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June
15, 2026
As
Peoples
Bancorp Tries
Buy Kentucky
Bank It Blows
Off Locals
Opposing It So
FFW Writes
by
Matthew Russell Lee, Patreon Book
Substack
FEDERAL COURT,
June 12 – Peoples Bancorp of Ohio proposes to
expand into Kentucky by buying Citizens Bank
there - then dumping its securities business to
game the system and stay under the $10 billion
line and away from the defanged CPFB.
Fair Finance Watch, after the Federal Reserve
refused to act to ensure public access to Home
Mortgage Disclosure Act data, has
commented to the Fed on the 2024 HMDA data of
Peoples - and on the scam - and now, on
Peoples Bancorp's contempt for local
communities:
Dear
Chairman Warsh, Secretary
Misback:
This
is early opposition to the application of
Peoples Bancorp Inc. of Marietta, Ohio to
acquire Citizens National Corporation, and
thereby indirectly acquire Citizens Bank of
Kentucky, Inc., both of Paintsville,
Kentucky.
What
is most striking about this proposed
acquisition, and calls for inquiry, hearing and
denial, is the gaming of the system. The
proposed acquisition would take Peoples over $10
billion - to avoid that, and fly under the
radar, Peoples proposes to buy Citizens and then
immediately sell off its securities portfolio
and more.
It's
like consciousness of guilty - what is People's
so afraid of? The CFPB?
Seemingly
relatedly, Fair Finance Watch hereby entered
into the record, at the earliest time, Peoples
Bank's disparate records of lending in its home
state, Ohio.
In 2024 in Ohio, People's Bank (LEI
I70W3N0Z6KOX8FYIH023) made fully 981 mortgage
loans to whites, while denying only 272 -
meanwhile it made only 28 loans to African
Americans, while denying fully
14.
Evidentiary hearings are needed on this
application. There are consumer complaints, but
the FRB has declared that even CFPB database
complaints, no matter the volume, are not
"substantive." We disagree - and ask for a
hearing on these issues as well.
And
on these - beyond Chair Warsh, it would seem
that Governor Bowman should take a close listen
to, for example
Sharon
Collins, who worked at and is a shareholder in
the target bank: "I am totally against this
merger approved by the board . As a stockholder
I am making my voice known. Every person in my
community that I hear from is not pleased. Help
us stop this unwanted merger in our community.
Help the voice of the community be heard."
Angela
Johnson: ""Citizens is not in any kind of
financial trouble, so it makes no sense. As a
shareholder of Citizens, I was not informed of
this decision beforehand and have still not been
permitted to vote on it. It is very
disheartening to learn about this decision
second hand and on social media."
Antitrust
- Deborah Ferguson wrote, "customers will not
have abundant amounts of choices when it comes
to a bank because People’s bank will be too
abundant in these areas. As a member of this
area I wish you would please consider not
letting this merger go through."
On
June 8 the FRB of Cleveland provide a portion of
the application - but withholding even Peoples
current and "prospective" list of shareholders.
Inner City Press immediately appealed, citing
inter alia its FOIA lawsuit against the Fed on
Enova, 26-cv-4556 (SDNY).
Meanwhile,
more protests against the application:
W.C.
Rice, from the email address Casey Jones: "Some
years back 2018 or in that area people's bank
came into our small town buying a local bank
"First Commonwealth" . I had accounts there. I
kept them for a while after the merge of First
Commonwealth but eventually decided I really
just wanted to bank local and not with an out of
state financial institution from ohio. So i
decided to just close them out and keep my
anchor accounts in the local bank, Citizens. Now
I learn People's bank is now buying out/ merging
yet with another hometown bank in my community
ultimately forcing me to bank with them or
switch out to find banking services with someone
else. Then I see the ad in the local paper last
week with the information for federal reserve.
Unfortunately there was a typo in and I had a
returned email as undeliverable which i caught
by accident and looked into it so im guessing
you may have had several more emails had they
not put a hyphen in the email address."
[Note:
the Fed has been known to reject public comments
as purported spam - and has not come forward
with any fix or safeguard as Fair Finance Watch
requested]
Johnna
Sloan: " I am a concerned citizen of
Paintsville, Kentucky. I recently learned that
People's Bank was acquiring Citizens Bank of
Kentucky. This has me worried for our small
town. Citizens Bank of Kentucky is a staple in
our town and has been since the early 1900's
when it began as Citizens National Bank. I was
blessed to have worked for Citizens Bank for 15
years. I very much enjoyed my job as a teller.
We worked hard to maintain a personal connection
with our customers. We prioritized taking time
to speak with our customers as friends and not
just as a number. We took the time to get to
know them, to ask how their families were doing.
And , we sincerely cared how they were doing!!
We celebrate the Johnson County Apple Festival
the 1st Friday and Saturday in October each
year. This festival all Started over 50 years
ago when Mr Elmond Davis, an officer of the
bank, allowed local farmers to bring their
apples into town and sell them in the street in
front of Citizens National Bank ( That's what
the bank name was at that time) This act of
kindness to the farmers resulted in the making
of our town "Apple Festival that takes place the
1st weekend each October every year. This merger
would devastate our community!! Jobs are scarce
right now!! I ask you to please help our people
to keep their jobs by allowing this merger to
not be allowed."
Anthony
Daniel: "I'm writing as a concern citizen of
paintsville kentucky to block Peoples Bank for
acquiring Citizens National Corp., This will
have a negative effect on the town as well as
cost major job loss in a already poor area. We
have the right to have community based bank that
has been in this town for 116 years . If you
drive 20 mins up the road in prestonsburg Ky
people's bank will have 3 locations within a
mile radius . In paintsville this means people's
bank will have multiple locations with mins from
apart which isn't right."
Are
Governor Bowman, and new chair Kevin Warsh,
listening to this? Fair Finance Watch has
written in again:
On
June 11, 2026, Peoples Bancorp filed a response
to the public comment letters with the Federal
Reserve Bank of Cleveland. Its letter runs four
pages. The 2024 HMDA data is dismissed as
"narrow" and "misrepresentative," without any
counter-analysis.
More
striking: Peoples does not address a single
community member by name. Sharon Collins, who
wrote that every person in her community is
opposed. Johnna Sloan, the 15-year Citizens Bank
teller who fears for her job and her town.
Anthony Daniel, who noted that Peoples already
has three locations within a mile radius in
Prestonsburg and doesn't need more. W.C. Rice,
who was forced to bank with Peoples after it
bought another local bank in 2018 and is now
watching it happen again.
None
of them merited a sentence in Peoples' response.
What Peoples did address: its Forbes ranking.
Its employee benefits package. Its 4,000 CRA
volunteer hours. Its eleven consecutive years of
dividend increases. These are the things Peoples
chose to put before the Federal Reserve as its
answer to a community saying: please don't take
our bank. Fair Finance Watch has filed a
detailed reply to the Federal Reserve, noting
what Peoples said — and what it didn't.
More
on X for Subscribers here
and Substack here
Your support means a
lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus
material on our Patreon page. Click
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June 8,
2026
Fed FOIA Denials for Predatory Enova
Application Trigger Lawsuit by Inner City Press in SDNY
SOUTH
BRONX/SDNY, June 1 – The
Federal Reserve and OCC are entertaining
applications by Enova, the parent of high cost
lender CashNetUSA, to acquire Grasshopper
Bank, already deeply engaged in AI banking.
Inner City
Press requested documents including the Federal
Reserve's communications with Enova, under
the Freedom of Information Act. The
Fed denied the request, then on Inner
City Press' appeal provided
entirely redacted pages
and a denial, which said if you
don't agree, you can sue.
Among with the
denial, the Fed sent
Inner City Press
entirely redacted pages
from its Additional
Information letter to
Enova, which we put on
our DocumentCloud here
Inner City Press
has now
filed a FOIA lawsuit
against the Fed for
its communications
with Enova - copy of
complaint,
which went live on
PACER on June 1, on
now
on
CourtListener,
here.
The Fed has 30
days to answer.
More on X for Subscribers here and Substack here
Your support means a lot. As little as $5
a month helps keep us going and grants you access to exclusive
bonus material on our Patreon page.
Click here to
become a patron.
June 1,
2026
Revolut
flying under
the radar? The
Fed has asked
their law
firm: May 29,
2026 Mr. C.
Andrew Gerlach
Partner
Sullivan and
Cromwell 125
Broad Street
New York, NY
10004
Dear
Mr. Gerlach:
This refers to
the
applications
filed by
Revolut Group
Holdings Ltd.,
London, United
Kingdom, and
Revolut
Holdings US
Inc., New
York, New
York, to
become bank
holding
companies,
pursuant to
Section
3(a)(1) of the
Bank Holding
Company Act,
in connection
with the
Interagency
Chart
er and
Federal
Deposit
Insurance
Application to
establish and
operate
Revolut Bank
US, N.A.,
Stamford,
Connecticut.
Please provide
a complete,
detailed
response to
the following
additional
information
item.
Supporting
documentation
should be
provided, as
appropriate.
1. Provide
Interagency
Biographical
and Financial
Reports for
Martin Gilbert
and Bruce
Wallace.
Please provide
your response
within eight
business days
of the date of
this letter.
Any
information
for which
confidential
treatment is
desired should
be so labeled
and separately
bound in
accordance
with Section
261.17 of the
Board of
Governor’s
Rules
Regarding
Availability
of
Information.
As previously
communicated,
copies of the
public
portions of
any response
should be
provided to
the relevant
agencies and
commenter
Matthew R.
Lee, Esq.,
Fair Finance
Watch
May
25, 2026
Green
Dot Predatory
Practices
Covered Up by
CommerceOne
Redacted
Answers So
FOIA
by
Matthew Russell Lee, Patreon Book
Substack
SOUTH
BRONX/SDNY,
May 17 – Green Dot Bank,
the subject of extensive
consumer complaints, proposes
to split itself with its bank
going with CommerceOne
and its fintech business to
(related) Smith
Ventures. Fair Finance
Watch has filed opposition to
the Federal Reserve.
"This is early opposition to the application of
Compass Sub Northwest, Inc., Birmingham, Alabama
"and others" to become a bank holding company by
acquiring Green Dot Corporation, and thereby
indirectly acquiring Green Dot Bank, both of
Provo, Utah "and more." ... CommerceOne is a
HMDA reporter - and lending only to whites, not
to any African American...
There are extensive consumer complaints against
the applicant(s) here; the FRB has taken the
problematic position that even the CFPB
complaint database is not "substantive." FFW
objects, and requests a hearing.
Ten
days later, Sullivan & Cromwell submitted an
entirely dismissive response, to which FFW
immediately replied, with 2025 HMDA data and
more - including S&C being slammed for
misusing AI in court.
And
on May 7, the Fed asked CommerceOne / Compass
Sub North questions, including "Describe
specific actions New CommerceOne would take to
strengthen and enhance Green Dot Bank’s
complaints management program and to reduce the
number of customer complaints the bank receives.
Describe any new systems, additional staffing,
and new operations New CommerceOne would
implement at Green Dot Bank to strengthen and
enhance its complaints management program. 6.
Provide a detailed timeline New CommerceOne
would expect Green Dot Bank to address each of
the corrective actions of the Consent Order
after the acquisition" and saying, "Please provide a
copy of the public portion of your response to
the commenter, Mr. Matthew Lee."
On
Saturday, May 16 Sullivan & Cromwell sent
Inner City Press a heavily redacted answer -
information about Bill Smith removed, and any
moves to address the predatory lending consent
order. On Inner City Press' DocumentCloud here
Inner
City Press immediately email a FOIA request to
the Board, whose FOIA portal has been broken for
weeks. What is happening at the Fed? Watch this
site.
Watch this site.
***
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support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
here to become a patron.
May 18,
2026
Fed OKs
Stephen Calk
Convicted of
Manafort Loans
in 2021 To
Stay In
Banking Who Is
Next?
By
Matthew Russell Lee, Patreon Podcast 2 3 5
SDNY
COURTHOUSE, May 13 – 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 2026 - when the Fed found a way to let a
convicted felon stay in banking. Who's next:
SBF?
On
January 2026 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."
Then
on March 24 the Fed sent Inner City Press a
redacted answer. The Fed asked, "1. Confirm
whether The Stephen M Calk 2025 Trust has been
legally formed. If it has not yet been formed,
confirm when the applicant intends to complete
formation of the trust.
The
answer: "The Trust has not been legally formed;
we intend to form it promptly upon approval of
the application by the Federal Reserve Board." -
than a full paragraph redacted. Inner City Press
immediately submitted a FOIA request, receipt
confirmed.
We said: we will comment more once the needed
documents are provided.
While the Fed has continued to withhold, now
Stephen Calk's brother John has opposed the
application, and also complains of the Fed's
FOIA performance. Watch this site.
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.
The
application should not be approved.
But
it was, on May 13, 2026, with the Fed saying "
The Board received a comment alleging that Mr.
Calk may not be eligible to be a controlling
shareholder of a financial institution due to
his criminal conviction. See Department of
Justice, Bank CEO Stephen M. Calk Sentenced To
One Year And One Day For Corruptly Soliciting A
Presidential Administration Position In Exchange
For Approving $16 Million In Loans (Feb.
7, 2022). As noted above, the purpose of the
proposed transaction is to facilitate Mr. Calk’s
compliance with the prohibitions of section 19
of the Federal Deposit Insurance Act, and the
proposal would not result in Mr. Calk being a
controlling shareholder of a financial
institution. This commenter also noted that the
proposed trustee of the Trust is on the board of
directors of another banking organization.
However, the proposed trustee’s service would
not be prohibited by the Depository Institution
Management Interlocks Act, the Board’s
Regulation L, or subpart J of the Board’s
Regulation LL." The rules mean nothing: felons
in banking.
Meanwhile
throughout May 2026 the Fed's FOIA portal has
been broken, an endless loop when one signs in
to try to get what documents they release - and
no answer to an email to the Fed.
On
February 7, 2022 Calk was sentenced to a year
and a day - but got bail pending appeal.
Two
years later, with Calk still not in prison, on
February 22, 2024 his lawyers wrote in. Letter
on Patreon here.
On
March 4, Judge Schofield denied Calk's motion,
and set a surrender date: "ORDERED that
Defendant shall surrender for service of
sentence at the institution designated by the
Bureau of Prisons by 2:00 P.M. on April 18,
2024.
On
December 2, 2025 Calk's counsel wrote in asking
to eliminate the last year of supervised
release, saying the US Attorney has no
objection.
And
on December 9, it was granted: "as to Stephen M.
Calk, Application Granted. Defendant Calk's term
of supervision is terminated effective
today.(Signed by Judge Lorna G. Schofield on
12/9/2025)."
The case is
US v. Calk, 19-cr-366 (Schofield)
May 11,
2026
Northfield
Protest Fed
Calls CFPB Non
Substantive
by
Matthew Russell Lee, Patreon Book
Substack
SOUTH
BRONX/SDNY,
May 8 – Columbia Financial proposes to expand
into New York by taking over Northfield Bancorp.
Fair Finance Watch, while the Federal Reserve
refuses to act to ensure public access to Home
Mortgage Disclosure Act data, has
commented to the Fed on the 2024 HMDA data of
both institutions:
"Dear
Chairman Powell, Secretary Misback:
This is early opposition to the application of
Columbia Financial, Inc.to acquire Northfield
Bancorp and Northfield Bank, Staten Island, New
York. Today the application was filed / notice
posted on the FRB's website.
In New York in 2024 Columbia made four mortgage
loans to whites while denying one - with nothing
at all to / for African
Americans.
Northfield Bank in New York in 2024 made only 10
loans to African Americans, while denying fully
21 application (it made 93 loans to whites,
denying 146).
In New Jersey in
2024 Columbia made 612 loans
to whites with 164 denial, but
only 82 to African Americans,
with 18 denials.
FFW expressed concerns about /
to Northfield in 2020 - see, here
An
evidentiary hearing is
needed.
There are consumer complaints against these two
banks, but the FRB has taken the position that
even the CFPB complaint database is not
"substantive." FFW objects, and requests a
hearing."
On
April 1, Columbia's outside counsel purported to
respond, bragging that Columbia CEO "Thomas J.
Kemly is on the Board of Directors of the
Federal Home Loan Bank of New York" and stating
that "Northfield Bank finds the comment
unsupportable."
Then,
in a new low, Columbia Financial redacted -
blacks out - its purported response. A FOIA
request has been filed.
On
April 10 the Fed asked Columbia more questions,
filing on Patreon here
On
April 15, Columbia's lawyers sent along a copy
of their answers - with nearly all answers
confined to a "confidential" volume we have now
requested under FOIA, filing on Patreon here
The
Fed rubber-stamped the deal on May 8, stating
among other things that "The data cited by the
commenter corresponds to publicly available 2024
data reported by Northfield Bank under the HMDA.
Separately, the commenter noted consumer
complaints against both Columbia Bank and
Northfield Bank that are publicly available on
the CFPB’s website. Complaints based on
individual customer transactions generally are
not considered to be substantive comments and,
thus, generally are not considered by the Board
in its evaluation of the statutory factors
governing the transaction." CFPB not substantive
- it's what's being called the Bowmanization of
the FRB.
***
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little as $5 a month helps keep us going and grants you access
to exclusive bonus material on our Patreon page. Click here
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May 4,
2026
After
OceanFirst
Flushing
Proposal
Rubber Stamped
by Fed Fair
Finance Watch
Requests
Reconsideration
by
Matthew Russell Lee, Patreon Book
Substack
FEDERAL COURT,
April 27 – How automatic do bank
now think merger approvals are? How automatic
does the (new) Federal Reserve Board make them?
On December 29, 2025, OceanFirst, which settled
charges of redlining earlier this decade,
announced it will apply to buy Flushing Bank in
New York.
Fair Finance Watch opposed it, in comments filed
January 2 with the Federal Reserve Board which
had recently allowed a $7 billion mega-merger to
proceed with no Fed review.
After the Fed withheld all information about
Warburg Pincus' other bank holdings, and Inner
City Press appealed under FOIA, the Fed hauled
off and approved the deal. OceanFirst bragged.
Fair
Finance Watch on April 27 filed a formal request
for reconsideration under the Fed's rules,
including:
Dear
Chairman Powell, Secretary
Misback:
Fair Finance Watch hereby timely requests
reconsideration of the Board's approval of the
above-captioned proposal, despite OceanFirst's
demonstrably disparate lending history and
specifically as to the Board's treatment of the
investments by funds controlled by Warburg
Pincus LLC ("Warburg") in OceanFirst Financial
Corp. as part of the transaction. On that:
...FFW did not make a speculative or unsupported
factual claim. FFW identified a legal question —
whether Warburg's fund investments in
OceanFirst, combined with Warburg's existing
investments in other banking organizations,
triggered filing requirements under Section 3 of
the Bank Holding Company
Act. That is a legal
argument requiring Board analysis. The Board's
refusal to engage with it on substantive grounds
is itself a legal error. SR Letter 97-10
was designed to filter out anecdotal consumer
complaints and unsupported character attacks on
applicants. It was not designed to — and cannot
lawfully — exempt the Board from analyzing
whether a proposed transaction triggers
independent statutory obligations under the BHC
Act. The two are categorically
different. It is an antitrust
issue, and the Board's dismissive approach is
telling - as is, while the Fed withheld
information about the Warburg investments in
banks from Inner City Press' FOIA requests and
appeal, the Fed calling ICP/FFW's comment "not
substantive." It is a Catch-22, intentionally
created, insulating the Fed from public
scrutiny.
Warburg Pincus is one of the largest private
equity firms in the world with an extensive
portfolio of financial services investments.
Where a private equity firm acquires a
controlling or significant interest in multiple
banking organizations simultaneously or in close
succession, the Board has an independent
obligation to assess whether the acquiring
entity has become a bank holding company
requiring registration and ongoing
supervision. The
Supreme Court recognized the competitive
significance of cross-institutional equity
holdings in United States v. Philadelphia
National Bank, 374 U.S. 321 (1963), establishing
that bank merger analysis must account for the
full competitive structure created by a
transaction — not merely the nominal parties.
While Philadelphia National Bank addressed
direct mergers, its logic applies with equal
force to situations where a single investor
acquires significant interests across competing
institutions.
FFW respectfully requests that the
Board: Reconsider the approval order
and provide a reasoned explanation of its
analysis of Warburg's aggregate holdings in
banking organizations under Section 3 of the BHC
Act and Regulation Y; Require Warburg to
submit information regarding its total equity
holdings in banking organizations and bank
holding companies, and assess whether any such
holdings independently trigger BHC Act
registration requirements; If the Board
concludes no independent filing obligation
arose, explain that conclusion with specificity
— identifying the threshold analysis applied and
Warburg's holdings relative to those thresholds;
and Reopen the comment period on the
Warburg issue to permit substantive public
comment on the information
disclosed.
Please
have this considered by each Governor, and rule,
as much before the possible closing date as
possible.
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
February 17 the Fed asked OceanFirst 17
questions, including "Discuss in
greater detail the due diligence conducted by
OceanFirst related to Flushing Bank’s Community
Reinvestment Act (“CRA”) program and how
OceanFirst will ensure compliance with Community
Reinvestment Act requirements
post-acquisition.Todd Schell of Warburg Pincus
(“WP”) needs to submit an IBFR for purposes of
processing the instant application" - filing on
Patreon here
On
March 5, the FRB of Philly, not the bank, sent
out OceanFirst's response - and it was heavily
redacted, including response on CRA. So, an
immediate FOIA request, for response /
responsive documents within the comment period.
Watch this site.
***
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support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
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April
27, 2026
After
OceanFirst
Flushing Hit
by Fair
Finance Watch
Fed Withholds
Warburg Pincus
Rubber Stamps
by
Matthew Russell Lee, Patreon Book
Substack
FEDERAL COURT,
April 24 – How automatic do bank now think
merger approvals are? On December 29,
OceanFirst, which settled charges of redlining
earlier this decade, announced it will apply to
buy Flushing Bank in New York.
Fair Finance Watch has opposed it, in comments
filed January 2 with the Office of teh
Comptroller of the Currency, and 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
February 17 the Fed asked OceanFirst 17
questions, including "Discuss in
greater detail the due diligence conducted by
OceanFirst related to Flushing Bank’s Community
Reinvestment Act (“CRA”) program and how
OceanFirst will ensure compliance with Community
Reinvestment Act requirements
post-acquisition.Todd Schell of Warburg Pincus
(“WP”) needs to submit an IBFR for purposes of
processing the instant application" - filing on
Patreon here
On
March 5, the FRB of Philly, not the bank, sent
out OceanFirst's response - and it was heavily
redacted, including response on CRA. So, an
immediate FOIA request, for response /
responsive documents within the comment period.
But
on April 24, the Board rubber stamped the
redlining deal, now dismissing comments on
Warburg Pincus while withhold info: "One of the
adverse comments the Board received on the
proposal, discussed further below, observed that
certain funds controlled by Warburg Pincus LLC
(“Warburg”), New York, New York, would make
investments in OceanFirst as part of the
proposal. The commenter asserted, without
offering support or analysis, that (i) the Board
should take into account Warburg’s involvement
in the proposal, and (ii) Warburg should be
required to file applications with the Board
under section 3 of the BHC Act in connection
with the transaction. Wholly unsubstantiated
claims generally are not considered to be
substantive comments and, thus generally are not
considered by the Board in its evaluation of the
statutory factors governing the transaction....
Regardless, the Board considered the impact of
the investments by the funds controlled by
Warburg as part of the proposed transaction when
considering the financial and managerial
resources and future prospects factors under the
BHC Act." This new "substantive" language, with
the Fed applies even to the CFPB complaint
database is called by some the "Bowmanization"
of the Fed. Sullivan & Cromwell gleefully
uses it, even as it uses AI. And so it goes...
Note: the above was written and published before
the Board's 4:45 pm phone call -- Inner City
Press answered and said it knew the script.
Strange system: the Board bounced / did not
accept comments by email, but insists on phone
call notice, hours after announcing the approval
to the market. The changes at the Fed, the
shrill language about "substantive," is a step
back. Watch this site.
***
Your
support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
here to become a patron.
April
20, 2026
As
Columbia
Financial
Brags of FHBNY
Spot in
Northfield
Protest
Withholds
Answers to Fed
Qs
by
Matthew Russell Lee, Patreon Book
Substack
SOUTH
BRONX/SDNY,
April 15 – Columbia Financial proposes to expand
into New York by taking over Northfield Bancorp.
Fair Finance Watch, while the Federal Reserve
refuses to act to ensure public access to Home
Mortgage Disclosure Act data, has
commented to the Fed on the 2024 HMDA data of
both institutions:
"Dear
Chairman Powell, Secretary Misback:
This is early
opposition to the application of Columbia
Financial, Inc.to acquire Northfield Bancorp and
Northfield Bank, Staten Island, New York. Today
the application was filed / notice posted on the
FRB's website.
On
April 1, Columbia's outside counsel purported to
respond, bragging that Columbia CEO "Thomas J.
Kemly is on the Board of Directors of the
Federal Home Loan Bank of New York" and stating
that "Northfield Bank finds the comment
unsupportable."
Then,
in a new low, Columbia Financial redacted -
blacks out - its purported response. A FOIA
request has been filed.
On
April 10 the Fed asked Columbia more questions,
filing on Patreon here
On
April 15, Columbia's lawyers sent along a copy
of their answers - with nearly all answers
confined to a "confidential" volume we have now
requested under FOIA, filing on Patreon here
***
Your
support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
here to become a patron.
April
13, 2026
Burke
& Hebert
Challenged on
Bid for
LINKBANK FRB 3
AI Letters
Rubberstamp
by
Matthew Russell Lee, Patreon Book
Substack
Federal Court,
April 10 – 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
On
April 10 the Fed rubberstamped the application:
"The commenter also noted that, in connection
with its approval of an acquisition by LINKBANK
in 2023, the FDIC placed a condition on the bank
requiring the bank to take certain specific
actions related to mortgage lending and related
activities in certain areas, particularly with
respect to African American consumers and LMI
communities." No follow up. Even when banks are
bad enough to have conditions imposed, there is
no follow up. But we will follow up. Watch this
site.
Watch this site.
April
6, 2026
Stephen
Calk Convicted
of Manafort
Loans in 2021
Applied to Fed
But His
Brother
Opposes
By
Matthew Russell Lee, Patreon Podcast 2 3 5
SDNY
COURTHOUSE, April 3 – 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."
Then
on March 24 the Fed sent Inner City Press a
redacted answer. The Fed asked, "1. Confirm
whether The Stephen M Calk 2025 Trust has been
legally formed. If it has not yet been formed,
confirm when the applicant intends to complete
formation of the trust.
The
answer: "The Trust has not been legally formed;
we intend to form it promptly upon approval of
the application by the Federal Reserve Board." -
than a full paragraph redacted. Inner City Press
immediately submitted a FOIA request, receipt
confirmed.
We said: we will comment more once the needed
documents are provided.
While the Fed has continued to withhold, now
Stephen Calk's brother John has opposed the
application, and also complains of the Fed's
FOIA performance. Watch this site.
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.
The
application should not be approved
On
February 7, 2022 Calk was sentenced to a year
and a day - but got bail pending appeal.
Two
years later, with Calk still not in prison, on
February 22, 2024 his lawyers wrote in. Letter
on Patreon here.
On
March 4, Judge Schofield denied Calk's motion,
and set a surrender date: "ORDERED that
Defendant shall surrender for service of
sentence at the institution designated by the
Bureau of Prisons by 2:00 P.M. on April 18,
2024.
On
December 2, 2025 Calk's counsel wrote in asking
to eliminate the last year of supervised
release, saying the US Attorney has no
objection.
And
on December 9, it was granted: "as to Stephen M.
Calk, Application Granted. Defendant Calk's term
of supervision is terminated effective
today.(Signed by Judge Lorna G. Schofield on
12/9/2025)."
The case is
US v. Calk, 19-cr-366 (Schofield)
March
30, 2026
Stephen
Calk Convicted
of Manafort
Loans in 2021
Applies to Fed
Now Redactions
By
Matthew Russell Lee, Patreon Podcast 2 3 5
SDNY
COURTHOUSE, March 24 – 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."
Then
on March 24 the Fed sent Inner City Press a
redacted answer. The Fed asked, "1. Confirm
whether The Stephen M Calk 2025 Trust has been
legally formed. If it has not yet been formed,
confirm when the applicant intends to complete
formation of the trust.
The
answer: "The Trust has not been legally formed;
we intend to form it promptly upon approval of
the application by the Federal Reserve Board." -
than a full paragraph redacted. Inner City Press
immediately submitted a FOIA request, receipt
confirmed.
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.
The
application should not be approved
On
February 7, 2022 Calk was sentenced to a year
and a day - but got bail pending appeal.
Two years later, with Calk still not
in prison, on February 22, 2024 his lawyers wrote
in. Letter on Patreon here.
March
23, 2026
Fed
Gives Stock
Yards Bancorp
Waiver As On
Reserve Bank
Board While
Claims No
Records
by
Matthew Russell Lee, Patreon Book
Substack
FEDERAL COURT,
March 20 – 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.
On
March 20 - more than a month later - the Fed
Secretary wrote that he was giving a waiver, and
to request any records under FOIA. But the Fed
has already told Inner City Press it HAS not
records about the very time of board interlock -
between bank and Reserve Bank - which is cites
here. Inner City Press has asked for expedited
treatment.
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 proposal must be denied
***
Your
support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
here to become a patron.
March
16, 2026
Fed OKs
Home
BancShares
Tennessee
Proposal
Opposed by FFW
Says CFPB Not
Substantive
by
Matthew Russell Lee, Patreon Book
Substack
FEDERAL COURT,
March 12 – Home BancShares, whose Centennial
Bank has a disparate lending record in all five
states it it is, including an office in New
York, applied to the Federal Reserve to buy a
bank in Tennessee, Mountain Commerce.
Fair Finance Watch opposed it, in comments filed
January 19 with the Federal Reserve Bank of St.
Louis and the Federal Reserve Board which had
recently allowed a $7 billion mega-merger to
proceed with no Fed review.
On
March 12, the Federal Reserve Board
rubber-stamped the merger. It admitted that the
HMDA data cited by FFW was accurate; it added
that "In addition, the commenter noted a
consumer complaint against Centennial Bank that
is publicly available on the CFPB’s website.
Complaints based on individual customer
transactions generally are not considered to be
substantive comments and, thus, generally are
not considered by the Board in its evaluation of
the statutory factors governing the transaction.
See 12 CFR 225.16(c)(3); SR Letter 97-10 (Apr.
24, 1997),
https://www.federalreserve.gov/boarddocs/srletters/1997/sr9710.htm."
But that was about consumers opposing a merger
based on their own transaction, not a pattern of
comments to the CFPB. The Fed denied FFW's
petition for rulemaking that it preserve HMDA
which it handed off to the under-fire CFPB. Now
the Fed dissed the CFPB complaint database as
non-substantive. What's next?
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.
***
Your
support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
here to become a patron.
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.
***
Your
support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
here to become a patron.
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.
***
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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.
***
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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.
***
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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:
Dear Chair
Powell, Comproller Gould, others
This is a timely first comment on
the applications by UBS Group AG and UBS AG, both of Zurich,
Switzerland, and UBS Americas Holding LLC and UBS Americas Inc
to become bank holding companies by acquiring UBS Bank USA, Salt
Lake City, Utah, upon the conversion of UBS Bank USA from a
state-chartered industrial bank to a national bank.
UBS, beyond its involvement in predatory subprime lending
- see, e.g., "UBS to pay $300 million to resolve US mortgage
securities cases," August 4, 2025 - has numerous other
compliance scandal on which public hearings should be held, on
this application and possible plan to relocate to the
US.
There is tax evasion and retaliation against whisteblowers:
“France: UBS fined in France for harassing whistleblowers”, 10
March 2025 The Swiss bank UBS was fined €75,000 (CHF71,410), the
maximum penalty, in Paris on Monday for moral harassment by its
French subsidiary of two whistleblowers, who had denounced the
tax evasion system organised by the bank. UBS Europe, which
absorbed the French branch, was also ordered to pay €50,000 in
damages to Nicolas Forissier, the former head of internal
auditing. However, the bank was acquitted of witness tampering
and obstructing the health, safety and working conditions
committee. According to Forissier’s lawyer, William Bourdon,
this is the first time in France that a whistleblower has
obtained a conviction against his former employer. … At the
hearing, the public prosecutor had requested a maximum fine of
€225,000 for the three offences.
There are human rights - and managerial - issues: the Society
for Threatened Peoples Switzerland (STP) filed a specific
instance against UBS Group AG (UBS) at the Swiss NCP. The
complaint concerns the bank’s financial ties with Hangzhou
Hikvision Digital Technology Co. Ltd. (Hikvision), a provider of
modern surveillance technology that has played a key role in the
mass surveillance of the Uyghurs and other Turkic minorities in
Xinjiang, China. Also involving private prisons in
the US.
(On November 25 UBS
through Sullivan & Cromwell submitted a dismissive response, stating that " FFW criticizes UBS for business
relationships with certain clients (e.g., private
prisons).
There
are managerial factor issues, particularly on an initial
application to become a US bank holding company. Fair Finance
Watch hereby timely requests hearings, and the denial of these
UBS applications.
The denial was by a conflicted Reserve Bank.
On February 5 the Fed
wrote: "You previously submitted a comment on
the Application, expressing concerns about UBS’s
managerial resources and corporate governance.
Specifically, the comment expressed
concerns regarding (1) an agreement UBS entered
into in 2025 with the U.S. Department of
Justice (“DOJ”) after acquiring the U.S.
subsidiaries of Credit Suisse Group AG (“Credit
Suisse”), wherein UBS agreed to pay Credit
Suisse’s remaining obligations in connection
with a settlement
agreement that Credit Suisse had previously
entered into with the DOJ in 2017; (2) two
prior lawsuits in France, wherein UBS was sued
by the French government for allegedly assisting
French clients in evading taxes between 2004 and
2012, and for allegedly harassing two whistleblowers
who reported this conduct;5 (3) a settlement
agreement entered into in 2015 between a
broker–dealer subsidiary of UBS, UBS Securities
LLC, and the U.S. Securities and Exchange
Commission (“SEC”), related to allegations UBS
Securities LLC’s alternative trading
system violated SEC rules regarding minimum
pricing increments;6 and (4) alleged investments
by UBS in (i) a company that provides
surveillance technology that is allegedly used
in China
and (ii) private prisons in the United States.
In acting on the Application, the Reserve Bank
found that concern number (1) was not relevant
for purposes of assessing the managerial factor
for UBS because it did not involve conduct by
UBS, concerns number (2) and number (3) did not
preclude approval for the reasons explained in
the letter addressed to you on January 26, 2026
(the “Reserve Bank’s letter”), and concern
number (4) involved matters that are outside the
scope
of the limited statutory factors that the
Federal Reserve is authorized to consider when
reviewing
an application under section 3 of the BHC Act.7
In addition, the Reserve Bank’s letter advised
that the Reserve Bank also considered concerns
number (1) through (3) with respect to the
financial resources of UBS.
In the petition for review, you assert that the
Board should not have permitted the Reserve
Bank to act on an application involving a
comment that raises substantive issues because
(1) Reserve Banks do not have delegated
authority to deny applications and (2) Reserve
Banks [See Lee v.
Bd. of Governors of the
Fed. Rsrv. Sys., 118 F.3d
905, 911 (2d Cir. 1997).
Nevertheless, in its
discretion, the Board has
reviewed your petition.]
are quasi-governmental entities with
directors who are the heads of banks and bank
holding companies.
As cited in the Reserve Bank’s letter, the
Board’s “Guidance on Protested Proposals”
SR Letter No. 97-10, part II.A.5 (April 24,
1997), provides that, in certain instances, a
Reserve
Bank may act on an application that received a
substantive adverse comment. Additionally, no
directors or officers of Applicants serve on the
board of the Reserve Bank.
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.
***
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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.
***
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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.
The application should not be
approved
Federal
Reserve Banks
Have on Board
Bankers
Seeking Merger
Approvals now
FOIA Expedited
by
Matthew Russell Lee, Patreon Book
Substack
FEDERAL COURT,
Jan 16 – Amid welcome focus on Federal Reserve
independence, from a community perspective Fair
Finance Watch and Inner City Press have raised a
different question to the Federal Reserve Board:
How
is it that Federal Reserve Banks which review
and approve banks' mergers, and decide what
questions to ask, who to send copies to and what
information can be withheld from the public,
have the very banks they regulate on their
boards of directors?
The
question arose this month on the protested
application by Fulton Financial to buy Blue
Foundry Bank. FFW filed comments with the
Federal Reserve Board on December 8, after the
proposal was announced but before the banks
applied. (FFW has adopted this new comment-early
policy in light of regulators including Fed
Governor Michelle W. Bowman saying applications
will be reviewed and approved more quickly).
It was the Federal Reserve Bank of Philadelphia
that responded, when Fulton applied on December
23. On January 7, Fulton sent FFW a
copy of its response to December 23 questions
from the Federal Reserve Bank of Philadelphia, a
copy of which was not sent to FFW on December
23, as required by the Federal Reserve's rules
against ex-parte communications.
Fulton's response sought to withhold, about
branch closings, even the timing for decision.
But in response to a recent FFW / Inner City
Press FOIA request, Fifth Third was required to
disclose the street addresses of the 80 branches
it would close if allowed to acquire
Comerica. So why did the Federal
Reserve Bank of Philadelphia not send timely
protester FFW a copy of its question or
"Additional Information" letter - and why is it
allowing Fulton to be more secretive even than
other banks?
Well, Inner City Press looked at the Board of
Directors list of the Federal Reserve Bank of
Philadelphia and finds on it "Curtis J. Myers,
President and Chief Executive Officer, Fulton
Bank and Fulton Financial Corporation,
Lancaster, Pennsylvania."
Isn't
this a conflict of interest? Or, what safeguards
have the Federal Reserve put in place?
Further cursory review by Inner City Press finds
bank representatives on the boards of directors
of all 12 of the Federal Reserve Banks, and of
their branches - including Huntington Bank,
which the Fed recently allowed to do a $7
billion merger without even applying to the Fed,
and including National Bank Holdings Corporation
(recipient of a recent merger approval), M&T
Bank (represented on two separate boards),
Stockyard Bank & Trust and many others,
including:
Peapack
Private Bank & Trust; First Financial
Bancorp Cincinnati, Ohio ;
First Horizon Bank; BankUnited, Inc.; Northern
Trust, Renasant Bank, United Community Bank;
Southern Bancorp, Inc.; Home BancShares, Inc.;
First National Bank of Omaha; National Bank of
Texas; Columbia Banking System, Inc., and Chief
Executive Officer Columbia Bank; and Cathay Bank
- again, among others.
Inner
City Press has submitted a Freedom of
Information Act request to the Board, alongside
its second timely comment opposing Fulton - Blue
Foundry, for " all records reflecting FRS
including FRB of Philadelphia considering of
possible conflicts of interesting 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 send 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 representation
on the boards of the other Reserve Banks."
On
January 16 the Fed granted expedited treatment
to the FOIA request: "I have granted your
request for expedited processing because (1) you
are primarily engaged in disseminating
information, and (2) the application you seek is
pending with the Board. Accordingly, your
request will be processed as soon as practicable
and ahead of other FOIA requests."
Watch
this site.
***
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January 19,
2026
Federal
Reserve Banks
Have on Board
Bankers
Seeking Merger
Approvals now
FOIA Expedited
by
Matthew Russell Lee, Patreon Book
Substack
FEDERAL COURT,
Jan 16 – Amid welcome focus on Federal Reserve
independence, from a community perspective Fair
Finance Watch and Inner City Press have raised a
different question to the Federal Reserve Board:
How
is it that Federal Reserve Banks which review
and approve banks' mergers, and decide what
questions to ask, who to send copies to and what
information can be withheld from the public,
have the very banks they regulate on their
boards of directors?
The
question arose this month on the protested
application by Fulton Financial to buy Blue
Foundry Bank. FFW filed comments with the
Federal Reserve Board on December 8, after the
proposal was announced but before the banks
applied. (FFW has adopted this new comment-early
policy in light of regulators including Fed
Governor Michelle W. Bowman saying applications
will be reviewed and approved more quickly).
It was the Federal Reserve Bank of Philadelphia
that responded, when Fulton applied on December
23. On January 7, Fulton sent FFW a
copy of its response to December 23 questions
from the Federal Reserve Bank of Philadelphia, a
copy of which was not sent to FFW on December
23, as required by the Federal Reserve's rules
against ex-parte communications.
Fulton's response sought to withhold, about
branch closings, even the timing for decision.
But in response to a recent FFW / Inner City
Press FOIA request, Fifth Third was required to
disclose the street addresses of the 80 branches
it would close if allowed to acquire
Comerica. So why did the Federal
Reserve Bank of Philadelphia not send timely
protester FFW a copy of its question or
"Additional Information" letter - and why is it
allowing Fulton to be more secretive even than
other banks?
Well, Inner City Press looked at the Board of
Directors list of the Federal Reserve Bank of
Philadelphia and finds on it "Curtis J. Myers,
President and Chief Executive Officer, Fulton
Bank and Fulton Financial Corporation,
Lancaster, Pennsylvania."
Isn't
this a conflict of interest? Or, what safeguards
have the Federal Reserve put in place?
Further cursory review by Inner City Press finds
bank representatives on the boards of directors
of all 12 of the Federal Reserve Banks, and of
their branches - including Huntington Bank,
which the Fed recently allowed to do a $7
billion merger without even applying to the Fed,
and including National Bank Holdings Corporation
(recipient of a recent merger approval), M&T
Bank (represented on two separate boards),
Stockyard Bank & Trust and many others,
including:
Peapack
Private Bank & Trust; First Financial
Bancorp Cincinnati, Ohio ;
First Horizon Bank; BankUnited, Inc.; Northern
Trust, Renasant Bank, United Community Bank;
Southern Bancorp, Inc.; Home BancShares, Inc.;
First National Bank of Omaha; National Bank of
Texas; Columbia Banking System, Inc., and Chief
Executive Officer Columbia Bank; and Cathay Bank
- again, among others.
Inner
City Press has submitted a Freedom of
Information Act request to the Board, alongside
its second timely comment opposing Fulton - Blue
Foundry, for " all records reflecting FRS
including FRB of Philadelphia considering of
possible conflicts of interesting 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 send 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 representation
on the boards of the other Reserve Banks."
On
January 16 the Fed granted expedited treatment
to the FOIA request: "I have granted your
request for expedited processing because (1) you
are primarily engaged in disseminating
information, and (2) the application you seek is
pending with the Board. Accordingly, your
request will be processed as soon as practicable
and ahead of other FOIA requests."
Watch
this site.
***
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January
12, 2026
The Federal
Reserve has a
new
boilerplate,
here from
Prosperity: Fair
Finance Watch
"asked the
Board to
consider three
unrelated
customer
reviews posted
on Yelp and
Reddit
regarding
different
individualized
customer
complaints.
Complaints
based on
individual
customer
transactions
generally are
not considered
to be
substantive
comments and,
thus,
generally are
not considered
by the Board
in its
evaluation of
the statutory
factors
governing the
transaction.
See 12 CFR
225.16(c)(3);
SR Letter
97-10 (Apr.
24, 1997)." So
forget
consumers.
Even if from
the CFPB?
Watch this
site.
January
5, 2026
How could
the Federal
Reserve let
through a $7
billion
without
requiring an
application? That
one does not
even seen to
be mentioned
for a waiver
in the H2A,
until this:
Cleveland
Park National
Corporation,
Newark,
Ohio—waiver of
filing
requirement
under section
3 of the Bank
Holding
Company Act to
merge with
First Citizens
Bancshares,
Inc., and
thereby
indirectly
acquire First
Citizens
National Bank
(FCNB), both
of Dyersburg,
Tennessee, in
connection
with the
merger of FCNB
with and into
Park National
Bank, Newark,
Ohio. Granted:
December 23,
2025
So
is the trick
decertifying
the target's
holding
company? As
Flagstar also
did? We'll
have more on
this.
December
29, 2025
Burke
& Hebert
Challenged on
Bid for
LINKBANK on
which FFW got
CRA Condition
by
Matthew Russell Lee, Patreon Book
Substack
Federal Court,
Dec 22 – 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.
Watch this site.
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December
22, 205
Fed
Rubber Stamped
Pinnacle
Synovus Merger
FFW Request
for
Reconsideration
Denied
by
Matthew Russell Lee, Patreon Book
Substack
NASHVILLE/NYC, Dec
17 – Synovus Bank, with a track record of
disparate lending and consumer complaints, aims
to cash out and merge with Nashville-based
Pinnacle.
But Pinnacle has its own disparities, and is
under-regulated by the Tennessee Commissioner of
Financial Institutions, who refuses to provide
any documents to anyone but Tennessee "citizens"
(not even those *in* Tennessee).
So
Fair Finance Watch filed Community Reinvestment
Act challenges with the Federal Reserve and the
Georgia regulator (both have confirmed receipt
and the Fed has sent
to Pinnacle) as well as the recalcitrant
Tennessee regulator, who refuses to give records
or even confirm receipt of the challenge.
Pinnacle has Tennessee in the palm of its hand,
lock stock and barrel, regulator and media.
And
now it has the Federal Reserve too, which on
November 25 issued a rubber stamp approval,
including that FFW "objected to the proposal,
alleging that both Synovus Bank and Pinnacle
Bank generally made proportionally fewer home
loans to African American individuals as
compared to white individuals in 2024
The
Fed Order concedes as to FFW that "The data cited by
this commenter corresponds to
publicly available 2024 data
reported by both Synovus Bank
and Pinnacle Bank under the
Home Mortgage Disclosure Act
of 1975 (“HMDA”), 12 U.S.C. §
2801 et seq." - but the Fed
doesn't care about disparities.
It continues: "This commenter also alleged that
Pinnacle Bank denied home loan applications of
African American individuals at a higher rate
than those of white individuals." But the Fed
still approved.
On
December 7, within the time set for such
requests, FFW requested reconsideration by the
Board, writing to the general counsel that,
among other things, "ten day AFTER the approval
- so, new fact that FFW could not have presented
before the approval - the FRS on Friday,
December 5 belatedly announced an enforcement
action against a Synovus universal banker for
misappropriation from customers and forgery of
documents. Why was this
enforcement action withheld or held up under
after the approval, and just before the time to
request reconsideration of it was set to
expire?"
On
December 17 the Fed sent back a letter denying
reconsideration, decision made by the General
Counsel, not the Governors. The first version of
the letter was dated in the future - December 18
- but was then resent, including to two law
firms also representing Huntington (which
avoided / evaded even applying to the Fed to buy
Cadence) and Fifth Third, with the correct date:
December 17. But why was the request and the
questions in it presented to the Governors, at
least in writing? What about FFW's petition for
rulemaking to save access to HMDA?
Watch
this site.
Back
on October 9 the Fed asked Pinnacle nine
multi-part questions, including "A copy of the
CRA policy to be used by the combined
organization or, if one is not available, a
projected timeline for completion. 4.
Discuss the combined organization’s plans to
manage third party partnership compliance risk
exposure, including, but not limited to, BHG
Financial and GreenSky, LLC. a. Include in your
discussion anticipated key leadership positions
and any individuals identified to fill them;
plans for reporting/Management" - full letter here.
From
the comment: Dear Chair Powell and others in the
FRS:
...
Fair Finance Watch has reviewed the
just-released 2024 Home Mortgage Disclosure Act
data of Synovus and finds that while it made
3.18 loans to whites for each denial to whites,
it made only 1.7 loans to African Americans for
each denial to African Americans.
Pinnacle is of even greater concern. In
Virginia, where Pinnacle received a Low
Satisfactory on the Lending Test in its most
recently (May 2023) CRA performance evaluation,
in 2024 it made 133 mortgage loans to whites,
with 19 denials, but only 13 loans to African
Americans, with fully eight denials...
This application should not be approved;
particularly in light of the disparities, public
evidentiary hearings are needed.
Watch this site.
***
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December
15, 2025
Fed
Rubber Stamps
PNC Reciting
Fair Finance
Watch Comments
But No
Rebuttal So AI
Next
by
Matthew Russell Lee, Patreon Book
Substack
FEDERAL COURTHOUSE,
Dec 11 – As PNC Bank has grown it has become
more disparate in its lending. After its CEO
Bill Demchak announced a $4.1 billion proposal
to buy FirstBank and bragged, "We just
effectively bought Colorado," Fair Finance Watch
prepared an early filing to the regulators
demanding scrutiny and hearings. While
preparing for PNC's sure to be coming next
bank-grab as PNC expands in AI and crypto, FFW
commented twice, as noted by the Fed:
"The
Board received two timely adverse comments on
the proposal, both from the same commenter.32
The commenter objected to the proposal, alleging
that, based on data reported under the Home
Mortgage Disclosure Act of 1975 (“HMDA”), 33 PNC
Bank made fewer home loans to African American
individuals as compared to white individuals
nationwide, including in Pennsylvania, Michigan,
Texas, Florida, Indiana, Maryland, New York,
Alabama, Colorado, the District of Columbia,
Illinois, Georgia, Arizona, Virginia,
California, Missouri, New Jersey, North
Carolina, Ohio, Tennessee, Delaware,
Massachusetts, Kentucky, South Carolina, and
Wisconsin in 2024. The commenter also alleged
that PNC Bank denied home loan applications of
African American individuals at a higher rate
than those of white individuals. 34 The
commenter requested that the Board consider and
hold hearings regarding a consumer complaint
submitted by an unknown customer of PNC Bank to
the Consumer Financial Protection Bureau
(“CFPB”) regarding an allegation that the
consumer’s account was frozen by the bank
without explanation, which was published on the
CFPB’s consumer complaint database (“CFPB
database”). The commenter also more generally
requested that the Board review consumer
complaints in the CFPB’s database regarding PNC
Bank."
But there is no rebuttal. Game on - as PNC
promotes crypto trading, orders staff back to
the office only to fire then for AI - and
to outsource decisions to AI. It will all be
opposed.
On
October 15 the OCC provided some responsive
documents - but withheld in full 435 pages,
while providing suborned letters from supportive
commenters who have PNC on their Board of
Directors (can you say, conflict of interest) or
who name support. OCC responsive documents in
Inner City Press' CloudDocument here.
In
state after state, PNC for African Americans has
(many) more denials than originations, while the
opposite is true for white borrows. The pattern
is striking:
In
New York, where PNC recently and unceremoniously
closed a deposit facility, PNC in 2024 denied 52
applications from African Americans while making
fewer, only 28 loans - while it made fully 289
loans to whites and denied only 252
applications. This follows the same PNC pattern
and is disparate.
In Colorado, which PNC CEO's says the bank has
now "effectively bought," PNC in 2024 denied 12
applications from African Americans while making
only 17 loans - while it made fully 422 loans to
whites and denied only 244 applications. This is
disparate.
In Arizona, where PNC lists 60 branches and now
proposes to further expand, PNC in 2024 denied
15 applications from African Americans while
making only 22 loans - while it made fully 796
loans to whites and denied only 466
applications. This is disparate.
There are more states.
Watch
this site.
***
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and grants you access to exclusive bonus material on our Patreon
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December 8,
2025
Federal
Reserve Board
Nixed Public
Comments on
Merger Now
Cleveland
Reserve Bank
Spins
by
Matthew Russell Lee, Patreon Book
Substack
SDNY/SOUTH BRONX,
Dec 5 – As US bank regulators loosen rules -
including the FDIC moving to eliminate public
comment altogether on branch expansion
applications - more big banks are moving to get
bigger.
And
now Federal Reserve is rejecting public comments
opposing mergers, here Fifth Third's already
sued Comerica proposal, citing the "reputation"
of the submitter. Inner City Press / Fair
Finance Watch wrote to the Board Secretary:
Yesterday
Fair Finance Watch emailed a timely comment
opposing Fifth Third / Comerica as we have
always done - and got back this (which I'm glad
we saw) "This is the mail system at host
www2.webmail.pair.com. I'm sorry to have
to inform you that your message could not be
delivered to one or more recipients. It's
attached below.
"federalreserve.gov:
Your access to this mail system has been
rejected due to the sending MTA's poor
reputation."
We
ask that an explanation be provided - and that
the Federal Reserve System check on this pending
application and other applications, including
going forward, that it has not rejected comments
from the public. Awaiting Fed response,
Matthew Lee, Esq., Executive Director, Fair
Finance Watch / Inner City Press
The response, days later, came not from the
Board but a Reserve Bank, that in Cleveland:
"comments can also be sent electronically to
Comments.applications@clev.frb.org.”1 In
order to ensure proper receipt of electronic
comments on an application, please use the email
address provided in the Federal Register
notice.2 As you noted in your correspondence,
based on consideration of the initial server
from which it was sent, your first email on
November 28, 2025, was flagged for spam and
other suspicious activity, and automatically
rejected by the Board’s system prior to
receipt. However, the subsequent message
that you sent to the Board’s email address on
November 29, 2025, was received, and that
message included the comment emailed on November
28, 2025."
But what about Reserve Bank
like in Kansas City that list no email address?
What of the non-public nature of the Reserve Bank?
Still no response from the Board or Governors (who
recently denied Fair Finance Watch's petition for
rulemaking to preserve public access to HMDA data.
We've refiled via the FDIC, OCC and even NCUA with
the FFIEC, what- and who ever that it...
December
1, 2025
Fed
Rubber Stamps
Pinnacle
Synovus Merger
Protested on
Community
Reinvestment
Act
by
Matthew Russell Lee, Patreon Book
Substack
NASHVILLE, Nov
25 – Synovus Bank, with a track record of
disparate lending and consumer complaints, aims
to cash out and merge with Nashville-based
Pinnacle.
But Pinnacle has its own disparities, and is
under-regulated by the Tennessee Commissioner of
Financial Institutions, who refuses to provide
any documents to anyone but Tennessee "citizens"
(not even those *in* Tennessee).
So
Fair Finance Watch filed Community Reinvestment
Act challenges with the Federal Reserve and the
Georgia regulator (both have confirmed receipt
and the Fed has sent
to Pinnacle) as well as the recalcitrant
Tennessee regulator, who refuses to give records
or even confirm receipt of the challenge.
Pinnacle has Tennessee in the palm of its hand,
lock stock and barrel, regulator and media.
And
now it has the Federal Reserve too, which on
November 25 issued a rubber stamp approval,
including that FFW "objected to the proposal,
alleging that both Synovus Bank and Pinnacle
Bank generally made proportionally fewer home
loans to African American individuals as
compared to white individuals in 2024
The
Fed Order concedes as to FFW that "The data cited by
this commenter corresponds to
publicly available 2024 data
reported by both Synovus Bank
and Pinnacle Bank under the
Home Mortgage Disclosure Act
of 1975 (“HMDA”), 12 U.S.C. §
2801 et seq." - but the Fed
doesn't care about disparities.
It continues: "This commenter also alleged that
Pinnacle Bank denied home loan applications of
African American individuals at a higher rate
than those of white individuals." But the Fed
still approved.
Back
on October 9 the Fed asked Pinnacle nine
multi-part questions, including "A copy of the
CRA policy to be used by the combined
organization or, if one is not available, a
projected timeline for completion. 4.
Discuss the combined organization’s plans to
manage third party partnership compliance risk
exposure, including, but not limited to, BHG
Financial and GreenSky, LLC. a. Include in your
discussion anticipated key leadership positions
and any individuals identified to fill them;
plans for reporting/Management" - full letter here.
From
the comment: Dear Chair Powell and others in the
FRS:
...
Fair Finance Watch has reviewed the
just-released 2024 Home Mortgage Disclosure Act
data of Synovus and finds that while it made
3.18 loans to whites for each denial to whites,
it made only 1.7 loans to African Americans for
each denial to African Americans.
Pinnacle is of even greater concern. In
Virginia, where Pinnacle received a Low
Satisfactory on the Lending Test in its most
recently (May 2023) CRA performance evaluation,
in 2024 it made 133 mortgage loans to whites,
with 19 denials, but only 13 loans to African
Americans, with fully eight denials...
This application should not be approved;
particularly in light of the disparities, public
evidentiary hearings are needed.
Watch this site.
***
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and grants you access to exclusive bonus material on our Patreon
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November
24, 2025
On
Fifth Third
Bid for
Comerica CRA
Protest Now
Fed Asks of
Branches and
Direct Express
by
Matthew Russell Lee, Patreon Book
Substack
SDNY/SOUTH BRONX,
Nov 18 – As US bank regulators loosen rules -
including the FDIC moving to eliminate public
comment altogether on branch expansion
applications - now more big banks are moving to
get bigger.
On October 6, Fifth Third announced it will
apply to buy damaged Comerica Bank. On October
8-9, it was opposed, to the Fed and OCC. On
November 10, after a contemptuous response by
Fifth Third's Kala Gibson, Fair Finance Watch
spread the fight spread to five more states.
On November 18 the Federal Reserve put 15
multi-part questions to Fifth Third, ranging
from branch closures and the Community
Reinvestment Act to potential shareholder
litigation and, at last, the Direct Express
program. Inner City Press is putting the Fed's
question letter on its DocumentCloud here,
as it will Fifth Third responses - after FOIA if
necesary, though 53 is supposed to sent them to
Fair Finance Watch.
Their
application to the Fed discloses five states
they are filing with: Michigan, Texas,
California, Florida and Arizona. On November 10
Inner City Press filed with all five.
Fair Finance Watch filed:
Fair Finance Watch has long been concerned about
Fifth Third. Fair Finance Watch has
reviewed the just-released 2024 Home Mortgage
Disclosure Act data of Fifth Third, not reviewed
in any Community Reinvestment Act performance
evaluation.
In state after state, Fifth Third for African
Americans has (many) more denials than
originations, while the opposite is true for
white borrows. The pattern is striking, starting
with two states Fifth Third and Comerica overlap
in:
In Michigan, the state Comerica abandoned for
Texas, Fifth Third in 2024 denied 249
applications from African Americans while making
fewer, only 177loans - while it made fully 4189
loans to whites and denied only 1688
applications. This is disparate [there are
more states]
***
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and grants you access to exclusive bonus material on our Patreon
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November
17, 2025
On
Fifth Third
Bid for
Comerica Media
Reruns Spin on
Huntington
Amid CRA
Protests 5
States
by
Matthew Russell Lee, Patreon Book
Substack
SDNY/SOUTH BRONX,
Nov 12 – As US bank regulators loosen rules -
including the FDIC moving to eliminate public
comment altogether on branch expansion
applications - now more big banks are moving to
get bigger.
On October 6, Fifth Third announced it will
apply to buy damaged Comerica Bank. On October
8-9, it was opposed, to the Fed and OCC. Now on
November 10, after a contemptuous response by
Fifth Third's Kala Gibson, the fight has spread
to five more states.
Meanwhile, how does today's business media work,
or not work? On November 12 a pro-business
consultancy based in Minneapolis put out a
gushing press release entitled "Fifth Third’s
Comerica Acquisition Unseats Top 10 Bank
Competitors in Small Business and Middle
Market," saying that Huntington had First
Citizens (both proposing acquisitions) have been
pushed out of the top 10. FOX 4 in Kansas City
re-ran the press release, without change,
presumably as "news," here
And so it goes - that's where Inner City Press
comes on, on this beat.
Fifth
Third's EVP of "Corporate Responsibility" Kala
Gibson wrote in urging a rubber stamp from the
Federal Reserve Bank of Cleveland, saying that
HMDA data proves nothing. He is speaking for CEO
Tim Spence, who bragged on the day of
announcement how fast he could obtain an
approval. Well let's see.
Their
application to the Fed discloses five states
they are filing with: Michigan, Texas,
California, Florida and Arizona. On November 10
Inner City Press filed with all five.
Fair Finance Watch filed:
Fair Finance Watch has long been concerned about
Fifth Third. Fair Finance Watch has
reviewed the just-released 2024 Home Mortgage
Disclosure Act data of Fifth Third, not reviewed
in any Community Reinvestment Act performance
evaluation.
In state after state, Fifth Third for African
Americans has (many) more denials than
originations, while the opposite is true for
white borrows. The pattern is striking, starting
with two states Fifth Third and Comerica overlap
in:
In Michigan, the state Comerica abandoned for
Texas, Fifth Third in 2024 denied 249
applications from African Americans while making
fewer, only 177loans - while it made fully 4189
loans to whites and denied only 1688
applications. This is disparate [there are
more states]
***
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and grants you access to exclusive bonus material on our Patreon
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November
10, 2025
As
Fifth Third
Bids to Buy
Comerica
Disparities
Raised by Fair
Finance Watch
and Tricolor
Loss
by
Matthew Russell Lee, Patreon Book
Substack
SDNY/SOUTH BRONX,
Nov 7 – As US bank regulators loosen rules -
including the FDIC moving to eliminate public
comment altogether on branch expansion
applications - now more big banks are moving to
get bigger.
On October 6, amid the pending PNC - FirstBank
and Pinnacle - Synovus proposals, Fifth Third
announced it will apply to buy damaged Comerica
Bank. Starting October 8, Fair Finance Watch
filed opposition, and Inner City Press FOIA
requests, including for the Fed's sealed
questions.
One of the damages to Comerica is
that the Treasury Department took from Comerica
its Direct Express contract - and awarded it to
Fifth Third.
Now Fifth Third has applied to the Treasury
Department's Office of the Comptroller of the
Currency to buy Comerica. Talk about picking
winners and losers.
And talking about losers, Fifth Third's
nationwide lending in 2024, the most recent year
for which data is available, was disparate:
26,121 mortgage loans to whites and only 11,566
denial to whites, versus only 1784 loans to
African Americans and even more denials:
1970. These disparities continue in Fifth
Third's other states, as Fair Finance Watch has
demonstrated. On November 7 it filed this:
In the month since Fair Finance Watch commented
to the agencies, the Federal Reserve has put
some question to Fifth Third's outside counsel
Rodgin Cohen - but has characterized them as
entirely confidential. Inner City Press
has submitted a FOIA request, and a second one
for the over-withheld
exhibits. For now, for the
record: "Fifth Third Bank faces $200M in
provisions from Tricolor ‘fraud’ - "potential
loss of millions following subprime lender
Tricolor Holdings’ bankruptcy filing.
Fifth Third faces 'nearly $200 million of
provision expense associated with the fraud at
Tricolor.'" Public hearings are
needed
Inner
City Press, which has opposed the FDIC's moves
to close itself to public scrutiny - American
Banker op-ed here
- has submitted FOIA requests on all this. The
FDIC said it will eliminate public notices
because it does not receive enough public
comments. That is changing, starting now. Watch
this site.
***
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and grants you access to exclusive bonus material on our Patreon
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November
3, 2025
Fed
Asked PNC Why
Response to
FFW Was Late
But Accepted
It on Bid for
FirstBank
by
Matthew Russell Lee, Patreon Book
Substack
FEDERAL COURTHOUSE,
Oct 28 – As PNC Bank has grown it has become
more disparate in its lending. After its CEO
Bill Demchak announced a $4.1 billion proposal
to buy FirstBank and bragged, "We just
effectively bought Colorado," Fair Finance Watch
prepared an early filing to the regulators
demanding scrutiny and hearings.
This
takes place as the regulators, led by the FDIC,
are seeking to eliminate public notice and limit
public comment. See, e.g., American Banker, Sept
10, 2025, "The FDIC is taking the 'community'
out of CRA enforcement," by Matthew R. Lee, here
On
September 13 Fair Finance Watch filed challenges
with the Federal Reserve and OCC, and Inner City
Press filed Freedom of Information Act requests,
see below.
Compare
OCC denial of expedited processing here
to FRB grant of identical request here
Inner
City Press appealed.
On
October 20 the Federal Reserve belatedly asked
PNC questions, now on Patreon here
On
October 28, the Fed provided Fair Finance Watch
with its email to PNC asking why did it did not
respond to FFW's September 18 comment within the
time granted. Instead, PNC late submitted a
breezy letter saying it "welcomed hearing from
the two commenters who expressed concerns
regarding the Proposed Transaction: Matthew Lee,
Esq. of Fair Finance Watch" then citing 15
suborned letters.
On October 15 the OCC provided some
responsive documents - but withheld in full 435
pages, while providing suborned letters from
supportive commenters who have PNC on their Board
of Directors (can you say, conflict of interest)
or who name support. OCC responsive documents in
Inner City Press' CloudDocument here.
On Fifth Third Bid for
Comerica Challenged on CRA Fed
Acknowledges Receipt But Hides
by
Matthew Russell Lee, Patreon Book
Substack
SDNY/SOUTH BRONX,
Oct 31 – As US bank regulators loosen rules -
including the FDIC moving to eliminate public
comment altogether on branch expansion
applications - now more big banks are moving to
get bigger.
On October 6, amid the pending PNC - FirstBank
and Pinnacle - Synovus proposals, Fifth Third
announced it will apply to buy damaged Comerica
Bank. On October 8-9, it was opposed, to the Fed
and OCC.
Inner City Press submitted a Freedom of
Information Act request to the Fed, the same it
has used on other mergers, always resulting in
expedited treatment.
But
on October 16, the Fed for the first time denied
expedited treatment on Fifth Third - Comerica
and Direct Express. Inner City Press appealed,
asking that the Governors answer: what changed?
The Federal Reserve explained it was because the
application has not been filed yet. Fine. On
October 30, the Fed send "Mathew Lee,
Attached is a letter from the Federal Reserve
Bank of Cleveland (the “Reserve Bank”)
acknowledging receipt of the public comment you
submitted (the “receipt letter”) regarding Fifth
Third Bancorp’s, Cincinnati, Ohio, intended
acquisition of Comerica Incorporated, Dallas,
Texas. Also attached is a letter
from this Reserve Bank to Fifth Third's retained
counsel transmitting your comment and giving the
company an opportunity to respond."
But at 4 pm on October 31, notice of the
application was still not on the Fed's website.
Inner City Press raised just this to Governor
Michelle Bowman at the FRBKC's hearing on EGRPRA
on October 30. Watch this site.
Fair Finance Watch filed:
Dear FRB Chair Powell, Comptroller Gould:
This is an early first comment on, the proposal
and applications by Fifth Third to acquire
Comerica. Beyond the lending disparities
preliminarily identified below, the US
government's Direct Express payment program was
removed from Comerica, part of its weakening,
and given to Fifth Third, which now applies to
acquire Comerica. Public hearings are needed,
and hereby required.
Fair Finance Watch has long been concerned about
Fifth Third. Fair Finance Watch has
reviewed the just-released 2024 Home Mortgage
Disclosure Act data of Fifth Third, not reviewed
in any Community Reinvestment Act performance
evaluation.
In state after state, Fifth
Third for African Americans has (many) more
denials than originations, while the opposite is
true for white borrows. The pattern is striking,
starting with two states Fifth Third and Comerica
overlap in:
October
27, 2025
Fed
Asks Questions
after PNC Bid
for FirstBank
Challenged on
CRA by Fair
Finance Watch
by
Matthew Russell Lee, Patreon Book
Substack
FEDERAL COURTHOUSE,
Oct 20 – As PNC Bank has grown it has become
more disparate in its lending. After its CEO
Bill Demchak announced a $4.1 billion proposal
to buy FirstBank and bragged, "We just
effectively bought Colorado," Fair Finance Watch
prepared an early filing to the regulators
demanding scrutiny and hearings.
This
takes place as the regulators, led by the FDIC,
are seeking to eliminate public notice and limit
public comment. See, e.g., American Banker, Sept
10, 2025, "The FDIC is taking the 'community'
out of CRA enforcement," by Matthew R. Lee, here
On
September 13 Fair Finance Watch filed challenges
with the Federal Reserve and OCC, and Inner City
Press filed Freedom of Information Act requests,
see below.
Compare
OCC denial of expedited processing here
to FRB grant of identical request here
Inner
City Press appealed.
On
October 20 the Federal Reserve belatedly asked
PNC questions, now on Patreon here
On October 15 the OCC provided some
responsive documents - but withheld in full 435
pages, while providing suborned letters from
supportive commenters who have PNC on their Board
of Directors (can you say, conflict of interest)
or who name support. OCC responsive documents in
Inner City Press' CloudDocument here.
October
20, 2025
Rare
Fed denial:
"The Federal
Reserve Board
on Friday
denied an
application by
Canandaigua
National
Corporation,
of
Canandaigua,
New York. The
firm provided
a
complementary
activity
notice to the
Board
proposing to
engage in
certain
activity that
would obligate
it to acquire
real property.
Bank holding
companies are
generally
prohibited
from investing
in real
property under
the Bank
Holding
Company Act.
After
reviewing the
proposal and
considering
all the facts
and
circumstances,
the Board has
determined
that the
proposed
activity is
inconsistent
with the
factors the
Board is
required to
evaluate by
law. The
Board's order
will be
released
following a
review for
confidential
information
related to the
firm" - this
while the Fed
for the first
time denies
the Press
expedited
treatment of
FOIA about an
announced
merger (Fifth
Third /
Comerica) - Inner
City Press
immediately
appealed and
asked that it
be presented
to all
Governors,
watch this
site. Also,
asked the
Fed to take
back over HMDA
data. No
response.
October
13, 2025
As
Pinnacle Bank
Synovus Merger
Protested Now
Fed Asks About
CRA and
GreenSky
by
Matthew Russell Lee, Patreon Book
Substack
NASHVILLE, Oct
9 – Synovus Bank, with a track record of
disparate lending and consumer complaints, now
proposes to cash out and merge with
Nashville-based Pinnacle.
But Pinnacle has its own disparities, and is
under-regulated by the Tennessee Commissioner of
Financial Institutions, who refuses to provide
any documents to anyone but Tennessee "citizens"
(not even those *in* Tennessee).
So
Fair Finance Watch filed Community Reinvestment
Act challenges with the Federal Reserve and the
Georgia regulator (both have confirmed receipt
and the Fed has sent
to Pinnacle) as well as the recalcitrant
Tennessee regulator, who refuses to give records
or even confirm receipt of the challenge.
Pinnacle for now seems to think it has Tennessee
in the palm of its hand, lock stock and barrel,
regulator and media. But then there's Inner City
Press, and other states...
On
October 9 the Fed asked Pinnacle nine multi-part
questions, including "A copy of the CRA policy
to be used by the combined organization or, if
one is not available, a projected timeline for
completion. 4. Discuss the combined
organization’s plans to manage third party
partnership compliance risk exposure, including,
but not limited to, BHG Financial and GreenSky,
LLC. a. Include in your discussion anticipated
key leadership positions and any individuals
identified to fill them; plans for
reporting/Management" - full letter here.
The
Federal Reserve, while correctly granting
expedited processing to Inner City Press' FOIA
request about Pinnacle and Synovus, on October 1
wrote to say they need yet more time: "Pursuant
to section (a)(6)(B)(i) of the FOIA, we are
extending the period for our response until
October 16, 2025, in order to consult with two
or more components of the Board having a
substantial interest in the determination of the
request." Will processing of the application be
stayed?
Dear
Chair Powell and others in the FRS:
...
Fair Finance Watch has reviewed the
just-released 2024 Home Mortgage Disclosure Act
data of Synovus and finds that while it made
3.18 loans to whites for each denial to whites,
it made only 1.7 loans to African Americans for
each denial to African Americans.
Pinnacle is of even greater concern. In
Virginia, where Pinnacle received a Low
Satisfactory on the Lending Test in its most
recently (May 2023) CRA performance evaluation,
in 2024 it made 133 mortgage loans to whites,
with 19 denials, but only 13 loans to African
Americans, with fully eight denials...
This application should not be approved;
particularly in light of the disparities, public
evidentiary hearings are needed.
Watch this site.
***
Your
support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
here to become a patron.
October
6, 2025
As
Pinnacle Bank
Synovus Merger
Protested Now
Fed Extends
Time on
Expedited FOIA
by
Matthew Russell Lee, Patreon Book
Substack
NASHVILLE, Oct
1 – Synovus Bank, with a track record of
disparate lending and consumer complaints, now
proposes to cash out and merge with
Nashville-based Pinnacle.
But Pinnacle has its own disparities, and is
under-regulated by the Tennessee Commissioner of
Financial Institutions, who refuses to provide
any documents to anyone but Tennessee "citizens"
(not even those *in* Tennessee).
So
Fair Finance Watch filed Community Reinvestment
Act challenges with the Federal Reserve and the
Georgia regulator (both have confirmed receipt
and the Fed has sent
to Pinnacle) as well as the recalcitrant
Tennessee regulator, who refuses to give records
or even confirm receipt of the challenge.
Pinnacle for now seems to think it has Tennessee
in the palm of its hand, lock stock and barrel,
regulator and media. But then there's Inner City
Press, and other states...
The
Federal Reserve, while correctly granting
expedited processing to Inner City Press' FOIA
request about Pinnacle and Synovus, on October 1
wrote to say they need yet more time: "Pursuant
to section (a)(6)(B)(i) of the FOIA, we are
extending the period for our response until
October 16, 2025, in order to consult with two
or more components of the Board having a
substantial interest in the determination of the
request." Will processing of the application be
stayed?
On
September 15 the FRB of Atlanta sent Fair
Finance Watch a list of question sent to
Pinnacle and Synovus including "an analysis of
CRA and fair lending impacts and the potential
effect on the community and customers served by
the branch, particularly distressed or
underserved nonmetropolitan middle- income
census tracts, majority-minority census tracts,
LMI census tracts, and rural areas;" and
"The Application identifies that The Vanguard
Group, Inc., BlackRock, Inc., and FMR, LLC,
would each hold more than 5 percent of the
combined organization’s common stock. Explain in
further detail why, as the Application
represents, “[n]one of these parties would
trigger any presumption of control” - full
letter on Inner City Press' DocumentCloud here
Dear
Chair Powell and others in the FRS:
...
Fair Finance Watch has long been concerned about
Synovus, as the Federal Reserve memorialized,
noting "disparities in denial rates and home
mortgage originations to African Americans
and/or Hispanics, as compared to whites, in
certain markets. The commenter also noted a
complaint filed with the CFPB against Synovus
Bank relating to collecting on a debt allegedly
not owed."
Fair Finance Watch has reviewed the
just-released 2024 Home Mortgage Disclosure Act
data of Synovus and finds that while it made
3.18 loans to whites for each denial to whites,
it made only 1.7 loans to African Americans for
each denial to African Americans.
Pinnacle is of even greater concern. In
Virginia, where Pinnacle received a Low
Satisfactory on the Lending Test in its most
recently (May 2023) CRA performance evaluation,
in 2024 it made 133 mortgage loans to whites,
with 19 denials, but only 13 loans to African
Americans, with fully eight denials.
In Alabama, where Pinnacle also received a Low
Satisfactory on the Lending Test, in 2024
Pinnacle made 106 mortgage loans to whites, with
16 denials, but only 56 loans to African
Americans, with fully nine denials.
In North Carolina, where Pinnacle also received
a Low Satisfactory on the Lending Test, in 2024
Pinnacle made 653 mortgage loans to whites, with
178 denials, but only 202 loans to African
Americans, with fully 82 denials.
Even in Tennessee, which conceals its records,
Pinnacle was rated Low Satisfactory on the
Lending Test in Knoxville and Chattanooga. Not
in the exam:
In Florida in 2024 Pinnacle made 38 mortgage
loans to whites, with 11 denials, but only five
loans to African Americans, with fully NINE
denials.
In Kentucky in 2024 Pinnacle made eleven
mortgage loans to whites, with seven denials,
but NO loans to African
Americans. This application
should not be approved; particularly in light of
the disparities, public evidentiary hearings are
needed.
Watch this site.
***
Your
support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
here to become a patron.
September
29, 2025
First
Security Bank
Protest Moves
to DC as FDIC
Moves To Cut
Notice of
Branches
by
Matthew Russell Lee, Patreon Book
Substack
SOUTH
BRONX / SDNY COURT,
Sept 24 – The Community
Reinvestment Act directs bank regulators to
consider banks' records of lending in poor
neighborhoods when they apply to expand with
mergers or, right in the statute, branches
("deposit facilities").
But
now the Federal Deposit Insurance Corporation is
quietly moving to eliminate public notice of,
and public comment on, banks' branch
applications. While Inner City Press has Freedom
of Information Act requests pending, Fair
Finance Watch on August 30 commented to the
FDIC, on the proposed change - and on sample
current branch applications pending.
On
August 21, in part to forestall the Federal
Reserve using the same twisted logic of "few
comments so let's eliminate public notice," Fair
Finance Watch filed a branch comment with the
Federal Reserve Bank of St. Louis on the pending
application by Arkansas-based First Security
Bank to open a branch at 4001 Rodney Parham Road
in Little Rock, noting that First Security Bank
in Arkansas in 2024 it made 1030 mortgage loans
to whites and denied only 120 applications, 1 to
9. For African Americans, only 17 loans and
fully 10 denials: approximately 1 to 1.7.
On September 11 First Security Bank vaguely
responded, pointing to a 2023 CRA Performance
Evaluation 1) that did not consider the 2024
HMDA data. 2) that PE states, inter alia,
Distribution on loans in non-MSA Arkansas is
"Poor" (id. at 10); on the Investment
Test in Jonesboro, Hot Springs and Fort Smith is
"Below" (id. at 13); in the same Jonesboro and
Hot Springs communities, accessibility of
delivery systems are "Below." Community
Development Services in Jonesboro, also
"Below." Fair Finance Watch
reiterated its request for hearings, and denial.
On
September 24 the Fed informed First Security
Bank that the application is being transferred
to the Board in DC and the time extended - but
only into October. Watch this site.
See
also, Inner City Press' op-ed in the American
Banker here
There
will be more.
This proposal to eliminate public notice and
comment on branch applications must be withdrawn
- or sued.
Watch
this site.
***
Your
support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
here to become a patron.
September
22, 2025
As
Pinnacle Bank
Synovus Merger
Protested Now
Fed Asks Fair
Lending and
Blackrock Qs
by
Matthew Russell Lee, Patreon Book
Substack
NASHVILLE, Sept
18 – Synovus Bank, with a track record of
disparate lending and consumer complaints, now
proposes to cash out and merge with
Nashville-based Pinnacle.
But Pinnacle has its own disparities, and is
under-regulated by the Tennessee Commissioner of
Financial Institutions, who refuses to provide
any documents to anyone but Tennessee "citizens"
(not even those *in* Tennessee).
So
Fair Finance Watch filed Community Reinvestment
Act challenges with the Federal Reserve and the
Georgia regulator (both have confirmed receipt
and the Fed has sent
to Pinnacle) as well as the recalcitrant
Tennessee regulator, who refuses to give records
or even confirm receipt of the challenge.
Pinnacle for now seems to think it has Tennessee
in the palm of its hand, lock stock and barrel,
regulator and media. But then there's Inner City
Press, and other states...
On
September 15 the FRB of Atlanta sent Fair
Finance Watch a list of question sent to
Pinnacle and Synovus including "an analysis of
CRA and fair lending impacts and the potential
effect on the community and customers served by
the branch, particularly distressed or
underserved nonmetropolitan middle- income
census tracts, majority-minority census tracts,
LMI census tracts, and rural areas;" and
"The Application identifies that The Vanguard
Group, Inc., BlackRock, Inc., and FMR, LLC,
would each hold more than 5 percent of the
combined organization’s common stock. Explain in
further detail why, as the Application
represents, “[n]one of these parties would
trigger any presumption of control” - full
letter on Inner City Press' DocumentCloud here
Dear
Chair Powell and others in the FRS:
...
Fair Finance Watch has long been concerned about
Synovus, as the Federal Reserve memorialized,
noting "disparities in denial rates and home
mortgage originations to African Americans
and/or Hispanics, as compared to whites, in
certain markets. The commenter also noted a
complaint filed with the CFPB against Synovus
Bank relating to collecting on a debt allegedly
not owed."
Fair Finance Watch has reviewed the
just-released 2024 Home Mortgage Disclosure Act
data of Synovus and finds that while it made
3.18 loans to whites for each denial to whites,
it made only 1.7 loans to African Americans for
each denial to African Americans.
Pinnacle is of even greater concern. In
Virginia, where Pinnacle received a Low
Satisfactory on the Lending Test in its most
recently (May 2023) CRA performance evaluation,
in 2024 it made 133 mortgage loans to whites,
with 19 denials, but only 13 loans to African
Americans, with fully eight denials.
In Alabama, where Pinnacle also received a Low
Satisfactory on the Lending Test, in 2024
Pinnacle made 106 mortgage loans to whites, with
16 denials, but only 56 loans to African
Americans, with fully nine denials.
In North Carolina, where Pinnacle also received
a Low Satisfactory on the Lending Test, in 2024
Pinnacle made 653 mortgage loans to whites, with
178 denials, but only 202 loans to African
Americans, with fully 82 denials.
Even in Tennessee, which conceals its records,
Pinnacle was rated Low Satisfactory on the
Lending Test in Knoxville and Chattanooga. Not
in the exam:
In Florida in 2024 Pinnacle made 38 mortgage
loans to whites, with 11 denials, but only five
loans to African Americans, with fully NINE
denials.
In Kentucky in 2024 Pinnacle made eleven
mortgage loans to whites, with seven denials,
but NO loans to African
Americans. This application
should not be approved; particularly in light of
the disparities, public evidentiary hearings are
needed.
Watch this site.
***
Your
support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
here to become a patron.
September
15, 2025
First
Security Bank
Protested As
FDIC Moves To
Cut Notice of
Branches
Citing Few
Protests
by
Matthew Russell Lee, Patreon Book
Substack
SOUTH
BRONX / SDNY COURT,
Sept 12 – The Community
Reinvestment Act directs bank regulators to
consider banks' records of lending in poor
neighborhoods when they apply to expand with
mergers or, right in the statute, branches
("deposit facilities").
But
now the Federal Deposit Insurance Corporation is
quietly moving to eliminate public notice of,
and public comment on, banks' branch
applications. While Inner City Press has Freedom
of Information Act requests pending, Fair
Finance Watch on August 30 commented to the
FDIC, on the proposed change - and on sample
current branch applications pending.
On
August 21, in part to forestall the Federal
Reserve using the same twisted logic of "few
comments so let's eliminate public notice," Fair
Finance Watch filed a branch comment with the
Federal Reserve Bank of St. Louis on the pending
application by Arkansas-based First Security
Bank to open a branch at 4001 Rodney Parham Road
in Little Rock, noting that First Security Bank
in Arkansas in 2024 it made 1030 mortgage loans
to whites and denied only 120 applications, 1 to
9. For African Americans, only 17 loans and
fully 10 denials: approximately 1 to 1.7.
On September 11 First Security Bank vaguely
responded, pointing to a 2023 CRA Performance
Evaluation 1) that did not consider the 2024
HMDA data. 2) that PE states, inter alia,
Distribution on loans in non-MSA Arkansas is
"Poor" (id. at 10); on the Investment
Test in Jonesboro, Hot Springs and Fort Smith is
"Below" (id. at 13); in the same Jonesboro and
Hot Springs communities, accessibility of
delivery systems are "Below." Community
Development Services in Jonesboro, also
"Below." Fair Finance Watch
reiterates its request for hearings, and denial.
See also, Inner City Press' op-ed in the
American Banker here
There
will be more.
This proposal to eliminate public notice and
comment on branch applications must be withdrawn
- or sued.
Watch
this site.
***
Your
support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
here to become a patron.
September
8, 2025
Filed
with the Fed:
Federal
Reserve Board
and Federal
Reserve Bank
of St. Louis
Re: Timely
Comment on
Branch
Application
for First
Security Bank
Dear Chair
Powell,
Secretary and
FRBSL:
On behalf of
Fair Finance
Watch and in
my personal
capacity this
is a timely
comment
opposing the
pending branch
application by
First Security
Bank to
establish a
deposit
facility at
4001 Rodney
Parham Road,
Little Rock,
Arkansas. The
application is
listed in the
FRB's H2A with
a comment
period running
through
September 1 -
Labor Day.
This August 31
comment is
timely.
FFW notes in
the FDIC's
pending
proposal RIN
3064-AG10:
"the FDIC has
received a
limited number
of public
comments in
response to
subpart C
applications....
Therefore, the
FDIC is
proposing to
eliminate the
public notice
and related
public comment
period from
subpart C and
to make
conforming
changes to
subpart A of
12 CFR part
303 of the
FDIC
Rules."
The Community
Reinvestment
Act specifies
that "the
appropriate
Federal
financial
supervisory
agency shall
(1) assess the
institution's
record of
meeting the
credit needs
of its entire
community,
including low-
and
moderate-income
neighborhoods,
consistent
with the safe
and sound
operation of
such
institution;
and (2) take
such record
into account
in its
evaluation of
an application
for a deposit
facility by
such
institution."
That is, the
only
enforcement
mechanism of
CRA is its
consideration
on
applications
for deposit
facilities:
branches.
But now the
Federal
regulator(s)
blithely
propose(s) to
eliminate
public notice
and public
comment on
branch
applications.
This is
blatantly
against the
CRA.
This proposal
to eliminate
public notice
and comment on
branch
applications
must be
withdrawn.
Ironically,
the FDIC's
reasoning is
that few
comments are
filed. So,
that is now
changing.
FFW has
reviewed the
2024 HMDA data
- not in any
CRA evaluation
- of First
Security Bank
in Arkansas in
2024 it made
1030 mortgage
loans to
whites and
denied only
120
applications,
1 to 9. For
African
Americans,
only 17 loans
and fully 10
denials:
approximately
1 to
1.7.
This is
disparate and
a hearing is
requested,
timely
opposition
made.
Again, the
only
enforcement
mechanism of
CRA is its
consideration
on
applications
for deposit
facilities:
branches.
A hearing is
requested,
timely
opposition
made
September
1, 2025
Inner City
Press live
tweeted the
Lisa Cook v.
Trump hearing
on August 29 -
and the notice
of
non-admittance
to the DDC of
the Fed's
lawyer, after.
Resolved.
We'll have
more on this
August
25, 2025
The
"new" Fed is
asking
questions - then
bank(s)
snailmail.
From a
consulting
group in
Little Rock, a
velobound spin
on CRA (while
it was
FedEZfiled to
the Fed. Then
last
week:
"Application
by BancFirst
Corporation,
Oklahoma City,
Oklahoma
(BANF),
pursuant to
Section
3(a)(3) and
3(a)(5) of the
Bank Holding
Company (BHC)
Act of 1956,
as amended, to
acquire and
merge with
AmeriBank
Holding
Company
(AmeriBank),
parent of
American Bank
of Oklahoma
(ABOK), both
of
Collinsville,
Oklahoma Dear
Mr. Shadid:
Mr. Matthew
Lee has
submitted an
adverse
comment
regarding your
filing; in
accordance
with the
Board’s ex
parte
procedures
described in a
letter to you
dated July 8,
2025, Mr. Lee
and the
agencies
copied on this
request are
entitled to
receive the
nonconfidential/public
portion of
your
response....
Non-Confidential/Public
- Additional
Items
Requested 1.
Provide all
the financial
statements
requested
below
beginning as
of June 30,
2025, and
denote what
date any
subsequent
projections
may be
referring to;
for example,
June 30, 2026
or December
31, 2026, etc.
2. Provide
interim ABOK
bank-level
current and
pro forma
applicable
capital ratios
for the period
of time in
which BANF
plans to hold
ABOK as a
separate bank
subsidiary. 3.
To the extent
possible,
provide the
following
current and
pro forma bank
level capital
and asset
quality ratios
for BancFirst
in which the
pro forma
scenario
reflects the
proposed bank
merger of ABOK
into and with
BancFirst: a.
Common Equity
Tier 1, Tier 1
Leverage, Tier
1 Risk-based
Capital, and
Total
Risk-based
Capital
ratios; and b.
Non-performing
Asset (“NPA”)
ratio in which
the NPA ratio
should be
calculated by
dividing the
sum of
nonaccrual
loans and
leases,
restructured
or modified
loans and
leases, and
other real
estate owned,
by the sum of
total equity
capital plus
the allowance
for credit
losses
(“ACL”). 4. To
the extent
possible,
provide
financial
projections,
including
capital
ratios, for
the next three
years for BANF
parent-only,
BANF
consolidated,
and BancFirst
bank-only
level
reflecting the
proposed bank
merger of ABOK
into and with
BancFirst. a.
If applicable,
include
payments
and/or other
financial
obligations
(if any) that
may be related
to the consent
orders
involving ABOK
referenced in
the prior
request for
additional
items sent on
August 1,
2025.
We'll
have more on
this.
August
18, 2025
Nevermind...
The Federal
Reserve Board
on Friday
announced that
it will sunset
its novel
activities
supervision
program and
return to
monitoring
banks' novel
activities
through the
normal
supervisory
process. Since
the Board
started its
program to
supervise
certain crypto
and fintech
activities in
banks, the
Board has
strengthened
its
understanding
of those
activities,
related risks,
and bank risk
management
practices. As
a result, the
Board is
integrating
that knowledge
and the
supervision of
those
activities
back into the
standard
supervisory
process and is
rescinding its
2023
supervisory
letter
creating the
program.
August
11, 2025
Synovus
Lending
Disparities
and CFPB Fine
Bode Badly For
Pinnacle Which
Says Too Early
by
Matthew Russell Lee, Patreon Book
Substack
SOUTH
BRONX/SDNY,
Aug 4 – Synovus Bank, with a track record of
disparate lending and consumer complaints, now
proposes to cash out and merge with
Nashville-based Pinnacle.
Pinnacle has said it's too early to say much:
"Joe Bass, a spokesman for Pinnacle, noted that,
when the merger closes, the combined bank would
have $116 billion in assets, compared to $55
billion for Pinnacle today. “It’s way too
soon to answer specific questions about specific
programs." So when will it not be too early?
Fair Finance Watch, as the Federal Reserve
memorialized, has noted "disparities in denial
rates and home mortgage originations to African
Americans and/or Hispanics, as compared to
whites, in certain markets. The commenter also
noted a complaint filed with the CFPB against
Synovus Bank relating to collecting on a debt
allegedly not owed."
Since then, Synovus showed up in the criminal
"We Build the Wall" prosecution in the U.S.
District Court for the Southern District of New
York, covered by Inner City Press, and in NSF
investigations.
Fair Finance Watch has reviewed the
just-released 2024 Home Mortgage Disclosure Act
data of Synovus and finds that while it made
3.18 loans to whites for each denial to whites,
it made only 1.7 loans to African Americans for
each denial to African Americans. We will have
more on these troubling disparities, including
under the Community Reinvestment Act. Watch this
site.
***
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August
4, 2025
Federal
Reserve
Governor
Adriana Kugler
announces she
will step down
from her
position on
the central
bank’s board,
effective Aug.
8, so new
nomination
coming
July
28, 2025
Synovus
Lending
Disparities
and CFPB Fine
Bode Badly For
Pinnacle
Proposal FFW
Details
by
Matthew Russell Lee, Patreon Book
Substack
SOUTH
BRONX/SDNY,
July 25 – Synovus Bank, with a track record of
disparate lending and consumer complaints, now
proposes to cash out and merge with
Nashville-based Pinnacle.
Fair Finance Watch, as the Federal Reserve
memorialized, has noted "disparities in denial
rates and home mortgage originations to African
Americans and/or Hispanics, as compared to
whites, in certain markets. The commenter also
noted a complaint filed with the CFPB against
Synovus Bank relating to collecting on a debt
allegedly not owed."
Since then, Synovus showed up in the criminal
"We Build the Wall" prosecution in the U.S.
District Court for the Southern District of New
York, covered by Inner City Press, and in NSF
investigations.
Fair Finance Watch has reviewed the
just-released 2024 Home Mortgage Disclosure Act
data of Synovus and finds that while it made
3.18 loans to whites for each denial to whites,
it made only 1.7 loans to African Americans for
each denial to African Americans. We will have
more on these troubling disparities, including
under the Community Reinvestment Act. Watch this
site.
***
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and grants you access to exclusive bonus material on our Patreon
page. Click
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July
21, 2025
Cadence
Bank Faced
Fair Lending
DOJ Charge
Inner City
Press Told Fed
Now Industry
Moves
By
Matthew Russell Lee, Patreon
FEDERAL
COURT / BRONX, July 16 -- How out of control is
the merger rubber stamping of the U.S. Federal
Reserve and other regulators, even as they are
ostensibly working to improve?
It was reported that Cadence Bank is looking to
settle with DOJ on lending discrimination. But
Inner City Press / Fair Finance Watch protested
Cadence to the Federal Reserve in 2018 - and the
Fed approved the merger.
Inner
City Press / Fair Finance Watch wrote: "timely
first comment on, the Applications of Cadence
Bancorporation, Houston, Texas; to acquire State
Bank Financial Corporation, Atlanta, Georgia,
and thereby indirectly acquire State Bank and
Trust Company, Macon, Georgia As an initial
matter, this is a request that the FRS
immediately send by email to Inner City Press
all non-exempt portions of the applications /
notices for which the Applicants have requested
confidential treatment.
Fair
Finance Watch has been tracking Cadence Bank: In
2017 in the Dallas, Texas MSA for convention
home purchase loans, Cadence made 99 such loans
to whites - and NONE, not a single origination,
to African Americans. In 2017 in the Houston
Texas MSA for convention home purchase loans,
Cadence made 236 such loans to whites - and only
15 to African Americans, and only 23 to Latinos.
This is not in keeping with the aggregate, which
made 37,128 such loans to whites, 3151 to
African Americans and 8215 to
Latinos.
In
2017 in the Birmingham, Alabama MSA for
convention home purchase loans, Cadence made 66
such loans to whites - and only ONE to African
Americans. Even combining in Table 4-1, it was
79 home purchase loans to whites and only THREE
to African Americans. This should
also be address in this proceeding, including at
the requested evidentiary hearing: “Cadence Bank
- Racist manager 2800 Post Oak Blvd Suite
101, Houston, TX 77056, USA Oct 14, 2017 NOT
RESOLVED I had my 2 business accounts at the
Williams tower location, I tried talking to the
manager about small business loans she always
avoided me looking at me kind of weird whenever
I done withdrawals she always asked me why I'm
taking money out after 3 months she sent me a
Leter saying she's going to be closing my
account because I take money out ones a week for
payroll and she didn't like that”
This
was covered not only in Inner City Press, here
on FOIA abuses the Fed did nothing about, but
also, for example, Barron's,
here.
And the Fed rubber stamped the merger.
Jump
cut to July 2025 when the Fed let Cadence
acquire scandal-plagued Industry
Bancshares a mere two months after Cadence
announced the proposed acquisition. The Fed then
lifted its order against Industry Bancshares for
"unsafe or unsound banking practices." Beyond
rubber stamping... Watch this site.
***
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July
14, 2025
"The
Board is also
proposing to
make similar
changes to its
supervisory
rating
framework for
insurers
regulated by
the Board" - what,
for fair
insurnce?
Doubtful...
July
7, 2025
Amid
all the
criminality in
the financial
sector,
this was the
Federal
Reserve's
enforcement
action last
week:
WHEREAS,
the Board of
Governors of
the Federal
Reserve System
(the “Board of
Governors”),
pursuant to
section 8(e)
of the Federal
Deposit
Insurance Act,
as amended
(the “FDI
Act”), 12
U.S.C. §
1818(e),
issues this
Order of
Prohibition
(the “Order”)
upon the
consent of
Respondent
Kendall
Hickman
(“Hickman”), a
former
employee and
institution-affiliated
party, as
defined in
sections 3(u)
and 8(b)(3) of
the FDI Act,
12 U.S.C. §§
1813(u) and
1818(b)(3), of
Jonah Bank of
Wyoming (the
“Bank”), a
state member
bank; WHEREAS,
Hickman was an
employee of
the Bank from
July 1, 2021,
until her
termination on
June 15, 2023;
WHEREAS, prior
to and during
the same
period,
Hickman served
as a
bookkeeper for
a nonprofit
organization;
WHEREAS, from
March 6, 2018,
to June 16,
2023, Hickman
embezzled a
total of
$33,212.84
from the
nonprofit
organization;
Huge.
June
30,
2025
Gov
Barr: "As far
as collecting
data, I would
also point to
our Community
Perspectives
Survey and the
Small Business
Credit Survey,
which the
Cleveland Fed
has conducted
since 2020.2
Beyond
collecting and
analyzing
data, the
Federal
Reserve's CD
function also
conducts
qualitative
research to
understand the
"why" behind
the data" -
then why is
the Fed so
dismissive of
HMDA data? Now
the
2024 is out...
June 23,
2025
on
Friday, the
Board
announced the
termination of
the
enforcement
actions listed
below:
UniCredit,
S.p.A., Milan,
Italy,
UniCredit Bank
AG, Munich,
Germany, and
UniCredit Bank
Austria AG,
Vienna,
Austria Cease
and Desist
Order dated
April 15, 2019
(PDF)
Terminated
June 5, 2025
China
Construction
Bank
Corporation,
Beijing,
People's
Republic of
China and
China
Construction
Bank New York
Branch, New
York, New
York. Yeah.
June 16,
2025
Gov
Bowman: "to
promote
accountability,
regulators
must be
transparent—both
in supervision
and
regulation.
Successful
policymaking
requires
openness and
humility,
caution and a
deliberate
approach. I
can assure the
Committee that
if I am
confirmed as
the Vice Chair
for
Supervision, I
will be
strongly
committed to
these values." We'll see,
on FOIA and
esp on
mergers....
June
9, 2025
CFPB
Double
Kneecaps HMDA
Analysis as
Summary Table
Search Spins
and Spins
by
Matthew R.
Lee
SOUTH
BRONX / DC, June
6 – Before Capital One announced and applied to
buy Discover, they and their law firm were
allowed to meet secretly with the Federal
Reserve, see below.
After they applied late March 20, 2024
Inner City Press submitted a Freedom of
Information Act request to the Fed. While they
granted expedited treatment, they delayed nearly
a near before on March 4, 2025 dumping over 1000
redacted pages.
On
March 28 the Fed has announced that "the federal
bank regulatory agencies today announced, in
light of pending litigation, their intent to
issue a proposal to both rescind the Community
Reinvestment Act (CRA) final rule issued in
October 2023 and reinstate the CRA framework
that existed prior."
On
March 31 the CFPB cut back on how HMDA data is
provided; on April 2 Fair Finance Watch
petitioned the Fed "to take emergency measures
to ensure public access to simply analyzable
data under the Home Mortgage Disclosure Act
(HMDA), including the 2024 data. Until now - for
2023 and before - CFPB has provided a filtering
page
for HMDA data, searchable by geography and
applicant characteristics.
On
March 31 the CFPB rather than adding 2024 data
to the filtering site linked above put
up only modified LARS by institution and a
large raw data date for which it provided a
warning.
The
effect of this is to make it significantly more
difficult for community groups to analyze and
compare lenders' HMDA data.
On
June 6, even for the 2023, a summary table
search even for a small institution just spun
and spun. The FRB should put a
simple collating / analyzing web interface with
the 2024 up forthwith.
The Fed's late-provided FOIA documents begin
with ex parte meetings between the bank, its law
firm and the Fed - telephone calls in February
2024, and a meeting inside the Fed on March 7,
2024 (the Fed waited until March 4, 2025 to
disclose this). 1000 page on Inner City Press'
DocumentCloud here.
200+ more pages here.
FOIA determination letter here
Inner
City Press has filed a FOIA appeal to the
Federal Reserve - and raised it in a March 21
comments, along with a new Bank for
International Settlements study that cries out
for denial of the merger.
On
March 24, the Fed's response: "Because your
letter was received after the end of the public
comment period, it will not be made a part of
the record of this case unless the Board in its
sole discretion determines to consider your late
comments." Yeah, discretion...
***
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June 2,
2025
Thou
dost protest
too much: "At
the
President's
invitation,
Chair Powell
met with the
President
today at the
White House to
discuss
economic
developments
including for
growth,
employment,
and inflation.
Chair Powell
did not
discuss his
expectations
for monetary
policy, except
to stress that
the path of
policy will
depend
entirely on
incoming
economic
information
and what that
means for the
outlook.
Finally, Chair
Powell said
that he and
his colleagues
on the FOMC
will set
monetary
policy, as
required by
law, to
support
maximum
employment and
stable prices
and will make
those
decisions
based solely
on careful,
objective, and
non-political
analysis."
May
26, 2025
And
there is is,
or was:
Reconsideration
of Board
action --
request for
reconsideration
of the Board's
approval of
(1) the
application by
Capital One
Financial
Corporation
(Capital One),
McLean,
Virginia, to
acquire
Discover
Financial
Services
(Discover),
Riverwoods,
Illinois, and
(2) Capital
One's notice
to acquire
certain of
Discover's
nonbanking
companies.
Denied: May
12, 2025
May
19, 2025
Governor
Barr spoke at
the 2025
Northeast /
Mid-Atlantic
Small Business
Credit
Symposium
- but no 1071
update...
May 12,
2025
Friday
was Fed day: "Governor
Michael Barr
speaks at the
Reykjavik
Economic
Conference at
5:55 a.m.,
followed by
Fed Governor
Adriana Kugler
at 6:45 a.m. …
Richmond Fed
President Tom
Barkin will
speak at the
Loudoun County
Chamber of
Commerce at
8:30 a.m. …
Fed Governors
Christopher
Waller and
Lisa Cook, New
York Fed
President John
Williams,
Cleveland Fed
President Beth
Hammack,
former Fed
Governor Kevin
Warsh (and Larry
Summers) speak
at a monetary
policy
conference
hosted by the
Hoover
Institution.
All this
and they can't
respond to
FOIA requests
on a timely
basis...
May 5,
2025
Keeping
its head down?
For the
week
April 28 to May 2,
not a single
piece of new
went up on the
Fed's website...
April
28, 2025
On
April 24,
this: "The
Federal
Reserve Board
on Thursday
announced the
withdrawal of
guidance for
banks related
to their
crypto-asset
and dollar
token
activities and
related
changes to its
expectations
for these
activities.
These actions
ensure the
Board's
expectations
remain aligned
with evolving
risks and
further
support
innovation in
the banking
system. The
Board is
rescinding its
2022
supervisory
letter
establishing
an expectation
that state
member banks
provide
advance
notification
of planned or
current
crypto-asset
activities. As
a result, the
Board will no
longer expect
banks to
provide
notification
and will
instead
monitor banks'
crypto-asset
activities
through the
normal
supervisory
process." Now
what?
April
21, 2025
In
Florida
Disparate
United
Community
Banks Granted
ANB By Fed
Amid Lending
Disparities
by
Matthew R.
Lee, Patreon Substack
FEDERAL COURT, April
16
–
In Florida, United Community Bank is trying to
move into the Miami area via merger, with a
disparate lending record. Fair Finance Watch
with Inner City Press on the FOIA has filed a
timely first comment on, the Application by UCB
to acquire American National Bank.
But consider United Community Bank's disparate
lending record:
In South Carolina in 2023, United Community
Banks made 673 mortgage loans to whites with 282
denials. Meanwhile to African Americans in the
state it made only FIFTY ONE loans, while
denying fully 45 applications.
In
Florida in 2023, United Community Banks made 240
mortgage loans to whites with 86 denials.
Meanwhile to African Americans in the state it
made only TWELVE loans, while denying five
applications.
Nationwide, United Community Banks is scarcely
better. In 2023 overall it made 5576 mortgage
loans to whites with 4114 denials. Meanwhile to
African Americans nationwide it made only 477
loans, while denying fully 1246 applications.
That is to say, while UCB to whites had more
loans then denial, to African Americans it had
nearly three times as many denials as of loans.
On
April 16 the Fed approved, calling Fair Finance
Watch the commenter and noting, "The data cited
by the commenter corresponds to publicly
available 2023 data reported by both banks under
the Home Mortgage Disclosure Act of 1975
(“HMDA”), 12 U.S.C. § 2801 et seq." - this while
the Fed has refused to respond to FFW's petition
that it ensure 2024 HMDA data is available as
before. We'll have more on this.
Watch
this site.
***
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April
14, 2025
Gov
Bowman, April 10:
"to promote
accountability,
regulators
must be
transparent—both
in supervision
and
regulation.
Successful
policymaking
requires
openness and
humility,
caution and a
deliberate
approach. I
can assure the
Committee that
if I am
confirmed as
the Vice Chair
for
Supervision, I
will be
strongly
committed to
these values."
We'll see:
Before
Capital One
announced and
applied to buy
Discover, they
and their law
firm were
allowed to
meet secretly
with the
Federal
Reserve.
After they applied late March 20, Inner
City Press submitted a Freedom of Information
Act request to the Fed. While they granted
expedited treatment, they delayed nearly a near
before on March 4 dumping over 1000 redacted
pages.
These begin with ex parte meetings between the
bank, its law firm and the Fed - telephone calls
in February 2024, and a meeting inside the Fed
on March 7, 2024 (the Fed waited until March 4,
2025 to disclose this). 1000 page on Inner City
Press' DocumentCloud here.
200+ more pages here.
FOIA determination letter here
Inner
City Press immediately appealed. More than a
month later, and apparently preparing its rubber
stamp, the Federal Reserve upheld its own
withholding in full and denied the appeal,
letter here.
April
7, 2025
CFPB
Kneecaps HMDA
Analysis as
Feds Drop CRA
Rule as Fed
Hides Talks
with Capital
One
by
Matthew R.
Lee
SOUTH
BRONX / DC, April
2 – Before Capital One announced and applied to
buy Discover, they and their law firm were
allowed to meet secretly with the Federal
Reserve, see below.
After they applied late March 20, 2024
Inner City Press submitted a Freedom of
Information Act request to the Fed. While they
granted expedited treatment, they delayed nearly
a near before on March 4, 2025 dumping over 1000
redacted pages.
On
March 28 the Fed has announced that "the federal
bank regulatory agencies today announced, in
light of pending litigation, their intent to
issue a proposal to both rescind the Community
Reinvestment Act (CRA) final rule issued in
October 2023 and reinstate the CRA framework
that existed prior."
On
March 31 the CFPB cut back on how HMDA data is
provided; on April 2 Fair Finance Watch
petitioned the Fed "to take emergency measures
to ensure public access to simply analyzable
data under the Home Mortgage Disclosure Act
(HMDA), including the 2024 data. Until now - for
2023 and before - CFPB has provided a filtering
page
for HMDA data, searchable by geography and
applicant characteristics.
On
March 31 the CFPB rather than adding 2024 data
to the filtering site linked above put
up only modified LARS by institution and a
large raw data date for which it provided a
warning.
The
effect of this is to make it significantly more
difficult for community groups to analyze and
compare lenders' HMDA
data. The FRB
should put a simple collating / analyzing web
interface with the 2024 up
forthwith.
The Fed's late-provided FOIA documents begin
with ex parte meetings between the bank, its law
firm and the Fed - telephone calls in February
2024, and a meeting inside the Fed on March 7,
2024 (the Fed waited until March 4, 2025 to
disclose this). 1000 page on Inner City Press'
DocumentCloud here.
200+ more pages here.
FOIA determination letter here
Inner
City Press has filed a FOIA appeal to the
Federal Reserve - and raised it in a March 21
comments, along with a new Bank for
International Settlements study that cries out
for denial of the merger.
On
March 24, the Fed's response: "Because your
letter was received after the end of the public
comment period, it will not be made a part of
the record of this case unless the Board in its
sole discretion determines to consider your late
comments." Yeah, discretion...
***
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March
31, 2025
Fed
Snubs New BIS
Study of Data
and Antitrust
Cited on
Capital One
Discover
Merger by FFW
by
Matthew R.
Lee
SOUTH
BRONX, March
25 – Before Capital One announced and applied to
buy Discover, they and their law firm were
allowed to meet secretly with the Federal
Reserve.
After they applied late March 20, Inner
City Press submitted a Freedom of Information
Act request to the Fed. While they granted
expedited treatment, they delayed nearly a near
before on March 4 dumping over 1000 redacted
pages.
These begin with ex parte meetings between the
bank, its law firm and the Fed - telephone calls
in February 2024, and a meeting inside the Fed
on March 7, 2024 (the Fed waited until March 4,
2025 to disclose this). 1000 page on Inner City
Press' DocumentCloud here.
200+ more pages here.
FOIA determination letter here
Inner
City Press has filed a FOIA appeal to the
Federal Reserve - and raised it in a March 21
comments, along with a new Bank for
International Settlements study that cries out
for denial of the merger.
On
March 24, the Fed's response: "Because your
letter was received after the end of the public
comment period, it will not be made a part of
the record of this case unless the Board in its
sole discretion determines to consider your late
comments." Yeah, discretion...
***
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and grants you access to exclusive bonus material on our Patreon
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March
24, 2025
New BIS
Study of Data
and Antitrust
Cited to Fed
Against
Capital One
Discover
Merger
by
Matthew R.
Lee
SOUTH
BRONX, March
21 – Before Capital One announced and applied to
buy Discover, they and their law firm were
allowed to meet secretly with the Federal
Reserve.
After they applied late March 20, Inner
City Press submitted a Freedom of Information
Act request to the Fed. While they granted
expedited treatment, they delayed nearly a near
before on March 4 dumping over 1000 redacted
pages.
These begin with ex parte meetings between the
bank, its law firm and the Fed - telephone calls
in February 2024, and a meeting inside the Fed
on March 7, 2024 (the Fed waited until March 4,
2025 to disclose this). 1000 page on Inner City
Press' DocumentCloud here.
200+ more pages here.
FOIA determination letter here
Inner
City Press has filed a FOIA appeal to the
Federal Reserve - and raised it in a March 21
comments, along with a new Bank for
International Settlements study that cris out
for denial of the merger. Who's in the
OCC's and Fed's wallet, now?
***
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and grants you access to exclusive bonus material on our Patreon
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March
17, 2025
Stock
Fraudster
Sterling
Bancorp OKed
To Sell Bank
with Weak CRA
to Everbank
Shirking NY
by
Matthew R.
Lee, Patreon Substack
FEDERAL COURT, March
14
–
Sterling Bancorp, which settled with DOJ on
securities fraud, it trying to sell its Sterling
Bank & Trust including in New York, where it
has a need to improve CRA Investment Test rating
to Everbank. Fair Finance Watch with Inner City
Press on the FOIA has filed a timely first
comment on, the Applications
This is a request for a full copy of, and a
timely first comment on, the Applications of
EverBank to acquire Sterling Bank & Trust
(with a rare Needs to Improve CRA rating on
Investment Test in New York), and not scandal
plagued Sterling
Bancorp.
Sterling Bancorp was recently prosecuted by DOJ;
EverBank purports that by buying the bank
portion it is not touched by the scandal. But
what is the showing that the criminal conduct at
the Bancorp was entirely insulated from the bank
and those who work there, and its
practices? As a
CRA matter, militating for a hearing, Sterling
Bank has a rare Needs to Improve rating on the
investment test in NY.
On
December 24 Everbank wrote in to the Fed stating
that "EverBank maintains the following two
office locations in New York, neither of which
is a “branch”... Islandia, NY: Located at 11
Oval Drive, Suite 107, Islandia, NY 11749.11
This location consists of an approximately
31,000 square-foot facility... EverBank notes
that its lease for the Islandia, New York
location is due to expire in 2025, after which
EverBank expects to move the back-office
operations currently conducted at that location
to another non-branch office location on Long
Island, New York." Needs to improve...
Nevertheless
on Friday, March 14 the Fed hauled off and
approved it, noting that FFW - "the commenter
criticized the CRA record of Sterling Bank with
respect to its “Needs to Improve” rating on the
investment test (“Investment Test”) component of
the bank’s statewide ratings in Michigan, New
York, and Washington" - then saying "EverBank
intends to renovate many of Sterling Bank’s
existing branches." Yeah.
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March
10, 2025
In
Florida
Disparate
United
Community
Banks Wants
ANB Now Fed Qs
Including on
CRA
by
Matthew R.
Lee, Patreon Substack
FEDERAL COURT, March
6
–
In Florida, United Community Bank is trying to
move into the Miami area via merger, with a
disparate lending record. Fair Finance Watch
with Inner City Press on the FOIA has filed a
timely first comment on, the Application by UCB
to acquire American National Bank.
But consider United Community Bank's disparate
lending record:
In South Carolina in 2023, United Community
Banks made 673 mortgage loans to whites with 282
denials. Meanwhile to African Americans in the
state it made only FIFTY ONE loans, while
denying fully 45 applications.
In
Florida in 2023, United Community Banks made 240
mortgage loans to whites with 86 denials.
Meanwhile to African Americans in the state it
made only TWELVE loans, while denying five
applications.
Nationwide, United Community Banks is scarcely
better. In 2023 overall it made 5576 mortgage
loans to whites with 4114 denials. Meanwhile to
African Americans nationwide it made only 477
loans, while denying fully 1246 applications.
That is to say, while UCB to whites had more
loans then denial, to African Americans it had
nearly three times as many denials as of loans.
To
this, on February 11 UCB through outside counsel
replied that while Fair Finance Watch "cites
data for the Bank’s lending in South Carolina,
Florida and 'nationwide,' the comment’s
assertion that “nationwide” data is relevant is
misplaced." What a surprise. They ignore their
disparities.
In
March the Fed asked questions, including on CRA
(and a Confidential question), and "Discuss the
purpose of each of the following provisions in
the Merger Agreement and whether any provisions
listed below would be considered to permit UCBI
or United Community Bank to exercise prior
control over the management or policies of
Bank: i. ii. Article 5.1(u),
which states that American Bank may not make or
acquire or issue a commitment for (i) any
commercial real estate Loan in an original
principal amount in excess of $7,000,000, (ii)
any residential Loan originated for retention in
the Loan portfolio in an original principal
amount in excess of $1,500,00 or (iii) any
commercial or industrial Loan in an original
principal amount in excess of $2,000,000."
Watch
this site.
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March 3,
2025
Gov
Philip
Jefferson said in
a speech last
week,
"Policymakers'
approach to
communication
has evolved
over time. In
the past,
policymakers
were not
focused on
clarity and
transparency
in their
communications
as they are
today. For
example,
former Fed
Chair Alan
Greenspan
famously
quipped in
1987, "If I
seem unduly
clear to you,
you must have
misunderstood
what I said.""
But how
transparent is
the Fed now?
Long delays on
FOIA, for
example....
February
24, 2025
Federal
Reserve
Defended
Terminating
Master
Accounts Now BSJI
Cites Fed on
Debanking
by
Matthew Russell Lee, Patreon Book
Substack
SDNY COURTHOUSE,
Feb 17 – The Federal Reserve - both the Board of
Governors in Washington and the FRBNY - have
been sued by Banco San Juan International for
the terminal of its master account(s).
On
the motion to dismiss, oral arguments were held
on December 12 before U.S. District Court for
the Southern District of New York Judge John G.
Koeltl. Inner City Press was there. Thread:
Fed's
lawyers from Simpson Thacher law firm cite
Custodia (crypto) case. Does this outside
counsel rep raise conflicts of interest on
mergers?
Note:
Simpson Thacher represents many banks applying
to the Fed for merger approvals - why did
the Fed, which has many in house lawyers,
have to hire them? And isn't there now a
conflict of interest on the merger applications?
Fed: The Reserve Banks are not govt
Plaintiff:
The Fed never closed the master accounts of
Deutsche Bank, despite wrongdoing - and what
about "Toronto Dominion, which pled guilty to
money laundering"?
[Note:
TD's Leonardo Ayala is being prosecuted in the
District of NJ]
On
January 8, 2025 Judge Koeltl dismissed the
amended complaint, setting a time to further
amend: "the defendants' motions to dismiss are
granted. All of BSJI's claims are dismissed
without prejudice as discussed above. At oral
argument, counsel for BSJI indicated that BSJI
may wish to file a second amended complaint. Tr.
16. The time to file a motion to amend,
attaching a copy of the second amended complaint
and explaining how the second amended complaint
solves the deficiencies noted in this opinion,
is January 27, 2025. The defendants may respond
by February 10, 2025. The plaintiff may reply by
February 17, 2025. If the plaintiff does not
file any such motion by January 27, 2025, the
Court will issue an order directing that
judgment be entered dismissing the Amended
Complaint."
On
February 17 BSJI through counsel Abbe Lowell
wrote in citing Fed Chair Jerome Powell's recent
testimony that he is (belatedly) troubled by
de-banking by the Reserve Banks. Full letter on
Patreon here
Inner
City Press will stay on these cases.
This
case is Banco San Juan Internacional, Inc. v.
The Federal Reserve Bank of New York, et al.,
1:23-cv-06414 (Koeltl)
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February
17, 2025
As CFPB
Home Page Goes
404 HMDA
Petition to
Federal
Reserve by
Fair Finance
Watch
by
Matthew Russell Lee, Patreon Book
Substack
Bronx / Federal
Court, Feb 11 – When a "404: Page Not
Found" message began on the homepage of the U.S.
Consumer Financial Protection Bureau, a call
went out among consumer advocates to dig deeper
in the site and begin downloading data before it
is deleted. Fine.
But the CFPB has become the platform on which
new data under the Home Mortgage Disclosure Act
is released. Simply downloading past years' data
is not enough. Where will the 2024 data go, and
be available to the public?
Fair Finance Watch, with Inner City Press on the
FOIA, filed a petition for rulemaking and
emergency mitigation with the Federal Reserve
Board:
Governor
Powell, Ladies and Gentlemen:
Fair Finance Watch and Inner City Press are
writing to petition the Board of Governors of
the Federal Reserve System under section 553(e)
of the Administrative Procedure Act to engage in
rulemaking and, most immediately, to take
emergency measures to ensure public access to
data under the Home Mortgage Disclosure Act
(HMDA), including the 2024 data.
When the Consumer Financial Protection Bureau
was created, the hosting of HMDA data shifted
from the FFIEC to CFPB website.
Today February 10, 2025 the
CFPB.gov website went dark. While portions of
the site are as of this writing still available,
it is foreseeable that the HMDA data site may be
taken down. The
Community Reinvestment Act, among other banking
laws, is largely enforced by use and analysis of
HMDA data. It is imperative that public access
to HMDA data remain.
The
FRB should begin a process to ensure access to
HMDA data, on FFIEC or the FRB's own website -
by rulemaking, if necessary long term, but
immediate on an interim basis, if necessary
mirroring the CFPB cite as long as it remains
under threat.
This petition concerning the continued public
access to HMDA data is also made with reference
to Section 553(e) of the APA, and we
respectfully request a response.
Watch
this site. Others like NCRC are advocating. We
aim to have more from DC
***
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February
10, 2025
Now the
Fed has
announced the
termination of
two
enforcement
actions with
Wells Fargo -
the one with
the predatory
lender Wells
Fargo
Financial...
February
3, 2025
Crime:
John Harold
Rogers, 63, a
former Senior
Adviser for
the Federal
Reserve Board
of Governors
was arrested
on charges
that he
conspired to
steal Federal
Reserve trade
secrets for
the People’s
Republic of
China
Revolving
door: Coinbase has
added to its Global
Advisory
Council former
New York Fed
President Bill
Dudley...
January
25, 2025
It was the
Federal
Reserve Bank of
Atlanta that
on January 23
asked "Provide
a complete
list of the
non-branch
offices of
EverBank,
National
Association
and Sterling
Bank. " Watch
this site.
January
20, 2025
On
Capital One
Discover OCC
Doubled Down
on FOIA
Withholding
Now Customers
Cut Off
by
Matthew R.
Lee
SOUTH
BRONX, Jan
17 – Capital One has applied to buy Discover, in
an anticompetitive deal that should be rejected
by regulators if they mean what they have been
saying. After they applied late March 20,
Inner City Press submitted a second Freedom of
Information Act request to the Office of the
Comptroller of the Currency (and to the Federal
Reserve).
On
May 14 - still without providing FOIA documents
- the OCC and Fed set a July 19 virtual public
meeting.
On
the eve of it, Capital One announced a vague and
less than credible plan - they previously
violated their ING Direct pledge - including
this time $75 billion in largely subprime auto
loans. Fair Finance Watch testified for three
minutes.
On
June 25 the OCC belatedly responded to Inner
City Press' FOIA request - by withholding in
full 185 pages. OCC FOIA production on
DocumentCloud here.
Inner City Press appealed.
On July 24, the very day on which the OCC and
Fed said they were closing the written comment
period, the OCC upheld in full its FOIA denials,
determination letter on Inner City Press'
Document Cloud here.
Inner City Press has requested an extension of
the comment periods - the Fed hasn't even
responded.
Nor does it seem the Fed has taken note of
Capital One cutting off its own customers on
January 16, then passing the buck to a third
party vendor, Fidelity Information Services.
Something is deeply wrong with Capital One, but
the Fed and OCC don't seem to care.
Meanwhile
Capitol One lobbying continues even now in 2024,
from New
Mexico even to Harlem by a social worker
with bankers on the board. How is this
Astroturfing organized?
Without
approvals, now the banks have set shareholders'
votes for February 18, 2025.
As
documented by Fair Finance Watch, Discover Bank
in 2022 denied mortgage loans application from
African Americans more than twice as frequently
as those of whites. It grew worse in the
just-out 2023 data.
Previously, Inner City Press and NCRC challenged
Capital One's acquisition of ING Direct, see here.This
time, given the antitrust enforcement claims
being made in DC, this proposal should be
denied. But will it be? Watch this site.
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January
13, 2025
UMB
Bank Heartland
Merger Hit on
Disparties and
Uninsured
Deposits Now
Rubber Stamped
by
Matthew R.
Lee, Patreon Substack
SOUTH BRONX /
SDNY, Jan 10
–
When First Republic Bank failed / was given to
JP Morgan Chase, a small list of other regional
banks came into focus as in danger. Among them
was UMB - a bank whose lending Inner City Press
and Fair Finance Watch had been scrutinizing,
and now challenge.
UMB is asking its regulators to allow it to
expand, buying Denver-based Heartland. The
application, Fair Finance Watch on June 21
formally told the Fed, should not be
approved. In 2022, the most recent
year for which Federal data is available, UMB
Bank, N.A. made over 2000 mortgage loans to
whites, and only 117 loans to African Americans.
For
every denial to an African American, it made
only 2.02 loans. But for whites, for every
denial it made 3.45 loans. It should be referred
to DOJ.
There
is litigation, there is also this, reported at
the time of Silicon Valley Bank's failure: "UMB
Bank, a regional bank headquartered in Kansas
City, Missouri, and with branches across the
Midwest, Southwest, and Western United States,
has total assets of $38 billion and deposits
totaling $32 billion, according to the FDIC.
However, only 16% of deposits fall under the
$250,000 FDIC insurance threshold, leaving
74.11% (equivalent to $28.36 billion) vulnerable
to potential losses."
Why
would regulators even consider approving its
expansion? On June 21, Fair Finance Watch filed
a formal Community Reinvestment Act challenge to
UMB's application to the Federal Reserve, adding
state by state data:
UMB Bank in 2022 in Missouri made 842 mortgage
loans to whites, and only 76 loans to African
Americans. Meanwhile it denied 41 applications
from African Americans, and only 257 from
whites.
UMB Bank in Colorado - in which it seeks to
expand - in 2022 made 378 mortgage loans to
whites, and only 13 loans to African Americans.
Meanwhile it denied six applications from
African Americans, and only 107 from whites.
UMB Bank in 2022 in Texas made 78 mortgage loans
to whites, and only six loans to African
Americans. Meanwhile it denied two applications
from African Americans, and only 27 from
whites.
These disparities cry out for a referral to DOJ,
and public hearings on, and denial of, UMB's
major expansion application.
On
October 11 UMB's outside counsel Davis Polk sent
the Fed a response but withheld branch closing,
subsidiary, fintech and crypto information from
Fair Finance Watch - so Inner City Press cc-ed
them on a FOIA request.
On
November 29, the Fed responded with the branch
closing list and more - now on Inner City Press'
DocumentCloud here.
Watch
this site.
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January
6, 2025
If the
Federal
Reserve Banks
are not the
government,
how can they
give out
approval like
this?
"New
York NBT
Bancorp Inc.,
Norwich, New
York—waiver of
application to
acquire Evans
Bancorp, Inc.,
Williamsville,
New York, and
thereby
acquire Evans
Bank, National
Association
(Evans Bank),
Angola, New
York, in
connection
with the
merger of
Evans Bank
with and into
NBT Bank,
National
Association,
Norwich, New
York.*
Granted:
December 18,
2024."
December
30, 2024
The Fed is
supposed to
sent copies of
its question
letters to
banking to the
community
groups which
have commented
on,
particularly
against, the
proposed
merger. But on
Capital One -
Discover, the
Fed just stopped.
Capital One
disclosed the
letter, but
not the
contents, in
SEC filings. A
new low.
December
23, 2024
Fraudster
Sterling
Bancorp Bid To
Sell Bank with
Weak CRA to
Everbank
Questioned on
NY
by
Matthew R.
Lee, Patreon Substack
FEDERAL COURT, Dec 20
–
Sterling Bancorp, which settled with DOJ on
securities fraud, it trying to sell its Sterling
Bank & Trust including in New York, where it
has a need to improve CRA Investment Test rating
to Everbank. Fair Finance Watch with Inner City
Press on the FOIA has filed a timely first
comment on, the Applications
This is a request for a full copy of, and a
timely first comment on, the Applications of
EverBank to acquire Sterling Bank & Trust
(with a rare Needs to Improve CRA rating on
Investment Test in New York), and not scandal
plagued Sterling
Bancorp.
Sterling Bancorp was recently prosecuted by DOJ;
EverBank purports that by buying the bank
portion it is not touched by the scandal. But
what is the showing that the criminal conduct at
the Bancorp was entirely insulated from the bank
and those who work there, and its
practices? As a
CRA matter, militating for a hearing, Sterling
Bank has a rare Needs to Improve rating on the
investment test in NY.
On
December 4 Everbank's outside counsel wrote in
that FFW "selectively criticizes a single
component of Sterling Bank’s most recent CRA
performance evaluation from states in which
Sterling Bank either no longer operates, will no
longer operate upon completion of the Proposed
Transaction, or maintains only a de minimis
banking presence" -- that would be New York, no
commitment to improve on the Needs to Improve.
As to Michigan the outside counsel says, or
brags, "EverBank intends to close Sterling
Bank’s only Michigan branch following completion
of the Proposed Transaction."
On
December 19, the Federal Reserve asked Everbank
questions including "Explain whether EverBank’s
office in New York is a “branch” within the
meaning of 12 U.S.C. 1841(o)(3) and indicate
whether loan proceeds are disbursed at that New
York office.
3.
The FR Y-3 notes: “following the Proposed
Transaction, the combined organization intends
to leverage the CRA and consumer protection
compliance strengths of both banks to create a
strong and comprehensive combined compliance
program.” The FR Y-3 subsequently states that
“EverBank does not anticipate any structural
changes to its CRA program, CRA leadership,
organizational structure, or oversight as a
result of the Proposed Transaction.” Clarify
whether the combined organization intends to
continue to utilize EverBank’s existing CRA and
consumer compliance programs following
consummation. If the combined organization
intends to incorporate specific aspects of
Sterling Bank’s CRA and consumer those programs
the combined organization intends to leverage
from Sterling Bank’s existing operations.
4.
The FR Y-3 notes that Sterling Bank would use
commercially reasonable efforts to close its
Southfield, Michigan branch... Indicate whether
a branch closure notice has been submitted under
section 42 of the FDI Act."
The
proposal should be denied.
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December
16, 2024
SouthState
Lending
Disparities
Triggered CRA
Protest But
Fed OKs
Admitting Weak
Carolinas
by
Matthew R.
Lee, Patreon Substack
SOUTH BRONX /
SDNY, Dec 13
–
When First Republic Bank failed / was given to
JP Morgan Chase, a small list of other regional
banks came into focus as in danger, banks whose
lending Inner City Press and Fair Finance Watch
had been scrutinizing, even more so that the
2023 data is out.
This week Inner City Press filed with the Fed, a
timely first comment on, the Applications of
SouthState Corporation to merge with Independent
Bank Group, Inc., and Independent
Bank.
SouthState in South Carolina in 2023 - data not
yet included in any CRA exam - made 5013
mortgage loans to whites, and only 228 loans to
African Americans. Meanwhile it denied only 670
applications from whites, and fully 195 from
African Americans. SouthState should be referred
to DOJ.
SouthState in North Carolina in 2023 - data not
yet included in any CRA exam - made 1334
mortgage loans to whites, and only FIFTY SEVEN
loans to African Americans. Meanwhile it denied
only 173 applications from whites, and fully 20
from African Americans.
SouthState in Georgia in 2023 - data not yet
included in any CRA exam - made 1176 mortgage
loans to whites, and only 318 loans to African
Americans. Meanwhile it denied only 304
applications from whites, and fully 88 from
African Americans.
Nationwide
in 2023, SouthState made 7798 mortgage loans to
whites, and only 947 loans to African Americans.
Meanwhile it denied only 2491 applications from
whites, and fully 558 from African
Americans.
Why would regulators even consider approving its
expansion?
On
August 9, SouthState submitted to the Fed a
response - that deals only with Independent
Bank.
On
September 18, the Fed asked SouthState questions
including "Confirm that no consumer products or
community development programs or services
offered by either organization will be
discontinued by the combined organization as a
result of the proposed transaction, other than
those identified in Confidential Exhibit 18 to
the application."
Inner
City Press has submitted a FOIA request with the
Fed for that obviously CRA-material Exhibits.
No thanks to the Fed, Inner City Press got the
exhibit - SouthState just withdrew its request
for confidential treatment, of this:
"CONFIDENTIAL SouthState Bank, N.A.
Independent Bank Discontinued Independent
Bank Products and Services June 2024
SSC and IBTX currently plan on discontinuing
Independent Bank’s mortgage warehouse program
and selling its Shared National Credits (SNC)
portfolio. Almost all purchased SNCs are in
Independent Bank’s commercial loan portfolio,
with the largest single industry concentration
in energy."
But
there is more being withheld. SouthState filed
on September 30: "Please see Confidential
Exhibit 1 to the Confidential Appendix for
additional information on branch actions
SouthState may plan to take that are unrelated
to the proposed transaction."
On
December 13 the Fed rubber stamped the deal,
even as it admitted it is order poor performance
in South Carolina and poor geographic
distribution of SouthState's loans in North
Carolina. This is today's Fed.
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December
9, 2024
First
Busey $1B Bid
For CrossFirst
Hit by Fair
Finance Watch
Now Fed Asks
Sealed
Question
by
Matthew R.
Lee, Patreon Substack
FEDERAL COURT, Dec 5
–
In the Midwest, Busey Bank is trying to move
into the Kansas City area via merger, with a
disparate lending record. Fair Finance Watch
with Inner City Press on the FOIA has filed a
timely first comment on, the Applications
Van Dukeman, First Busey's CEO called it a
"great fit from a cultural perspective." But
consider Busey Bank's culture - including
contempt for CRA, its disparate lending
record:
First
Busey's Busey Bank in Illinois in 2023 - data
not yet included in any CRA exam - made 1163
mortgage loans to whites, and only 772 loans to
African Americans. Meanwhile it denied only 216
applications from whites, and fully 24 from
African Americans. Busey Bank should be referred
to DOJ.
Busey
Bank in Missouri in 2023 - data not yet included
in any CRA exam - made 49 mortgage loans to
whites, and only seven loans to African
Americans. Meanwhile it denied only 21
applications from whites, and fully eight from
African Americans
Busey
Bank in Indiana in 2023 - data not yet included
in any CRA exam - made 22 mortgage loans to
whites, and only two loans to African
Americans.
Busey
Bank in Florida in 2023 - data not yet included
in any CRA exam - made 80 mortgage loans to
whites, and only ONE loan to an African
American.
Rather
than provide CRA info, First Busey's Monica L.
Bowe, Executive Vice President & Chief Risk
Officer of First Busey Corporation - and of the
Risk Management Association- submitted a letter
saying CRA conditions are never attached -
false, and telling.
Now
after questions Busey's outside counsel has
disclosed that Busey "has been the target of
multiple law firms’ efforts to solicit customers
via the internet to bring a mass arbitration
based on overdraft and NSF fees, specifically
Authorize Positive, Settle Negative and
Representment fees, both of which Busey Bank
stopped charging in 2022. Busey Bank first
became aware of these solicitations in February,
2024. Representatives of Busey have spoken with
representatives of some of these law firms and
have received demands for attorneys’ fees and
potential refunding of certain fees and Busey
management is currently discussing the path
forward with counsel."
On
December the Federal Reserve cc-ed Inner City
Press on its question to Busey Bank - but the
question was entirely withheld.
That's today Fed.
The
merger should be denied. Watch this site.
***
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December
2, 2024
UMB
Bank
Application
for Heartland
Hit on
Disparties
Info Withheld
Now Won Under
FOIA
by
Matthew R.
Lee, Patreon Substack
SOUTH BRONX /
SDNY, Nov 29
–
When First Republic Bank failed / was given to
JP Morgan Chase, a small list of other regional
banks came into focus as in danger. Among them
was UMB - a bank whose lending Inner City Press
and Fair Finance Watch had been scrutinizing,
and now challenge.
UMB is asking its regulators to allow it to
expand, buying Denver-based Heartland. The
application, Fair Finance Watch on June 21
formally told the Fed, should not be
approved. In 2022, the most recent
year for which Federal data is available, UMB
Bank, N.A. made over 2000 mortgage loans to
whites, and only 117 loans to African Americans.
For
every denial to an African American, it made
only 2.02 loans. But for whites, for every
denial it made 3.45 loans. It should be referred
to DOJ.
There
is litigation, there is also this, reported at
the time of Silicon Valley Bank's failure: "UMB
Bank, a regional bank headquartered in Kansas
City, Missouri, and with branches across the
Midwest, Southwest, and Western United States,
has total assets of $38 billion and deposits
totaling $32 billion, according to the FDIC.
However, only 16% of deposits fall under the
$250,000 FDIC insurance threshold, leaving
74.11% (equivalent to $28.36 billion) vulnerable
to potential losses."
Why
would regulators even consider approving its
expansion? On June 21, Fair Finance Watch filed
a formal Community Reinvestment Act challenge to
UMB's application to the Federal Reserve, adding
state by state data:
UMB Bank in 2022 in Missouri made 842 mortgage
loans to whites, and only 76 loans to African
Americans. Meanwhile it denied 41 applications
from African Americans, and only 257 from
whites.
UMB Bank in Colorado - in which it seeks to
expand - in 2022 made 378 mortgage loans to
whites, and only 13 loans to African Americans.
Meanwhile it denied six applications from
African Americans, and only 107 from whites.
UMB Bank in 2022 in Texas made 78 mortgage loans
to whites, and only six loans to African
Americans. Meanwhile it denied two applications
from African Americans, and only 27 from
whites.
These disparities cry out for a referral to DOJ,
and public hearings on, and denial of, UMB's
major expansion application.
On
October 11 UMB's outside counsel Davis Polk sent
the Fed a response but withheld branch closing,
subsidiary, fintech and crypto information from
Fair Finance Watch - so Inner City Press cc-ed
them on a FOIA request.
On
November 29, the Fed responded with the branch
closing list and more - now on Inner City Press'
DocumentCloud here.
Watch
this site.
***
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support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
here to become a patron.
November
25, 2024
First
Busey $1B Bid
For CrossFirst
Hit by Fair
Finance Watch
Now They
Disclose Legal
Threat
by
Matthew R.
Lee, Patreon Substack
FEDERAL COURT, Nov 20
–
In the Midwest, Busey Bank is trying to move
into the Kansas City area via merger, with a
disparate lending record. Fair Finance Watch
with Inner City Press on the FOIA has filed a
timely first comment on, the Applications
Van Dukeman, First Busey's CEO called it a
"great fit from a cultural perspective." But
consider Busey Bank's culture - including
contempt for CRA, its disparate lending
record:
First
Busey's Busey Bank in Illinois in 2023 - data
not yet included in any CRA exam - made 1163
mortgage loans to whites, and only 772 loans to
African Americans. Meanwhile it denied only 216
applications from whites, and fully 24 from
African Americans. Busey Bank should be referred
to DOJ.
Busey
Bank in Missouri in 2023 - data not yet included
in any CRA exam - made 49 mortgage loans to
whites, and onlyseven loans to African
Americans. Meanwhile it denied only 21
applications from whites, and fully eight from
African Americans
Busey
Bank in Indiana in 2023 - data not yet included
in any CRA exam - made 22 mortgage loans to
whites, and only two loans to African
Americans.
Busey
Bank in Florida in 2023 - data not yet included
in any CRA exam - made 80 mortgage loans to
whites, and only ONE loan to an African
American.
Rather
than provide CRA info, First Busey's Monica L.
Bowe, Executive Vice President & Chief Risk
Officer of First Busey Corporation - and of the
Risk Management Association- submitted a letter
saying CRA conditions are never attached -
false, and telling.
Now
after questions Busey's outside counsel has
disclosed that Busey "has been the target of
multiple law firms’ efforts to solicit customers
via the internet to bring a mass arbitration
based on overdraft and NSF fees, specifically
Authorize Positive, Settle Negative and
Representment fees, both of which Busey Bank
stopped charging in 2022. Busey Bank first
became aware of these solicitations in February,
2024. Representatives of Busey have spoken with
representatives of some of these law firms and
have received demands for attorneys’ fees and
potential refunding of certain fees and Busey
management is currently discussing the path
forward with counsel."
The merger should be denied. Watch
this site.
November
18, 2024
UMB Bank
Application
for Heartland
Hit on
Disparties
Info Withheld
Now FOIA Delay
by
Matthew R.
Lee, Patreon Substack
SOUTH BRONX /
SDNY, Nov 12
–
When First Republic Bank failed / was given to
JP Morgan Chase, a small list of other regional
banks came into focus as in danger. Among them
was UMB - a bank whose lending Inner City Press
and Fair Finance Watch had been scrutinizing,
and now challenge.
UMB is asking its regulators to allow it to
expand, buying Denver-based Heartland. The
application, Fair Finance Watch on June 21
formally told the Fed, should not be
approved. In 2022, the most recent
year for which Federal data is available, UMB
Bank, N.A. made over 2000 mortgage loans to
whites, and only 117 loans to African Americans.
For
every denial to an African American, it made
only 2.02 loans. But for whites, for every
denial it made 3.45 loans.
On
June 21, Fair Finance Watch filed a formal
Community Reinvestment Act challenge to UMB's
application to the Federal Reserve, adding state
by state data:
UMB Bank in 2022 in Missouri made 842 mortgage
loans to whites, and only 76 loans to African
Americans. Meanwhile it denied 41 applications
from African Americans, and only 257 from
whites.
UMB Bank in Colorado - in which it seeks to
expand - in 2022 made 378 mortgage loans to
whites, and only 13 loans to African Americans.
Meanwhile it denied six applications from
African Americans, and only 107 from whites.
UMB Bank in 2022 in Texas made 78 mortgage loans
to whites, and only six loans to African
Americans. Meanwhile it denied two applications
from African Americans, and only 27 from
whites.
These disparities cry out for a referral to DOJ,
and public hearings on, and denial of, UMB's
major expansion application.
On
October 11 UMB's outside counsel Davis Polk sent
the Fed a response but withheld branch closing,
subsidiary, fintech and crypto information from
Fair Finance Watch - so Inner City Press cc-ed
them on a FOIA request for:
This
is a formal FOIA request for the withheld
exhibits to UMB's October 11 submission to the
Federal Reserve in connection with its protested
application to acquire Heartland Financial, in
particular "Confidential" Exhibits A and B,
including about fintech and branch closings and
all activities engaged in by corporate
subsidiaries. This is presumptively public; if
any is withheld, all reasonably segregable
portions should be provided.
UMB
recites and responds: 1. Provide a description
of the activities conducted by the following UMB
subsidiaries: a. UMBCDC, Inc., Kansas City,
Missouri; b. UMB Financial Services, Inc.,
Kansas City, Missouri; c. UMB Management Equity
Holdings Inc., Kansas City, Missouri; d. UMB
Merchant LLC, Kansas City, Missouri; and e. UMB
Asset Management, LLC, Kansas City, Missouri The
requested information is included in AIR
Confidential Exhibit A. Convenience and Needs 2.
Provide an update on UMB Bank’s branch
consolidation analysis and confirm whether any
of the branches listed in Public Exhibit 3 of
the Additional Information Response, dated
August 5, 2024 (“August AI Response”) would be
consolidated, following consummation of the
proposed transaction. The requested information
is included in AIR Confidential Exhibit B.
Discuss any plans to engage in
crypto-asset-related activities or fintech
partnerships. The requested information is
included in AIR Confidential Exhibit
A.
Again,
this is both important for the public to know
and is presumptively public; if any is withheld,
all reasonably segregable portions should be
provided.
On
November 12 - a month after the request - the
Fed wrote that it was unilaterally extending its
time to respond to November 26.
Watch
this site.
***
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little as $5 a month helps keep us going and grants you access
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November
11, 2024
First
Busey $1B Bid
For CrossFirst
Hit by Fair
Finance Watch
Info Hidden
Now FOIA Delay
by
Matthew R.
Lee, Patreon Substack
FEDERAL COURT, Nov 4 –
In the Midwest, Busey Bank is trying to move
into the Kansas City area via merger, with a
disparate lending record. Fair Finance Watch
with Inner City Press on the FOIA has filed a
timely first comment on, the Applications
Van Dukeman, First Busey's CEO called it a
"great fit from a cultural perspective." But
consider Busey Bank's culture - including
contempt for CRA, its disparate lending
record:
First
Busey's Busey Bank in Illinois in 2023 - data
not yet included in any CRA exam - made 1163
mortgage loans to whites, and only 772 loans to
African Americans. Meanwhile it denied only 216
applications from whites, and fully 24 from
African Americans. Busey Bank should be referred
to DOJ.
Busey
Bank in Missouri in 2023 - data not yet included
in any CRA exam - made 49 mortgage loans to
whites, and onlyseven loans to African
Americans. Meanwhile it denied only 21
applications from whites, and fully eight from
African Americans
Busey
Bank in Indiana in 2023 - data not yet included
in any CRA exam - made 22 mortgage loans to
whites, and only two loans to African
Americans.
Busey
Bank in Florida in 2023 - data not yet included
in any CRA exam - made 80 mortgage loans to
whites, and only ONE loan to an African
American.
There
is litigation, for example under the FCRA, here
- dropped without explanation, presumable
settled, the FRB should ask First Busey about
all outstanding consumer litigation.
And
there was the First Busey board member,
Elisabeth Kimmel, caught in the college
admissions scandal, here.
When
the Fed provided the application, the banks had
withheld their CRA data. So, "This is a formal
FOIA request for the withheld exhibits to the
First Busey / CrossFirst application, in
particular "Confidential" Exhibits 9 ("First
Busey Community Reinvestment Act Data") and 10
("CrossFirst Community Reinvestment Act data").
This is presumptively public."
Rather
than provide the CRA info, First Busey's Monica
L. Bowe, Executive Vice President & Chief
Risk Officer of First Busey Corporation - and of
the Risk Management Association- submitted a
letter saying CRA conditions are never attached
- false, and telling.
Inner
City Press' FOIA request? The Fed on November 4
extended its time to reply - and unlike other
less arrogant banks, First Busey has provided
nothing. Watch this site.
***
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support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
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November
4, 2024
Today's
FRB gives out
gifts to
redliners in
secret. Consider:
St. Louis
German
American
Bancorp, Inc.,
Jasper,
Indiana—waiver
of application
to acquire
Heartland
BancCorp,
Whitehall,
Ohio, and
simultaneously
merge
Heartland
Bank,
Whitehall,
Ohio, with and
into German
American Bank,
Jasper,
Indiana.
Granted:
October 22,
2024
From
September,
ongoing: Fair
Finance Watch
has been
concerned for
some time with
German
American
Bank's
outreach /
image and
lending. In
Indiana in
2023 - in HMDA
data not yet
taken into
account in any
CRA exam -
German
American Bank
based on its
marketing made
1743 mortgage
loans to
whites, and
only SIXTEEN
loans to
African
Americans.
Meanwhile it
denied 11
applications
from African
Americans, and
only 356 from
whites
October
28, 2024
From
the FRB of Chicago:
"Dear Matthew:
This is in
reference to
the filing by
First Busey
Corporation,
Champaign,
Illinois, to
merge with
CrossFirst
Bankshares,
Inc., Leawood,
Kansas
(“Applicant”),
and thereby
indirectly
acquire
CrossFirst
Bank, Leawood,
Kansas. This
will
acknowledge
receipt of
your comment
email dated
October 15,
2024. Your
comment has
been accepted
by the Federal
Reserve Bank
of Chicago
(“Reserve
Bank”)
relative to
this filing
and will be
made a part of
the record. A
copy of your
comment has
been forwarded
to Applicant
for an
opportunity to
respond and if
Applicant
responds, you
will be
provided a
copy of the
response. To
the extent the
comment letter
and request
for a hearing
dated October
15, 2024, also
seeks records
under the
Freedom of
Information
Act (“FOIA”),
it does not
comply with
section
261.11(a)(2)
of the Board’s
Rules relating
to the
submission of
FOIA requests
because you
have combined
a request for
records with
comments on an
application
and a hearing
request, 12
CFR
261.11(a)(2).
This
correspondence,
therefore,
will not be
processed as a
FOIA request.
Accordingly,
if you seek
information
under the
FOIA, you may
submit a
separate
request to the
Board’s
Freedom of
Information
Office that
complies with
the
requirements
of section
261.11 of the
Board’s
Rules."
But on FOIA
requests, even
when the Board
grants expedited
processing, no
records are
received on a
timely
basis...
October
21, 2024
Expedited? From
the Fed: This is
in response to
your
electronic
message dated
and received
by the Board
on October 11,
2024. Pursuant
to the Freedom
of Information
Act (“FOIA”),
5 U.S.C. §
552, you
request:
the withheld
exhibits to
UMB’s October
11 submission
to the Federal
Reserve in
connection
with its
protested
application to
acquire
Heartland
Financial, in
particular
“Confidential”
Exhibits A and
B, including
about fintech
and branch
closings and
all activities
engaged in by
corporate
subsidiaries.
You have
requested
expedited
processing
... I
have
determined to
grant your
request for
expedited
processing
because (1)
you are
primarily
engaged in
disseminating
information,
and (2) the
application
you seek is
pending with
the Board.
Accordingly,
your request
will be
processed as
soon as
practicable
and ahead of
other FOIA
requests.
We'll see.
October
14, 2024
On First Busey,
Inner City
Press has been
granted
expedited
processing: "I
have
determined to
grant your
request for
expedited
processing
because (1)
you are
primarily
engaged in
disseminating
information,
and (2) the
application
you seek is
open for"
comment...
October
7, 2024
First
Busey $1B Bid
For CrossFirst
Hit by Fair
Finance Watch
As CRA
Exhibits
Withheld
by
Matthew R.
Lee, Patreon Substack
FEDERAL COURT, Oct
4 –
In the Midwest, Busey Bank is trying to move
into the Kansas City area via merger, with a
disparate lending record. Fair Finance Watch
with Inner City Press on the FOIA has filed a
timely first comment on, the Applications
Van Dukeman, First Busey's CEO called it a
"great fit from a cultural perspective." But
consider Busey Bank's culture, its disparate
lending record:
First
Busey's Busey Bank in Illinois in 2023 - data
not yet included in any CRA exam - made 1163
mortgage loans to whites, and only 772 loans to
African Americans. Meanwhile it denied only 216
applications from whites, and fully 24 from
African Americans. Busey Bank should be referred
to DOJ.
Busey
Bank in Missouri in 2023 - data not yet included
in any CRA exam - made 49 mortgage loans to
whites, and onlyseven loans to African
Americans. Meanwhile it denied only 21
applications from whites, and fully eight from
African Americans
Busey
Bank in Indiana in 2023 - data not yet included
in any CRA exam - made 22 mortgage loans to
whites, and only two loans to African
Americans.
Busey
Bank in Florida in 2023 - data not yet included
in any CRA exam - made 80 mortgage loans to
whites, and only ONE loan to an African
American.
There
is litigation, for example under the FCRA, here
- dropped without explanation, presumable
settled, the FRB should ask First Busey about
all outstanding consumer litigation.
And
there was the First Busey board member,
Elisabeth Kimmel, caught in the college
admissions scandal, here.
When
the Fed provided the application, the banks had
withheld their CRA data. So, "This is a formal
FOIA request for the withheld exhibits to the
First Busey / CrossFirst application, in
particular "Confidential" Exhibits 9 ("First
Busey Community Reinvestment Act Data") and 10
("CrossFirst Community Reinvestment Act data").
This is presumptively public." Watch this site.
***
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support means a lot. As little as $5 a month helps keep us going
and grants you access to exclusive bonus material on our Patreon
page. Click
here to become a patron.
September
30, 2024
The Fed
has granted
expedited
processing,
they say, to
Inner City
Press'
SouthState
FOIA - but
still no
documents...
September
23, 2024
SouthState
Lending
Disparities
Triggered CRA
Challenge Now
after FOIA
Withheld
Exhibit 18
by
Matthew R.
Lee, Patreon Substack
SOUTH BRONX /
SDNY, Sept
19 –
When First Republic Bank failed / was given to
JP Morgan Chase, a small list of other regional
banks came into focus as in danger, banks whose
lending Inner City Press and Fair Finance Watch
had been scrutinizing, even more so that the
2023 data is out.
This week Inner City Press filed with the Fed, a
timely first comment on, the Applications of
SouthState Corporation to merge with Independent
Bank Group, Inc., and Independent
Bank.
SouthState in South Carolina in 2023 - data not
yet included in any CRA exam - made 5013
mortgage loans to whites, and only 228 loans to
African Americans. Meanwhile it denied only 670
applications from whites, and fully 195 from
African Americans. SouthState should be referred
to DOJ.
SouthState in North Carolina in 2023 - data not
yet included in any CRA exam - made 1334
mortgage loans to whites, and only FIFTY SEVEN
loans to African Americans. Meanwhile it denied
only 173 applications from whites, and fully 20
from African Americans.
SouthState in Georgia in 2023 - data not yet
included in any CRA exam - made 1176 mortgage
loans to whites, and only 318 loans to African
Americans. Meanwhile it denied only 304
applications from whites, and fully 88 from
African Americans.
Nationwide
in 2023, SouthState made 7798 mortgage loans to
whites, and only 947 loans to African Americans.
Meanwhile it denied only 2491 applications from
whites, and fully 558 from African
Americans.
Why would regulators even consider approving its
expansion?
On
August 9, SouthState submitted to the Fed a
response - that deals only with Independent
Bank.
On
September 18, the Fed asked SouthState questions
including "Confirm that no consumer products or
community development programs or services
offered by either organization will be
discontinued by the combined organization as a
result of the proposed transaction, other than
those identified in Confidential Exhibit 18 to
the application."
Inner
City Press has submitted a FOIA request with the
Fed for that obviously CRA-material Exhibits.
No thanks to the Fed, Inner City Press got the
exhibit - SouthState just withdrew its request
for confidential treatment, of this:
"CONFIDENTIAL SouthState Bank, N.A.
Independent Bank Discontinued Independent
Bank Products and Services June 2024
SSC and IBTX currently plan on discontinuing
Independent Bank’s mortgage warehouse program
and selling its Shared National Credits (SNC)
portfolio. Almost all purchased SNCs are in
Independent Bank’s commercial loan portfolio,
with the largest single industry concentration
in energy."
Inner
City Press is requesting an extension of the
public comment period, public / virtual
evidentiary hearings and that, on the current
record, the applications not be approved
***
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September
16, 2024
The Fed
is a paper
tiger? Not
only still
nothing on the
Porticoes
application -
on September
11 the Fed
issued an
enforcement
action against
Fieldpoint,
which
immediately
put out "“We
have a strong
partnership
with our
regulators,”
said H.
Russell
Holland,
President and
CEO of
Fieldpoint
Private. "Private
Holdings,
Inc., is the
holding
company of
Fieldpoint
Private Bank
& Trust, a
boutique
private
banking firm
headquartered
in Greenwich,
Connecticut,
with offices
in New York
City, Atlanta
and
Orlando/Winter
Park.
Fieldpoint
Private was
established at
the onset of
the Great
Financial
Crisis by 31
individuals,
including
former
Chairmen and
CEOs of some
of the most
well-known and
successful
financial and
consumer firms
in America."
September
9, 2024
More from the
FRB Chicago,
but from FRBNY,
*still*
nothing on the
Porticoes
application...
September
2, 2024
The Fed
*still* hasn't
sent the
request Porticoes /
"blank
check" bank
application.
But from
the FRB Chicago,
this:
"Pursuant to
your email
request,
attached is
the public
portion of the
below
filing:
ChoiceOne
Financial
Services,
Inc., Sparta,
Michigan to
merge with
Fentura
Financial,
Inc., and
thereby
indirectly
acquire The
State Bank,
both of
Fenton,
Michigan
Please confirm
receipt of
this email
after
verifying that
the document
could be
opened." We
confirmed; OOO
August
26, 2024
And
SouthState's
response -
much of it
confined to a
"Confidential"
exhibit: