for example, Charleston - but then cites to still-withheld Compliance Plan and Supplement. This is a scam.


August 29, 2016

ICP Protested BNC - High Point, Now Fed Asks Questions, Here

By Matthew R. Lee

NEW YORK, August 24 -- The lack of seriousness in US bank regulation grows from the relatively smaller to the largest banks like Goldman Sachs - down to Bank of North Carolina (BNC), whose proposed acquisition of High Point Bank Corporation Inner City Press has challenged and the Federal Reserve has asked questions on, and BancorpSouth, which Inner City Press protested for discrimination in 2014, and has now been charged by the Department of Justice and CFPB.

On the evening of August 24, the Federal Reserve asked BNC questions about Inner City Press' protest, including:

"The public comment submitted on the proposed merger includes assertions that Home Mortgage Disclosure Act data from several metropolitan areas indicate that both BNC Bank and High Point Bank had unfavorable levels of mortgage lending to African American and Hispanic individuals as compared to white individuals.

-Directly address the assertions of unfavorable levels of mortgage lending to those population segments identified by the commenter in each relevant geographic area referenced in the comments;

-Discuss in detail the outreach and marketing activities by BNC Bank and High Point Bank, including any contemplated changes to those activities after consummation of the proposal; and

-Describe in detail the fair lending risk management policies and procedures of BNC Bank and High Point Bank, including any contemplated changes to these policies and procedures after consummation of the proposal...

 Discuss any plans to open, close, or consolidate any bank branches in connection with the proposal, or separately from the proposal, particularly in low- and moderate-income (“LMI”) areas. To the extent that any branches in LMI areas would be closed, discuss management’s plans to mitigate the impact of such closures on the affected communities."

On BNC, Inner City Press / Fair Finance Watch has raised to the Federal Reserve:

In the Charleston MSA in 2014 for conventional home purchase loans, BNC made 173 such loans to whites and only SIX to African Americans, and none to Latinos. For refinance loans, it made 68 loans to whites and only ONE to an African American, while denying the applications of African Americans 3.94 times more frequently than those of whites.

  Southcoast in the Charleston MSA in 2014 for conventional home purchase loans made 136 such loans to whites and NONE to African Americans. For refinance loans, Southcase made 35 loans to whites and only TWO to African Americans. To combine these two banks would make them worse.

  In the Greenville MSA in 2013 for home purchase loans, BNC made 117 such loans to whites and only SIX to African Americans, and only seven to Latinos.  For refinance loans, it made 31 loans to whites and only one to an African Americans and none to Latinos.

  BNC admits, as it must, that it is below-market in lending to African Americans, but paradoxically tries to use that the fact that it is subject to a compliance order as its defense to the Fed.

 To Fair Finance Watch, too. FFW asked to see, in writing, what are BNC's CRA plans going forward. BNC replied that it is "unable to share this with you. It is an internal document that is only shared with our Board of Directors and the FDIC (under the Order)."

  We'll have more on this.

August 22, 2016

How inattentive is the Fed? Well in its end of the week Form H2A listing pending application, it simply jammed five applications, not in alphabetical order, at the top. But this same Fed takes Goldman Sachs' telephone calls on Sunday, to expedite its applications...

 
August 15, 2016

Citing Redlining, ICP Challenges People's United Bid For Suffolk County National Bank

By Matthew R. Lee

NEW YORK, August 8 -- The lack of seriousness in US bank regulation grows from the relatively smaller to the largest banks like Goldman Sachs - down to People's United Bank now trying to buy Suffolk County National Bank while barely lending to people of color in New York.  Inner City Press / Fair Finance Watch has now challenged this application and People's United, as it did Bancorp South in 2014, which led to redlining charges by the Department of Justice and Consumer Financial Protection Bureau.

  Inner City Press / Fair Finance Watch has filed with the US Office of the Comptroller of the Currency:

"a timely first comment opposing and requesting an extension of the OCC's public comment period on the Application by People's United to buy The Suffolk County National Bank of Riverhead, NY. The newspaper notice says the comment period runs at least through August 16; this comment is timely.

People's United proposes to buy Suffolk County National Bank and its 27 branches in New York. But in the the New York City MSA in 2014, the most recent year for which Home Mortgage Disclosure Act data is publicly available, People's United made 82 home purchase loans to whites and NONE to African Americans or Latinos. This is redlining; this proposed acquisition could not legitimately be approved and People's United should be referred for prosecution for redlining by the Department of Justice and CFPB.

For refinance loans in the New York City MSA in 2013, People's United made 24 loans to whites, 1 to an African American and four to Hispanics. For home improvement loans in the New York City MSA in 2013, People's United made eight loans to whites, and NONE to African Americans or Latinos.

People's United record is scarcely better on Long Island, where it snapped up Bank of Smithtown and Citizen's Bank as it now proposes to do to Suffolk County National Bank. In the Nassau-Suffolk MSA in 2014, People's United made 48 home purchase loans to whites and NONE to African Americans. For home improvement loans it made 16 loans to whites and NONE to African American or Latinos.

In this context, the comment period should be extended so that public evidentiary hearings can be held, and the application should be denied."

August 8, 2016

After Taking Goldman Sachs Calls on Sunday, Fed Fines It $36M, Denies FOIA

By Matthew R. Lee

NEW YORK, August 3 -- The lack of seriousness in US bank regulation grows from the largest banks like Goldman Sachs - which gets weekend service from the Federal Reserve's top lawyer - down to the Bank of North Carolina, for which it hides the "compliance plan" that ostensibly rebuts Fair Finance Watch.

On August 3 after earlier in the year doling out an approval for Goldman Sachs on GE, the Fed announced it has

"ordered Goldman Sachs Group to pay a $36.3 million civil money penalty for its unauthorized use and disclosure of confidential supervisory information and to implement an enhanced program to ensure the proper use of confidential supervisory information. Additionally, the Board announced that it is instituting enforcement proceedings against Joseph Jiampietro, a former managing director at Goldman Sachs, seeking to impose a fine and permanently bar him from the banking industry."

 Goldman Sachs on January 14, 2016 withheld basic information from the response it was required to send to Inner City Press, see below.

But on March 21, after the Fed was notified of extensive irregularities in its processing of the Goldman Sachs - GE application, the Board hauled off and approved it, saying, in footnote 49, that

"Two commenters express concerns about GS Bank’s use of the Board’s prefiling process, suggesting that commenters could not participate in the resolution of substantive issues raised by the proposal because these issues were resolved before the filing of this application. One of these commenters withdrew its comments in full following its discussions with GS Bank.

 The Federal Reserve has established a prefiling process to provide potential applicants with information about the procedural requirements, such as timing and the applicable forms, associated with a proposal. See SR Letter 12-12. This process also helps to identify information that may be needed in connection with issues that the Board typically considers in connection with a particular type of application or notice, such as
competition or financial stability. The prefiling process is not used, and was not used in this case, to resolve or predetermine the outcome of any substantive issues. As in every case, the substantive issues involved in this case were considered and resolved as part ofthe processing of GS Bank’s formal application. In doing so, the Board considered all public comments on the proposal.

Voting for this action: Chair Yellen, Vice Chairman Fischer, and Governors Tarullo, Powell, and Brainard."

 Absurdly, when on January 22 Goldman Sachs sent Inner City Press a copy of its January 18 answer to the Fed, it withheld whole pages and exhibits.

August 1, 2016

Here is the fraud of US Community Reinvestment Act "enforcement" - detailed challenges are deemed rebutted by "Compliance Plans" a bank submits -- which are then deemed confidential in full, no reasonably segregable information, under FOIA exemption 8. This is from the FDIC this week, but concerns the Federal Reserve:

Dear Mr. Lee:
This is our final response to your July 8, 2016 Freedom of Information Act (FOIA) request for information that you described as follows:
This is a request for the Bank of North Carolina submission to the FDIC in connection with Inner City Press / Fair Finance Watch's CRA protest, referred to
(and relied on) by the Federal Reserve in this order:

"BNC further represents that BNC Bank is committed to continually improving its performance in the Greenville and Charleston MSAs and to meeting the needs of
all members of the communities. BNC notes that the commenter filed similar comments with the FDIC on an application for an unrelated acquisition, which was approved on the condition that BNC Bank develop and submit a supplement to its existing compliance plan that would strengthen the bank’s fair lending compliance program. BNC asserts that the supplement to BNC Bank’s compliance plan, which has been approved by the FDIC and implemented by the
bank, adequately addresses the concerns raised by the commenter on this proposal."

ICP's June 18, 2016 comments on Bank of North Carolina's application to acquire High Point Bank and Trust requested this plan. The FDIC extended the comment period to July 8 - but still, none of the plan has been received. Hence this formalFOIA request (and request for further extension of the BNC - High Point Bank and Trust comment period).

Our records search has been completed, and the record that you requested (Record) was located. We have determined that the Record does not contain any reasonably segregable non-exempt information. Therefore, your FOIA request is being denied.

The Record is exempt from disclosure in its entirety under FOIA Exemptions 4 and 8, 5 U.S.C. §552(b)(4) and (b)(8), and is being withheld in full. Exemption 4 permits the withholding of trade secrets, and confidential or privileged commercial or financial information obtained from a person. Exemption 8 permits the withholding of information contained in, or related to, the examination, operating, or condition reports prepared by, on behalf of, or for the use of the FDIC in its regulation or supervision of financial institutions.
This completes the processing of your request.

 We'll have more on this.

July 25, 2016

In January of this year, Inner City Press submitted a protest to the Federal Reserve to NYCB's application to acquire Astoria, see below. Now on July 20, the Fed has asked NYCB this:

"Based on staff’s review of the current record, the following additional information is requested. Supporting documentation, as appropriate, should be provided.

"In its February 13, 2016, comment on the proposal, Inner City Press/Fair Finance Watch (“ICP”) alleges that New York Community Bank’s and Astoria’s branch patterns disproportionately exclude Upper Manhattan and particularly the Bronx, which ICP states is the most predominately minority and low-income community in the state of New York. Please respond to these allegations. Please provide a copy of the public portion of your response directly to Matthew Lee of ICP. Any information for which you desire confidential treatment should be so labeled and separately bound in accordance with section 261.15 of the Board’s Rules Regarding Availability of Information"

 We'll see - is this like on a recent merger where the Fed withheld its FOIA response until the day before they approved the merger? This is a scam....

July 18, 2016

Wanna get to know you: The Federal Reserve has asked, "Please provide summaries of the existing business activities of BOK (including BOKF, National Association) and MBT (including MBT Bank). Your response should include a description of the geographic areas in which the banking organizations engage in their respective activities and the products and services that each organization currently provides. Regarding BOK, please also include details about the various banking organization acquisitions that BOK has made over the years and the subsequent consolidation of each acquired banking organization into BOKF, National Association."

July 11, 2016

The Fed has asked on Chemical - Talmer this, about branches: "demonstrate that Talmer B&T is using the branch primarily for the business of banking. Your answer should include the following, if

a. Date on which the branch was acquired or opened by Talmer B&T.

b. Explanation for the low branch occupancy percentage at the branch location

c. Description of any plans of Chemical to increase occupancy of the property

d. Description of the revenues and deposits associated with the branch relative

e. Description of any features of the branch that make it a marquee location of

f. Discussion of whether Talmer B&T’s ownership of the property housing


Branches for which information is requested:

? Boardman Financial Center, 724 Boardman-Poland Road, Boardman, Ohio

? Dublin Financial Center, 6033 Perimeter Drive, Dublin, Ohio

? Elyria – Downtown, 200 Middle Avenue, Elyria, Ohio

? Muskegon, 281 Seminole Road, Norton Shores, Michigan

? Port Huron Round, 525 Water Street, Port Huron, Michigan

? Portage, 800 East Milham, Portage, Michigan

? Ravenna Financial Center, 999 East Main Street, Ravenna Ohio"

July 4, 2016

The Fed says Bank of the Ozarks' (or BOTO's) overdraft fees don't have to be considered because the Bank says they changed them after being sued....

June 27, 2016

 After Brexit, the Fed on June 24 announced "The Federal Reserve is carefully monitoring developments in global financial markets, in cooperation with other central banks, following the results of the U.K. referendum on membership in the European Union. The Federal Reserve is prepared to provide dollar liquidity through its existing swap lines with central banks, as necessary, to address pressures in global funding markets, which could have adverse implications for the U.S. economy."

June 20, 2016

And now this: "Huntington seeks to exclude certain collateralized public funds from the competitive assessment that are booked to headquarters offices in two markets, Akron, OH and Canton, OH." Then a bunch of redactions that the Fed must rule on, it cannot require a FOIA request of the type the Fed now leaves unresponded to ...

June 13, 2016

And this from the Fed, under the ex-parte rules:

In connection with the application submitted by Huntington Bancshares Incorporated (“Huntington”), Columbus, to acquire all the voting shares of, and to merge with, FirstMerit Corporation and thereby indirectly acquire FirstMerit Bank, N.A., both of Akron, all of Ohio, pursuant to section 3 of the Bank Holding Company Act of 1956 (“BHC Act”), as amended, the following information is requested. Supporting documentation, as appropriate, should be provided. Further information may be required as staff continues its review of the proposal.

1. As provided in the Introductory Statement and Memorandum on Competitive Considerations, Huntington seeks to exclude certain public funds from the assessment of
competitive considerations in the Akron and Canton, Ohio, banking markets. For the public-fund exclusions sought in each market, provide the dollar amount of the deposits to be excluded that were deposited by public entities located in the respective markets. Show the calculations made to compute the dollar amount, and provide the data used to determine whether a public entity is located inside a banking market (e.g., depositor zip codes).

  Watch this site.

June 6, 2016

Federal Reserve Gives BNC An Approval Based on Secret Compliance Plan - and doesn't call ICP/FFW until the next day

By Matthew R. Lee

NEW YORK, June 2 -- The lack of seriousness in US bank regulation expends from the relatively smaller of mid-sized to the largest banks, with Goldman Sachs the most recent example.

  A mid-sized bank Inner City Press / Fair Finance Watch is scrutinizing, based on its records, is BNC Bancorp, seeking to acquire Southcoast Financial in South Carolina and, after that, High Point Bank & Trust.

On June 2 after a long delay, including delay in providing basic information to Inner City Press, the Federal Reserve approved the Southcoast deal. But the Fed didn't even call ICP/FFW until the next day: it's come to this. The Fed approval over said, "In this case, the Board received comments from a commenter who objects to the proposal on the basis of alleged disparities in the number of conventional home purchase loans made to African Americans and Hispanics, as compared to whites, by BNC Bank."

 Then the Fed says, "BNC further represents that BNC Bank is committed to continually improving its performance in the Greenville and Charleston MSAs and to meeting the needs of all members of the communities. BNC notes that the commenter
filed similar comments with the FDIC on an application for an unrelated acquisition, which was approved on the condition that BNC Bank develop and submit a supplement to its existing compliance plan that would strengthen the bank’s fair lending compliance program. BNC asserts that the supplement to BNC Bank’s compliance plan, which has been approved by the FDIC and implemented by the bank, adequately addresses the concerns raised by the commenter on this proposal."
 
But that's been withheld. We'll have more on this.

 On March 1 the Federal Reserve e-mailed Inner City Press a memo about a meeting it had with BNC Bank's highest executives, under the Fed's rules on Ex Parte contacts, avoiding the fair lending and Community Reinvestment Act issues which Inner City Press has raised. We are publishing the Federal Reserve memo online here.

  But as Inner City Press immediately replied, including to the Fed's Office of the Secretary, why did the Fed wait until March 1 to send a memo of a January 28, 2016 meeting -- more than a month? Does that comply with any meaningful rule on Ex Parte communications? We'll have more on this.

  There's a problem with this acquisitiveness: BNC is subject to to Compliance Order with the FDIC, which is rare, based on its fair lending record. But after Fair Finance Watch protested the deal, and the Fed told BNC to send it a copy of the bank's response, the response was provided six days later with with the entirety of the Community Reinvestment Act response withheld. See here.

Inner City Press has immediately filed a Freedom of Information Act request, and a second comment with the Fed.

May 30, 2016

  AGAIN, how can it be, that the Fed has STILL not provided the documents long ago requested under FOIA about Huntington - FirstMerit? Things are getting worse and worse...

May 23, 2016

  How can it be, that the Fed has STILL not provided the documents long ago requested under FOIA about Huntington - FirstMerit? Things are getting worse...

May 16, 2016

  Last week Inner City Press asked an economist from UN DESA about the likelihood of a Fed rate hike in June, here: https://youtu.be/HjmZSDhHjF4

May 9, 2016

The Fed on Republic ruled that Inner City Press / Fair Finance Watch "contends that Republic Bank’s past tax refund anticipation loan product is an example of problems with Republic Bank’s lending record....

 Through partnerships with tax preparers and tax software preparation companies, Republic Bank offered tax refund anticipation loans whereby the bank extended tax
refund advances to taxpayers shortly after they filed their tax returns. The advances were secured by the taxpayers’ refunds. In response to safety and soundness and consumer
compliance concerns raised by the FDIC regarding this tax refund anticipation loan product offered by Republic Bank, the product was discontinued in 2012 pursuant to an
agreement between the FDIC and Republic Bank. Republic Bank recently launched a new product that offers advances of taxpayers’ refunds; however, as discussed in more
detail below, Republic represents that the new product has significantly different terms and protections that address the FDIC’s concerns regarding the prior product."

We'll have more on this...

May 2, 2016

Inner City Press / Fair Finance Watch has asked the Fed this:

"We note that the FRB of Chicago, until Reserve Banks in New York, Philadelphia, Cleveland, Richmond and Atlanta, does not list an email address for comments - this should be acted on and improved."

April 25, 2016

ICP Awaits Fed's FOIA Response on Huntington - FirstMerit, May 16 New Date

By Matthew R. Lee

NEW YORK, April 22 -- The lack of seriousness in US bank regulation grows from the relatively smaller to the largest banks, more Fed-favored banks like Goldman Sachs - through those in the upper bulge like Huntington, seeking to buy First Merit and close more than 100 branches.

 Inner City Press / Fair Finance Watch on March 19 filed with the Federal Reserve a challenge to Huntington's application to acquire First Merit and close 107 branches. On April 16, Inner City Press made a third filing, for an extension of the comment period.

  On April 22, a week after Inner City Press' request but a day after Huntington CEO Steve Steinour downplayed the branch closures to his shareholders, the Federal Reserve called Inner City Press and said the comment period will now run to May 16. Later this was put online.

 While appreciated, will this help keep branches open? We'll see - for now, the Fed has extended its time to respond to Inner City Press' long pending Freedom of Information Act request:

April 18, 2016
 
Mr. Matthew R. Lee
Inner City Press
PO Box 20047
New York, NY 10017
 
Re:       Freedom of Information Act Request No. F-2016-0152
 
Dear Mr. Lee,
 
On March 21, 2016, the Board of Governors (“Board”) received your electronic message dated March 20, pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552... Pursuant to section (a)(6)(B)(i) of the FOIA, we are extending the period for our response until May 2, 2016, 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 May 2, 2016, we will respond to you promptly.  It is our policy to process FOIA requests as quickly as possible while ensuring that we disclose the requested information to the fullest extent of the law.
 
  So the documents should come in before May 16. Watch this site.

April 18, 2016

Inner City Press has filed: This is a timely third comment opposing, reiterating ICP's March 20 FOIA request on, and requesting an extension of the FRB's public comment period on the Application by Huntington Bancshares to acquire FirstMerit Corporation.

  The Board has STILL not responded to ICP's FOIA request and the comment period must be extended on that ground alone.
 
   This proposed merger would, if approved, result in the closure or “consolidation,” see below, of more than 100 branches -- nearly 50 are in the Cleveland, Akron and Canton areas. Huntington's lending in two of these areas was analyzed in ICP's first comment; FirstMerit is initially reviewed here. More will follow. These closures and “consolidations” would cause harm; what would be the countervailing public benefit? Public hearings are needed.

In its most recently submission, Huntington states that “the Board published notice of the Application in the Federal Register on March 17, 2016, inviting the public to comment on the Application through April 15, 2016.  Therefore, the current comment period on the Application is 36 days and it remains open to provide interested members of the public and ample time to comment on the Application.”
 
  Inner City Press is informed that Huntington has represented that it will not oppose, in fact will support, an extension of the comment period. Yet it is 4:50 pm on April 15 and nothing has been announced. Therefore this submission, requesting an extension of the comment period.
April 11, 2016

  So 107 prospective branch closures by Huntington, and not only no Fed public hearing - no extension of the comment period to consider this near-unprecedented level of closure? Pathetic...

April 4, 2016

 Goldman Sachs ultimately on March 21 obtained Federal Reserve approval to buy $16 billion in insured deposits from GE Capital, and the Fed, documents  released to Inner City Press under the Freedom of Information Act (FOIA) show, is inappropriately bent on helping, including by closing its comment period...  The Federal Reserve has belatedly responded to Inner City Press / Fair Finance Watch's September 2 FOIA request, with some of its internal documents, many heavily redacted. FOIA letter here; FOIA documents released to ICP here, and embedded below.

 On April 2, Inner City Press submitted a timely request for reconsideration: