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March 9, 2026

Burke & Hebert Challenged on Bid for LINKBANK Now FRB 3d AI Letter on CRE

by Matthew Russell Lee, Patreon Book Substack

Federal Court, March 3 – As banks rush to merge given rubberstamping signals from US regulators, LinkBank has done too far with Burke & Herbert.   Back in 2023 Fair Finance Watch got the FDIC to impose a Community Reinvestment Act condition on LINKBANK, here.

 Now with no indication of compliance, LINKBANK proposes to sell itself to also-disparate Burke & Hubert.   FFW on December 22 filed challenges with the Federal Reserve Board and FDIC. FRB version:

 Dear Chairman Powell, Secretary Misback:   This concerns the proposal by Burke & Herbert to acquire LINKBANCORP and LINKBANK.  

 This is opposition at the earliest possible time. In light of a recent proposal in which only the OCC is considering a multi-billion merger, we are submitting this to the FRB as soon as possible. Please immediate inform FFW if Burke & Herbert is applying to the FRS, and consider this comment on any and all Burke & Herbert applications. 

  FFW previously raised disparities of LINKBANK to the FDIC - resulting on a CRA condition being opposed on October 3, 2023.  It is imperative that compliance be reviewed, including at the requested public evidentiary hearing. Given recent developments, there is no reason to believe that the FDIC would or will enforce even its own conditions.     

Burke & Herbert in Virginia in 2024 made 83 mortgage loans to whites, and only SEVEN to African Americans. Meanwhile it denied two applications from African Americans, and only four from whites.   This is disparate.  

     Burke & Herbert in West Virginia in 2024 made 165 mortgage loans to whites, and only TWO to African Americans. Meanwhile it denied one application from an African Americans, and only 29 from whites.

    Burke & Herbert in Maryland in 2024 made 18 mortgage loans to whites, and only TWO to African Americans.  

  Now Burke & Herbert wants to buy LINKBANK, on which FFW had a CRA condition imposed. The FDIC wrote:  CRA Protest In the course of reviewing public input on the application, the FDIC received an adverse comment from a protester that was considered a CRA protest... the FDIC decided to approve the application with the following condition.

On January 7, the FRS wrote back: "The Federal Reserve Bank of Richmond received your correspondence on  December 23, 2025, regarding a future application by Burke & Herbert Financial Services Corporation (“B&H”) to acquire LINKBANCORP (“LINK”). The Federal Reserve has not yet received an application by B&H to acquire LINK. Accordingly, no immediate action will be taken on the correspondence dated December 23, 2025. If a filing is received in the next three months, your comment may be considered as part of the application record for the filing."

MAY be considered?

On February 25 the Fed asked 10 more questions, including on fair lending, letter on Patreon here

On March 3, the Fed asked 7 multi-part questions, including "Following the proposed transaction, CRE levels would continue to exceed the threshold for enhanced monitoring noted in SR 07-1. Accordingly, discuss whether and, if so, how the oversight of the loan portfolio, including concentration risk management practices and management's responsiveness to changing market conditions, would be enhanced. 5. Discuss the number of LINKBANK employees that B&H Bank would retain following the proposed transaction (aside from Messrs. Andrew Samual, Carl Lundblad, and Brent Smith)" - full letter on Patreon here

  Watch this site.

***

March 2, 2026

Home BancShares Tennessee Proposal Opposed by FFW St Louis Fed Asks of CRA Since 2023

by Matthew Russell Lee, Patreon Book Substack

FEDERAL COURT, Feb 25 – Home BancShares, whose Centennial Bank has a disparate lending record in all five states it it is, including an office in New York, as applied to the Federal Reserve to buy a bank in Tennessee, Mountain Commerce.

  Fair Finance Watch has opposed it, in comments filed January 19 with the Federal Reserve Bank of St. Louis and the Federal Reserve Board which recently allowed a $7 billion mega-merger to proceed with no Fed review. From the comment:

 Fair Finance Watch has been monitoring Home BancShares and its Centennial Bank and finds that in Arkansas in 2024 Centennial made 870 mortgage loans to whites while denying only 242 applications from whites, while making only 64 loans to African Americans and denying fully 48 applications from African Americans.    This is disparate - and note Centennial's significant decrease in loans to African Americans in Arkansas, from 113 loans to African Americans in 2020 to only 64 in 2024. Now they want to go into Tennessee - FFW is filing opposition and requesting hearings. 

  Likewise in Florida in 2024 Centennial made 406 mortgage loans to whites while denying only 146 applications from whites, while making only 23 loans to African Americans and denying fully 27 applications from African Americans - that is, more than its loans to African Americans. This is extremely disparate - this application should be denied. 

 In Alabama in 2024 Centennial made 20 mortgage loans to whites while denying only 11 applications from whites, while making only ONE loan to an African American - extremely disparate. 

  In Texas in 2024 Centennial made 477 mortgage loans to whites while denying only 151 applications from whites, while making only 14 loans to African Americans and denying fully 12 applications from African Americans. This again is extremely disparate; the proposal should be denied to prevent these patterns from being imposed on Tennessee. 

   There are extensive consumer complaints against Home's Centennial Bank. Since the Federal Reserve Board now appears dismissive of complaint based on the platform on which they appear, here for the record is a sample complaint from the CFPB site...

On January 20 the St. Louis Fed's Senior Manager  Mergers & Acquisitions emailed FFW: "Receipt confirmed."

Home BancShares responses emphasized that FFW (and Inner City Press) are "domiciled" in New York. And?

On Feb 25 the Fed asked Home BancShares, in its second AI letter, "by March 9, 2026.        Provide a discussion regarding Centennial Bank’s efforts to serve the convenience and needs of the communities within the bank’s assessment areas since the April 3, 2023 Community Reinvestment Act evaluation.    Confirm whether Bancshares plans to apply its risk-management policies, procedures, and controls at the combined organization following the transaction."

   Watch this site.

***

February 23, 2023

Fulton Financial Disparities Raised on $243M Deal Bank Dismissive Now FRB Rubberstamps

by Matthew Russell Lee, Patreon Book Substack

SDNY/SOUTH BRONX, Feb 19 – As US bank regulators loosen rules - including the FDIC moving to eliminate public comment altogether on branch expansion applications - now more big banks are moving to get bigger.

  So on December 8 Fair Finance Watch filed with the Federal Reserve and the Office of the Comptroller of the Currency - in advance - against Fulton Financial's newest merger proposal, under the Community Reinvestment Act. The Fed directed Fulton to make its branch closing plans public, as it did with Fifth Third - but on the day the comment period is set to expire, Fulton refused.

Immediate FOIA request and comment:

   Now at 4:41 pm on the day the comment period is set to expire, Fulton refused to comply with the FRS' request it make its branch closing thoughts public, as the FRB Cleveland made Fifth Third on Comerica do.     Weimmediately filed a FOIA request.

On January 30 Fulton Bank - or tellingly only its outside counsel Dimitri Nionakis of Holland & Knight - filed a short and dismissive response, not addressing the specific branch closing issues raised nor the consumer complaints.

   FFW noted that Fulton had a seat on the FRB of Philadelphia's board, and FOIA-ed what safeguards are in place. Still no documents, but on January 20 the FRBP wrote to FFW:

"the Chairman and Chief Executive Officer of FFC and Fulton Bank, N.A., Lancaster, Pennsylvania, serves on this Reserve Bank’s board of directors. As stated in the Application Acknowledgement Letter sent to FFC and in the Reserve Bank’s letter acknowledging the comment you submitted on December 8, 2025, the Board of Governors of the Federal Reserve System (“Board”) is processing the above-noted Application and is considering your comment dated December 8, 2025, in reviewing that Application." Then an enigmatic, "No further action will be taken with respect to your email received by the Board on January 12, 2026." Including by the Board?

  Later on January 20 Inner City Press submitted its third timely comment, noting with support another comment. With branch closings still withheld, and conflicts unresolved, the comment period must be extended. Watch this site.

     Fulton Bank NA in Delaware in 2024 made 199 mortgage loans to whites, and only 24 to African Americans. Meanwhile it denied five applications from African Americans, and only 68 from whites.     This is disparate.    

      Fulton Bank NA in Pennsylvania in 2024 made 2381 mortgage loans to whites, and only 181 to African Americans. Meanwhile it denied 111 applications from African Americans, and only 616 from whites.   

On January 15, the Fed told Fulton to make it branch closing plans public." But they haven't been.

And on February 19, the Fed rubber-stamped the deal, reciting that FFW "objected to the proposal, alleging that, in 2024, Fulton Bank made fewer home loans to African American individuals as compared to white individuals in Delaware, Maryland, New Jersey, Pennsylvania, and Virginia. 26 The commenter also alleged that Fulton Bank denied home loan applications of African American individuals at a higher rate than those of white individuals in Maryland, New Jersey, Pennsylvania, and Virginia. 27 Additionally, the commenter stated that Fulton Bank has closed many branches between August 1, 2024, and December 8, 2025, and alleged that Fulton Bank would close branches in New Jersey following the acquisition of Blue Foundry Bank. 28 ... Fulton has not made any final decisions to close or consolidate branches in
connection with the proposal." Yeah.

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

***

February 16, 2026

Stock Yards Bank Bid on Field & Main Opposed by Fair Finance Watch to FDIC & Conflicted Fed

by Matthew Russell Lee, Patreon Book Substack

FEDERAL COURT, Feb 13 –   How automatic do banks now think merger approvals are? Stock Yards Bancorp announced a proposal to buy Field & Main bank and its holding company - but has yet to apply to the Federal Reserve.

 This while Stocks Yards' CEO is on a board of directors of the Federal Reserve Bank of St Louis.

On February 13 Fair Finance Watch filed challenges to the deal with the FDIC - and with the Federal Reserve, opposing any waiver:

Dear Regional Director Bottone  and others at the FDIC:    This is a timely first comment opposing and requesting an extension of the FDIC's public comment period on the Application by Stock Yards Bank & Trust Company to acquire Field & Main Bank. The application is on the FDIC's website where a public comment period running through April 3, 2026 . These comment, and supplements to come, are timely.        Fair Finance Watch, which has commented to the FDIC that its proposal to eliminate public notice of branch applications violates the CRA, noting the FDIC's rationale that it receives few public comments, hereby timely informs the FDIC that is troubled by Stock Yards Bank & Trust's lending record and is requesting public hearings and denial of this application.    In 2024 in Kentucky, from which Stock Yards is ostensibly regulated, Stock Yards made only 60 loans to African Americans while denying  46 applications from African Americans. By contrast in Kentucky in 2024 Stock Yards made 1,424 loans to whites while denying only 515.    This comparison is striking. This application must be denied.    In 2024 in Ohio Stock Yards made only 13 loans to African Americans while denying three applications from African Americans. By contrast in Ohio in 2024 Stock Yards made 53 loans to whites while denying only six.    In 2024 in Indiana Stock Yards made only 27 loans to African Americans while denying seven applications from African Americans. By contrast in Indiana in 2024 Stock Yards made 209 loans to whites while denying only 59.    This comparison is striking. This application must be denied

The same data has been sent to the Federal Reserve, along with this:

Dear Chairman Powell, others:  This is a timely first comment opposing the Proposal of Stock Yards Bancorp Inc. to acquire Field & Main Bancorp, Field & Main Bank and affiliates - no waiver should be given to this holding company buying holding company proposal, esp given Stock Yards' CEO being named by the Reserve Bank to its Louisville branch Board of Directors:  James A. Hillebrand Chairman and Chief Executive Officer Stock Yards Bank & Trust Louisville, Kentucky 2028  (here)

      We are writing in at this time, the first day the proposal showed up on the FDIC website without being on the Fed's H2A, to oppose any waiver by the FRB of St Louis, including given its conflict of interest. That Reserve Bank named Stock Yards' CEO to the board of its Louisville branch - the Reserve Bank cannot be viewed as impartially granting approvals or waivers to Stock Yards bank.    Shockingly, in response to Inner City Press' FOIA request, the Fed has said it has not record of reviewing or imposing any safeguards on such conflicts of interesting, including for example SVB having been on the FRB of SF board when it failed.     This must go to the Board.

***

February 9, 2026

Appeal of UBS Holding Co Approval by Federal Reserve Bank Is Shown to Governors None Act

by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX/SDNY, Feb 5 – Amid the FDIC's bid to eliminate public notice of and public comment on branch applications, UBS -- Union Bank of Switzerland -- is moving to convert to a national bank in the US and become a bank holding company.

Despite a November 11, 2025 formal challenge by Fair Finance Watch, Fed approval was doled out on January 26, 2026 - by the Federal Reserve Bank of New York. On February 5 FFW was told its appeal was shown to the Governors, none of whom did anything, see below.

This while the Fed has yet to provide documents on Inner City Press' FOIA request for any safeguards the Fed has given that it allows - puts - banks on the boards of directors of its Reserve Bank, which now dole out approvals to banks.

The blatant and costly conflict of interest on Silicon Valley Bank, on the FRBSF's board, was one thing - still not addressed. Now the massive UBS. FFW immediate submitted, to the Board and the FRBNY's Keith Goodwin, a request for Board review citing UBS impending appearance on Capitol Hill. 

FFW filed for Board review, and on January 28 the FRBNY wrote to UBS, "On January 26, 2026, the commenter filed a petition for review with the Secretary of the Board. Acting under delegated authority, this letter is to advise that Applicants should not consummate the proposal until specifically authorized by the Reserve Bank or by the Board. The Board expects to decide whether to review the Reserve Bank’s delegated action within 10 calendar days of the date of the delegated action, i.e., on or before February 5, 2026, and will notify you of that action."

  On November 11 Fair Finance Watch filed opposition to the Federal Reserve Board and to the Office of the Comptroller of the Currency:

See, e.g., Sept 10, 2025: https://www.americanbanker.com/opinion/the-fdic-is-undercutting-a-key-element-of-the-cra  

 But now the Federal regulator(s) blithely propose(s) to eliminate public notice and public comment on banks' proposals to expand - and the Fed doles out approvals through conflicted Reserve Banks. The above-quoted reasoning is that few comments are filed. So, that is now changing.

***

February 2, 2026

Federal Reserve Says No Records on Conflicts Despite Silicon Valley Bank on FRBSF Board

by Matthew Russell Lee, Patreon Book Substack

FEDERAL COURT, Jan 28 – The Federal Reserve Board, currently proclaiming its independence, claims it has no records at all about considering or trying to address the conflict of interest of having banks on the boards of directors of its Federal Reserve Banks.

 This despite the obvious conflict and controversy of having had Silicon Valley Bank on the board of the FRBSF. Inner City Press on January 28 filed this FOIA appeal:

On behalf of Fair Finance Watch and Inner City Press and in my personal capacity, this is an immediate FOIA appeal of the Board's January 28 denial of our January 12 FOIA request for Fulton Financial's branch closing answer to the AI request they put it in a public exhibit - precisely the type of information made public after FOIA request in Fifth Third - Comerica, after an identical request, and a directly challenge, to be presented to the Governors, to the Denial's statement that

"With respect to item 2 of your request, staff searched Board records but did not locate any documents responsive to this portion of your request. Therefore, we are unable to provide you with any responsive information."    Item 2 was "[2] all records reflecting FRS including FRB of Philadelphia considering of possible conflicts of interesting [sic] in having Fulton’s CEO on the FRB of Philadelphia’s Board of Directors while the FRB of Philadelphia considers Fulton’s merger applications including deciding how to treat adverse comments and whether to sent [sic] copies of AI letters and allow withholding of answers to AI letters. The request, for context, includes FRS consideration of bank and bank holding company respresention [sic] on the boards of the other Reserve Banks."  

The item / request obviously includes Reserve Banks beyond FRB of Philadelphia.   Inner City Press understands from sources that the FRS has internally sought to address criticism of having had Silicon Valley Bank on the board of the FRBSF, and SVB's subsequent failure.   To say there are no record is not credible - this appeal must be presented directly to the Governors.

   On December 29, OceanFirst, which settled charges of redlining earlier this decade, announced it will apply to buy Flushing Bank in New York.  OceanFirst was on the board of the FRB of Philadelphia.

  Fair Finance Watch has opposed it, in comments filed January 2 with the Federal Reserve Board which recently allowed a $7 billion mega-merger to proceed with no Fed review. OceanFirst's record should preclude this. and this proposed deal. 

  In 2024 OceanFirst made 1399 loans to whites - and only 94 to African Americans. In Connecticut, for example, it made loans only to whites, none to African Americans.  

 In Pennsylvania its ratio of loans to whites to loans to African Americans was 4.5 to 1. In New York, it was 7 to 1.

This proposal is being opposed along with the OCC's moves to exclude the public, and to withhold documents under FOIA from Inner City Press and others until comment periods close.

On January 7 the Federal Reserve replied: "The Federal Reserve Bank of Phiadelphia received your correspondence on January 2, 2026, regarding a future application by OceanFirst to acquire Flushing Bank. The Federal Reserve has not yet received an application by OceanFirst to acquire Flushing Bank. Accordingly, no immediate action will be taken on the correspondence dated January 2, 2026. If a filing is received in the next three months, your comment may be considered as part of the application record for the filing."

MAY be considered? Watch this site.

***

January 26, 2026

Stephen Calk Convicted of Manafort Loans in 2021 Now Applies to Fed So Challenged

By Matthew Russell Lee, Patreon Podcast 2 3 5

SDNY COURTHOUSE, Jan 23 – After months of preliminaries, the trial of Stephen Calk for conspiracy to trade his bank's loans to Paul Manafort for the Secretary of the Army position began. Inner City Press live tweeted, here, previous coverage here,  podcast here

 After mere hours, the jury found him guilty. Inner City Press verdict tweet here; in front of 40 Foley Square, Calk refused questions (including on his bank and desire of UN Ambassador position) and was whisked off in a black car. Video here. Sentencing was set. Podcast here.

Jump cut to January 2026 when this appeared on the Federal Reserve's website:

"The Stephen M. Calk 2025 Trust, Houston, Texas;    to become a savings and loan holding company by acquiring National Bancorp Holdings, Inc., and thereby indirectly acquiring The Federal Savings Bank, both of Chicago, Illinois.    10    Chicago"

  Can a convicted felon be part of the ownership structure of an FDIC insured bank? Does it being a trust change anything?

  The Federal Reserve Bank of Chicago does not list an email address to request information or copies of applications. They should just be put on the Internet, Fair Finance Watch and Inner City Press suggested - and emailed 4 af FRBChi

  Days later, a portion of the application was provided. Surprised, FFW filed this:

This is a first timely comment opposing the application by The Stephen M. Calk 2025 Trust...

  Stephen Calk was indicted for, and in July 2021 was convicted of financial institution bribery and conspiracy to commit financial institution bribery. In the understanding of many, the conviction - or even before, given the evidence - would have led to an order of prohibition.  

 But after waiting some time for a copy of the "public' portion of the application, we learn of a September 2023 letter from the Federal Reserve Bank of Chicago to Mr. Calk, with heavy redactions - and now in 2026 this application, which we are opposing.     For the record, this FOIA request has been submitted through the Fed's FOIA portal: 

"This is a FOIA request for all withheld portions of the pending application by the Stephen M. Calk Trust re The Federal Savings Bank -  given the Mr. Calk was convicted of financial institution bribery and conspiracy to commit financial institution bribery in July 2021, the redactions to page 2 of the FRB of Chicago's September 5, 2023 letter to Calk are inappropriate, as are the other redactions to and withholdings from the regulations.     Given the irregularities here - including a felon being allowed to retain ownership since July 2021 of a financial institution, and being considering to continue ownership through a trustee who is already on the board of directors of another bank, Customers Bank, this is also a FOIA request for all FRS records concerning Mr. Calk and The Federal Savings Bank since May 2019 when the case resulting in the felony conviction was indicted by the grand jury.  Response should be expedited as the application's comment period is set to expire on February 9."

    We will comment more once the needed documents are provided. 

 Also, for the record,  Fair Finance Watch has been monitoring The Federal Saving Bank and finds that in 2025 in Illinois it made 759 mortgage loans to whites while denying only 86 applications from whites, while making only 98 loans to African Americans and denying fully 27 applications from African Americans.    This is disparate.

In New York State in 2024, The Federal Savings bank made 332 mortgage loans to whites while denying only 62 applications from whites, while making only 154 loans to African Americans and denying fully 19 applications from African Americans.    

Nationwide in 2024 The Federal Savings Bank made 4285 mortgage loans to whites while denying only 760 applications from whites, while making only 934 loans to African Americans and denying fully 239 applications from African Americans.  This is disparate.   

Finally, for now, while not conceding that this belated trusteeship structure would comply with the law and good policy, the proposed trustee is listed on the board of directors of another bank, Consumers Bank - we will have more on this when the documents, requested the day after the FRB of Chicago belatedly provided us the public portion of the application, are provided.  

Federal Reserve Banks Have on Board Bankers Seeking Merger Approvals now FOIA Expedited