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From a Fed approval order last week : "The HHI in this market would increase by 261 points, from 1604 to 1865."
Synovus Financial Corporation
General Counsel & Secretary
1111 Bay Avenue, Suite 500
Columbus, Georgia 31901
Dear Mr. Kamensky:
This refers to the application by (1) Synovus Financial Corp., Columbus, Georgia to acquire
FCB Financial Holdings, Inc. and thereby acquire Florida Community Bank, N.A., both of
Weston, Florida (Bank), pursuant to section 3(a)(3) and 3(a)(5) of the Bank Holding Company
Act; and (2) Synovus Bank, Columbus, Georgia to merge with Bank, pursuant to section 18(c) of
the Federal Deposit Insurance Act. Enclosed is a copy of a letter received from Fair Finance
Watch and Inner City Press commenting on the application.
Neither the Bank Holding Company Act nor the Board's Regulation Y requires a response from
Applicant. However, if you wish to respond, your comments should be received by this Reserve
Bank within eight business days from the date of this letter.
Jean Nellie Liang of Illinois, to be a Member of the Board of Governors of the Federal Reserve System for the remainder of a 14-year term expiring January 31, 2024. Ms. Liang is a Senior Fellow in Economic Studies at the Brookings Institution and a Visiting Scholar at the International Monetary Fund’s Monetary and Capital Markets Department. Previously, Ms. Liang served as Director of the Division of Financial Stability at the Board of Governors of the Federal Reserve System. Ms. Liang is a member of the Congressional Budget Office’s Panel of Economic Advisors and was a lecturer at the Yale School of Management. She earned her B.A. in economics from the University of Notre Dame and Ph.D. from the University of Maryland.
She wrote about subprime...
September 10, 2018
From Fed Reserve Bank: If you seek any “confidential” information regarding the application under the Freedom of Information Act (“FOIA”), you must submit a request to the Board’s Freedom of Information Office.
it's why you
such as in
Exhibits D and
E in their
Fed: Dear Mr. Lee: Applications staff reviewed the exhibits designated as “confidential” by the applicant and considered these exhibits to contain nonpublic information. If you seek copies of confidential information under the Freedom of Information Act, you must submit a request to the Board’s Freedom of Information Office, as described in my earlier email.
So will the
Reserve end up
Otting gamed their
to CIT? We'll
August 27, 2018
gotten too big
-- more market
share in fewer
are some of
days, and the
to meet in
will be the
But the Fed
has allowed and
ended its "enforcement
for murderous drug
gangs. Plus ca
August 13, 2018
Aug 10: "The
The $8.6 million penalty addresses the deficient execution and notarization of certain mortgage-related affidavits prepared by a subsidiary, CitiFinancial. The improper practices occurred in 2015 and were corrected. CitiFinancial exited the mortgage servicing business in 2017.
Also on Friday, the Board announced the termination of an enforcement action from 2011 against Citigroup and CitiFinancial related to residential mortgage loan servicing. The termination of this action was based on evidence of sustainable improvements." What improvements?
August 6, 2018
August 3 the Fed
ensure compliance with U.S. law and for its operations in general, and these will be continued at Nordea Finland following the Merger.
Finland is a member of the Financial Action Task Force and subscribes to its recommendations on measures to combat money laundering and international terrorism. "
banks want to
would intentionally choose to avoid minority areas. Nonetheless, some banks treat minority
neighborhoods less favorably.
For example, redlining risk may increase because of a failure to market products or locate
branches in the minority areas in the bank’s market, or because of changes in the bank’s
business model, such as through mergers, acquisitions, or new lending patterns. The Federal
Reserve conducts a risk-focused review of potential redlining risk, consistent with the
2009 Interagency Fair Lending Examination Procedures.5
Below are the key risk factors considered by the Federal Reserve in the redlining review as
well as some practical steps controls for mitigating risk.
Community Reinvestment Act (CRA) assessment area. Federal Reserve examiners
review whether the bank’s assessment areas appear to inappropriately exclude majority
minority census tracts.
Lending record. Federal Reserve examiners review whether the bank’s record of Home
Mortgage Disclosure Act (HMDA) mortgage lending and/or CRA small business lending
shows statistically significant disparities in majority minority census tracts when compared
with similar lenders.
Branching strategy. Federal Reserve examiners review whether the bank’s strategy for
branch or loan production office locations appears to exclude majority minority census
tracts. Marketing and outreach strategy. Federal Reserve examiners review whether the
bank’s marketing and outreach strategy appears to treat majority minority census tracts
Complaints. Federal Reserve examiners review whether any complaints by consumers
or consumer advocates raise concerns that the bank treats certain geographies differently
on a prohibited basis." we'll see...
Speaking of NY
the Fed last
week ended an
- from 2009...
July 2, 2018
Reserve had to
admit that Deutsche Bank again
failed the stress
test. Now what
out the stress
Matthew R. Lee, Patreon
a 60 day
comment period on
and tailor 'Volcker
June 4, 2018
Matthew R. Lee, Audio
Matthew R. Lee, Audio
Matthew R. Lee, Patreon
Fed-speak / Fed - spun “A commenter objected to the proposal alleging that, based on data reported under the Home Mortgage Disclosure Act of 1975 (“HMDA”), Charles Schwab Bank lent only to white borrowers with incomes above 120 percent of the area median income in the Reno, Nevada, Metropolitan Statistical Area..The commenter also criticized the workplace benefit plans of Charles Schwab, noting that employees of Charles Schwab had filed a lawsuit alleging that the 401(k) plans of Charles Schwab have expensive fees and poor performance that have benefited Charles Schwab at the expense of its employees. See Severson v. Charles Schwab Corp., No. 4:17-cv-00285-CW (N.D. Cal. 2017). Charles Schwab has denied any wrongdoing. The allegations regarding the performance of 401(k) plans and fees charged by plan sponsors are matters that are reviewed under the Employee Retirement Income Security Act of 1974. See 29 U.S.C. § 1001 et seq. The allegations are currently under review in the appropriate legal forum, and action on this proposal would not interfere with the court’s ability to resolve the pending litigation. See Natcom Bancshares Inc., FRB Order No. 2017-37 at 6 n.18 (December 18, 2017); M&P Community Bancshares, Inc., 92 Federal Reserve Bulletin C156, C156 n.7 (2006).”March 19, 2018
Tthe bank with the worst record in the United States for gouging consumers with overdraft fees, Ameris, has applied to the Federal Reserve to buy Hamilton State Bancshares - which, in the Atlanta MSA in 2016 for home purchase loans received 52 applications from whites, originated 37 of those as loans, denying only 12 applications. But for African Americans for home purchase loans, Hamilton State Bank denied every single on of the five applications that, based on its disparate marketing, it received or acknowledged. This is outrageous as is Ameris' record, and mis-statements. Ameris when it applied to buy Atlantic Coast Financial Corporation, and thereby directly acquire shares of Atlantic Coast Bank, falsely stated in its application that it would continue the CRA policies of Atlantic - see response to AI question 3, incorporated herein by reference. On the current record, public evidentiary hearings are needed on Ameris' Hamilton (and Atlanic) applications....
you need in a
object to the
So new Fed
Act in the
week - as if
he were coming
in fresh, and
some time been
appeals to get
ICP Protest to
Matthew R. Lee, Patreon
US Bancorp Slapped by Federal Reserve for Money Laundering, Fee Gouger Ameris Still Silent
Matthew R. Lee
Something remains wrong with the Federal Reserve's website https://www.federalreserve.gov/apps/h2a/h2a.aspx - when searched by end of comment period, as of February 10 the most recent end is February 6. This hides applications and excludes the public. Inner City Press wrote to the Fed, without response or improvement. We'll have more on this.
After US OCC
Imposes Cap on
By Matthew R. LeeNEW YORK, February 2 – More than ten months after Wells Fargo Bank's Community Reinvestment Act rating was dropped two levels to "Needs to Improve," barring it from acquisitions, on February 2 the Federal Reserve said this: "Responding to recent and widespread consumer abuses and other compliance breakdowns by Wells Fargo, the Federal Reserve Board on Friday announced that it would restrict the growth of the firm until it sufficiently improves its governance and controls.. Until the firm makes sufficient improvements, it will be restricted from growing any larger than its total asset size as of the end of 2017." By contrast the Office of the Comptroller of the Currency has quietly said, in a footnote to a Bulletin issued on October 12, that "The OCC’s policy is not to lower a bank’s CRA composite or component rating by more than one rating level." See here, footnote 8. So when did this become the OCC's policy, after it dropped Wells by two levels? Call it a stealth sop to Wells Fargo - and seemingly a violation of the Administrative Procedures Act. We'll have more on this
Act After Fair
By Matthew R. LeeWASHINGTON, January 24 – Earlier this month Inner City Press / Fair Finance Watch filed with the Federal Reserve for evidentiary hearings on the application by Charles Schwab Corporation to set up Charles Schwab Trust Bank in Henderson, Nevada, noting that Schwab has been sued by its own employees, about 401k plans. See, e.g., Severson v. Charles Schwab Corp. , N.D. Cal., No. 3:17-cv-00285-JCS, complaint filed 1/19/17. It is also noteworthy that, Inner City Press wrote to the Fed, despite the issues there, Schwab reportedly held merger talks with SoFi earlier this year. Now the Federal Reserve has written to Schwab, on January 24, with these three questions: "Provide a summary regarding the current status of litigation in Severson v. Charles Schwab Corp., No. 4:17-cv-00285-CW (N.D. Cal. 2017). 2. Provide the “home state” of CSC as that term is defined in section 10(e)(7)(B)(iv) of
The Federal Reserve Board last week took up the application of Huron Community Bank (“Huron Bank”), the state member bank subsidiary of Huron Community Financial Services, Inc. (“Huron Financial”), both of East Tawas, Michigan, has requested the Board’s approval under section 18(c) of the Federal Deposit Insurance Act (“Bank Merger Act”)1 to acquire certain assets and assume certain liabilities of a branch of First Federal of Northern Michigan. Don't blame it on CRA...
Actions on 10
By Matthew R. LeeNEW YORK, January 12 – After the Federal Reserve let Goldman Sachs set up a bank, without any public comment, during the financial meltdown, today the Fed has announced it has fined Goldman Sachs Bank USA for violating the National Flood Insurance Act. But the fine is for only $90,000. Some wondered about this announcement - and then two minutes later, perhaps explaining, this: "The Federal Reserve Board on Friday announced the termination of enforcement actions related to residential mortgage loan servicing and foreclosure processing issued in 2011 and 2012 against 10 banking organizations: Ally Financial Inc.; Bank of America Corporation; CIT Group, Inc. (as successor to IMB HoldCo LLC); The Goldman Sachs Group, Inc.; HSBC North America Holdings, Inc.; JPMorgan Chase & Co.; Morgan Stanley; The PNC Financial Services Group, Inc.; SunTrust Banks, Inc.; and U.S. Bancorp." Wag the dog. In the battle for the US Consumer Financial Protection Bureau, on January 10 US District Judge Timothy Kelly ruled that Leandra English lacks a likelihood of success on the merits in removing Mick Mulvaney as acting director. Meanwhile Mulvaney is putting under “strictest review” the CFPB's fund to compensate victims of fraud. And fraud is more and more pervasive. Last week Inner City Press / Fair Finance Watch filed with the Federal Reserve for evidentiary hearings on the application by Charles Schwab Corporation to set up Charles Schwab Trust Bank in Henderson, Nevada. It has been reported that this bank would “focus on Schwab’s workplace benefit plan clients, such as employers who offer 401k plans, and the intermediaries who serve them.” But Schwab has been sued by its own employees, about 401k plans. See, e.g., Severson v. Charles Schwab Corp. , N.D. Cal., No. 3:17-cv-00285-JCS, complaint filed 1/19/17 ). Schwab “larded” its own 401(k) plan with expensive and poorly performing investment funds and services that earned fees for the company at the expense of workers’ retirement savings, according to the new lawsuit, filed Jan. 19. The lawsuit also targets the performance of Schwab’s stable value fund and claims that Schwab executives allowed the plan’s trustee to profit from the unallocated plan assets it held. It is also noteworthy that, Inner City Press wrote to the Fed, despite the issues there, Schwab reportedly held merger talks with SoFi earlier this year. Fair Finance Watch has also reviewed, in Nevada, Charles Schwab Bank's lending in the Reno MSA. For home purchase loans, all of the loans were to whites (none to Latinos or African Americans), all to applicants over 120% of MSA median income. The same is true of refinance lending. On the current record, these applications should not be approved." We'll have more on this.
Something to watch: "The