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January 18, 2021

From the Fed's OIG: "Closed Investigations: 2020  Number Date Opened Date Closed Case Name 1 07/24/17 02/13/20 Alleged Bank Fraud 2 01/15/19 03/19/20 Employee Misconduct 3 09/27/18 03/27/20 Advance Fee Scheme 4 11/02/18 04/01/20 Alleged Bank Fraud 5 07/05/18 05/15/20 Advance Fee Scheme 6 08/11/15 06/23/20 Alleged Fraudulent Loans 7 04/23/20 06/30/20 Alleged Fraudulent Scheme 8 05/07/18 08/26/20 Alleged Bank Fraud 9 05/16/18 09/22/20 Alleged Bank Fraud 10 02/04/15 09/23/20 Alleged Bank Fraud 11 03/06/19 10/29/20 Alleged Bank Fraud 12 01/14/20 11/17/20 Alleged Fraudulent Scheme 13 11/09/18 12/15/20 Employee Misconduct 14 06/09/20 12/31/20 Alleged Fraudulent Loans" We'll have more on this.

January 11, 2021

 Here from the Council on Foreign Relations... Richard H. Clarida: "It is my pleasure to meet virtually with you today at the Council on Foreign Relations.1 I regret that we are not doing this session in person, as we did last year, and I hope the next time I am back, we will be gathering together in New York City again. I look forward to my conversation with Steve Liesman and to your questions, but first, please allow me to offer a few remarks on the economic outlook, Federal Reserve monetary policy, and our new monetary policy framework.  Current Economic Situation and Outlook In the second quarter of last year, the COVID-19 (coronavirus disease 2019) pandemic and the mitigation efforts put in place to contain it delivered the most severe blow to the U.S. economy since the Great Depression." And CRA? Watch this site.

January 4, 2021

Fed Governor Brainard: ...The Federal Reserve Financial Stability Report incorporated for the first time an analysis of the ways climate change could present risks to financial stability.38 Similarly, the Federal Reserve Supervision and Regulation Report described how climate-related risks can create microprudential risks and how supervisors are working to better understand, measure, and mitigate these risks.39 Last quarter, the Federal Reserve released a CRA proposal that for the first time highlighted the importance of investing in climate resilience for LMI and underserved communities.

We'll have more on this.

December 28, 2020

Look at the chair and vice chair of the Federal Reserve Bank of DallasDallas Greg L. Armstrong, co-founder and chairman and chief executive officer (retired), Plains All American Pipeline L.P., Houston, Texas, renamed Chair. Thomas J. Falk, executive chairman (retired), Kimberly-Clark Corporation, Dallas, Texas, renamed Deputy Chair.

Pipeline and Kimberly-Clark.

December 21, 2020

Gov Brainard at CBA:  we aim to modernize the CRA in a way that advances the core purpose of the statute, while also providing greater certainty, tailoring regulations, and minimizing burden. Over the next few months, the Federal Reserve System will host outreach meetings and listening sessions like this one around the country. We encourage the public to submit written comments by the deadline of February 16, 2021, and I look forward to your feedback [here]

December 14, 2020

NY Federal Reserve Firing Former FBI Agent Escorted Him Out at 69 So He Sues in SDNY

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - ESPN

SDNY COURTHOUSE, Dec 10 – Robert N. Sama, 69, was terminated by the Federal Reserve Bank of New York on February 19, 2020. He had worked there since 2007.

He filed a lawsuit in the U.S. District Court for the Southern District of New York on December 10, 2020 - Inner City Press is reporting it that same day.  

From the complaint we learn that "each FRS Bank maintains an on-site law enforcement commad called a Law Enforcement Unit."

 Sama was Vice President of the FRBNY's LEU. He had previously been with the FBI for 29 years.  

After Sama's "escorted ejection," his job was given to LEU Captain Ronald Porter, who was "jumped three level" to handle Sama's LEU responsibilities.

  The complaint calls the FRB a "privately held corporation... not a federal agency and its employees are not federal employees with the protections inherent therein."  

 Similarly, the Federal Reserve says that the FRBNY and other Reserve Banks are not subject to FOIA. Why then can they approve bank mergers? Inner City Press has a FOIA request pending.

The case is Sama v. Federal Reserve Bank of New York, 20-cv-10450 (Unassigned)

December 7, 2020

To Federal Reserve Waller Squeaks In 48-47 In Lame Duck Distanced Self From Judy Shelton

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - The Source

SOUTH BRONX, Dec 5 – In the midst of the Coronavirus pandemic and the election, with a fintech and crypto-currency proponent installed as Acting Comptroller, SoFi and its controller SoftBank sought to get and then got a U.S. national bank charter. Now Judy Shelton is still being pushed for the Federal Reserve, albeit with dwindling chances.

 Her fellow-nominee Christopher Waller, who squeaked in last week 48-47 as the first lame duck Fed confirmee, said this about Shelton:

Q: Mr. Waller, given Ms. Shelton’s answers on monetary policy in her thirty years of writing on the gold standard, would you recommend we confirm her to the Fed?

Waller:  Senator, that’s your decision, not mine. 

Sen. Brown: I figured that would be your answer. Let me ask in a different way. So, you’re at St. Louis Fed, right? 

Waller: Correct. 

Sen. Brown: If you were interviewing for your research department, would you hire her? 

Waller: I have a very different research department, in terms of the type of academic research we do. Judy’s been much more in the public light, in terms of her research. My department’s all publishing for academic journals. No, that’s not [inaudible] 

Sen. Brown: If someone brought her body of work and writing to you, would you hire her? Or him? 

Waller: Like I said, where her outlets are compared to what we expect our staff… They’re just two different outlets for your research

 As of November 16, there are at least three GOP senators opposing. Joining Senators Collins and Romney, Senator Lamar Alexander said “I oppose the nomination of Judy Shelton because I am not convinced that she supports the independence of the Federal Reserve Board as much as I believe the Board of Governors should. I don’t want to turn over management of the money supply to a Congress and a President who can’t balance the federal budget.” And of course there are also CRA and fair lending laws.

 On November 17, cloture for her failed 47-50. Sen McConnell switched his "yes" vote to "no," to let him attempt to re-vote again. Watch this site.

November 30, 2020

Federal Reserve Board Is Sued For FOIA About Maiden Lane and FRBNY Now To 2d Cir

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - ESPN

SDNY COURTHOUSE, Nov 28 – The U.S. Federal Reserve Board got a Freedom of Information Act request for "any records from Maiden Lane LLC and Maiden Lane II LLC and Maiden Lane III LLC containing the CUSIP Number 40431LAR9."

The Fed Board denied it "because these loans were issued by the FRB of New York, not as a delegated function of the Board."  

That is to say, the Federal Reserve Board is again saying its its Reserve Banks, to which it delegates rubber stamping of mergers, are not subject to FOIA. 

  In this case, the Federal Reserve Board has not sent its own lawyers, as it did when Inner City Press sued it under FOIA.

Instead, it is represented, like ICE or other agencies, by the US Attorney's Office at 86 Chambers Street.

  Now there's a bid to appeal to the Second Circuit Court of Appeals.

The case is Junk v. Board of Governors of the Federal Reserve System, 19-cv-385 (Cote).

November 23, 2020

To Federal Reserve Judy Shelton Fails 47-50 For Now But Another Attempt May Be Made

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - The Source

SOUTH BRONX, Nov 17 – In the midst of the Coronavirus pandemic and the election, with a fintech and crypto-currency proponent installed as Acting Comptroller, SoFi and its controller SoftBank sought to get and then got a U.S. national bank charter. Now Judy Shelton is being pushed for the Federal Reserve.

 As of November 16, there are at least three GOP senators opposing. Joining Senators Collins and Romney, Senator Lamar Alexander said “I oppose the nomination of Judy Shelton because I am not convinced that she supports the independence of the Federal Reserve Board as much as I believe the Board of Governors should. I don’t want to turn over management of the money supply to a Congress and a President who can’t balance the federal budget.” And of course there are also CRA and fair lending laws.

 On November 17, cloture for her failed 47-50. Sen McConnell switched his "yes" vote to "no," to let him attempt to re-vote again. Watch this site.

November 16, 2020

To Federal Reserve Board Judy Shelton Is Being Pushed Like Lameduck OCC OKing Charters

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - The Source

SOUTH BRONX, Nov 12 – In the midst of the Coronavirus pandemic and the election, with a fintech and crypto-currency proponent installed as Acting Comptroller, SoFi and its controller SoftBank sought to get and then got a U.S. national bank charter. Now Judy Shelton is being pushed for the Federal Reserve.

 Meanwhile Inner City Press' requests under the Freedom of Information Act into Acting Comproller Brian P. Brooks' conflicts of interest in the fintech and crypto-currency world have yet to be fully answered.  

   On November 9, Fair Finance Watch and Inner City Press have begun a call to block Brooks from handing out any more national bank charters between now and January 20 - such charters would be illegitimate, gifts by a lame duck. How much more so this: the Senate majority says it is moving forward to have a vote on a long-pending Federal Reserve Board nominee, Judy Shelton. Even in September 2020 she was said to not have the votes for confirmation.  We'll have more on this.

On July 13 Fair Finance Watch filed with the OCC, including this: "July 13, 2020
 Office of the Comptroller of the Currency  DC Comptroller Brooks and Mr. Lybarger, Deputy Comptroller for Licensing  & Northeastern District Office 
 Re: Timely First Comment on SoFi's reported application to the OCC to get into banking 

Dear Mr. Lybarger, Ms. Cummings and others in the OCC:  This is a timely first comment opposing and requesting an extension of the required OCC's public comment period on reported proposal by SoFi to get a national bank charter.  

    This is a major proposal, by a fintech in which SoftBank has a large stake. Yet, it is not yet on the OCC's website, where as of July 13 the most recent Weekly Bulletin cuts on on July 4. The only charter application listed as open for comment is Monzo Bank; the New Bank application link does not work. So, any comment period will have be be extended. This is a request for the complete application, all portions that the OCC after review does not find withholdable under FOIA. 

     Inner City Press / Fair Finance Watch opposed SoFi's previous, suspended attempt to get into banking. Since then the questions have only grown.  

    For now, we note that Inner City Press asked the OCC's FOIA unit for a copy of Comptroller Brooks' conflict of interest list with fintechs but has yet to receive it. Pending receipt, we ask that Acting Comptroller Brooks be recused from this application and that you confirm this in writing.

      As to SoftBank, the dispute regarding another of its holdings, WeWork, portends the type of problems that regulators like the OCC are directed to keep out of, not invite into, the banking system.

     For the above reasons, including the ongoing COVID-19 pandemic lockdowns and restrictions, the comment period should not yet start or should extended, until in person public hearings can be held, and Comptroller Brooks' should be recused pending/and his conflict of interest list should be released."

And now on October 28, Brooks' OCC has rubber stamped the application, stating "The OCC received one comment related to the Proposed Bank’s plans for complying with the Community Reinvestment Act (CRA, 12 USC 2901 et seq.), asserting, among other things, that the CRA plan included with the application only provides an outline of proposed activities without sufficient details. The OCC also received one other comment opposing approval of the charter application for reasons not related to the CRA and requesting an extension of the comment period. The CRA requires that the OCC take a national bank’s or federal savings association’s (bank) CRA record into account when evaluating an application for a deposit facility. 12  SoFi Bank, National Association, Cottonwood Heights, Utah (proposed) OCC Control Nos. 2020-WE-Charter-315294 and 2020-WE-Waiver-315536  2  USC 2903(a)(2). An application for a deposit facility is defined to mean, among other things, “a charter for a national bank or federal savings and loan association.” 12 USC 2902(3)(A). The CRA regulations require that “[a]n applicant... for a national bank charter must submit with its application a description of how it will meet its CRA objectives, if applicable.” 12 CFR 25.02(b). The Proposed Bank’s charter application included a CRA plan that provided an initial description of how it proposes to help meet the credit needs of its community. With regard to the commenter’s concerns about the sufficiency of the Proposed Bank’s CRA plan, the CRA requires the OCC to consider a proposed insured bank’s description of how it will meet the credit needs of its community in considering a charter application. 12 CFR 25.02(b). The OCC expects that organizers of a bank will begin to develop a CRA plan during the charter application phase; however, the OCC does not expect a bank to have a fully developed plan at this stage. The CRA plan should be finalized after a bank has received preliminary conditional approval from the OCC, but prior to final approval of the charter application. The Bank has demonstrated in its charter application and through discussions with OCC staff that it understands the requirements of the CRA and has begun to develop a CRA plan. The Bank is considering a strategic plan pursuant to 12 CFR 25.18, and the OCC will work with the Bank in the development of a strategic plan if this alternative is chosen." Rush job, rubber stamp. Watch this site.

November 9, 2020

From the Fed last week: "While this report is focused on safety and soundness initiatives, it is also important to note that on September 21, 2020, the Board issued an Advance Notice of Proposed Rulemaking to modernize the regulations to implement the Community Reinvestment Act with a 120-day comment period.6 6 See Board of Governors of the Federal Reserve System, “Federal Reserve Board Issues Advance Notice of Proposed Rulemaking on an Approach to Modernize Regulations That Implement the Community Reinvestment Act,” news release, September 21, 2020, https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200921a.htm

yeah...

November 2, 2020

  Amid the exposed failure of the SARs system, the Federal Reserve has come out with a decidedly uninspiring proposal: "The Financial Crimes Enforcement Network (FinCEN) and the Federal Reserve Board today invited comment on a proposed rule that would amend the recordkeeping and travel rule regulations under the Bank Secrecy Act. FinCEN and the Board, pursuant to their shared authority, are proposing amendments to the recordkeeping rule jointly, while FinCEN, pursuant to its sole authority, is proposing amendments to the travel rule.  Under the current recordkeeping and travel rule regulations, financial institutions must collect, retain, and transmit certain information related to funds transfers and transmittals of funds over $3,000. The proposed rule lowers the applicable threshold from $3,000 to $250 for international transactions. The threshold for domestic transactions remains unchanged at $3,000." Oh.

October 26, 2020

Banco Bradesco Over Inner City Press Protest OKed Now Appeal Not Shown To Fed Board

By Matthew R. Lee, Exclusive

SOUTH BRONX, Oct 20 – Amid escalating attacks on the U.S. Community Reinvestment Act, Inner City Press / Fair Finance Watch back in August filed comments under the CRA opposing Banco Bradesco's application to acquire BAC Florida, see below.

 Amid the Coronavirus pandemic, it has continued to appear that the Federal Reserve is churning forward to try to rubber stamp a bank merger. On April 7 the Fed asked Banco Bradesco's New York law firm to supplement the record with how it is dealing with current economic situation. On April 24 the bank's law firm Shearman & Sterling sent an answer to the Fed - with the entire Covid section, as sent as required to Fair Finance Watch and Inner City Press, entirely redacted. Inner City Press FOIA-ed that, then was asked to narrow the request.

 So S&S submitted another filing, with even the name of the exhibits redacted. As of June 7, the Fed simply extended its time to reply.

 On October 7 the Federal Reserve rubber stamped the troubled and troubling merger, stating in part that "A commenter objected to the proposal and alleged disparities in the number of home purchase loans made by BAC Bank to African Americans and Hispanics, as compared to Asians, in the New York City Metropolitan Statistical Area (“New York City MSA”), based on data that BAC Bank reported under the Home Mortgage Disclosure Act of 1975 (“HMDA”) for its 2017 mortgage-related lending activities. 29 In  27 12 U.S.C. § 2903. 28 Bradesco’s New York branch is not authorized to take insured deposits and is not subject to the CRA. 29 12 U.S.C. § 2801 et seq. - 12 - addition, the commenter asserted that BAC Bank denied 100 percent of home purchase applications from Hispanics in the New York City MSA based on the bank’s 2017 HMDA data. The commenter also alleged disparities in the number of home purchase loans made by BAC Bank to African Americans as compared to Whites in the Miami, Florida MSA, based on 2017 HMDA data. Furthermore, the commenter alleged that the proposal does not have a public benefit, including under the CRA, and that Bradesco plans to acquire BAC Bank to disproportionately serve affluent clients. BAC Bank’s Business and Applicants’ Response to the Public Comments BAC Bank offers a variety of products and services in the areas of personal banking, wealth management, corporate banking, institutional banking, and real estate financing. BAC Bank serves domestic and international customers, and, as previously noted, the bank’s sole deposit-taking office is located in Florida. In response to the public comments, Bradesco asserts that the fair lending and CRA records of BAC Bank do not support a conclusion that the bank has engaged in improper lending practices." Yeah.

 So on October 15, we filed a timely request for reconsideration: "Re: Timely Request for Reconsideration of FRB approval, with information about COVID-19 Impacts withheld and BAC lending record ignored, of Banco Bradesco to acquire BAC Florida  Dear Chair Powell"   This is a timely request for reconsideration of the above-captioned application. As you may know, Inner City Press / Fair Finance Watch timely opposed the application on CRA and then other grounds, including the need to publicly disclose the financial irregularities of Banco Bradesco and the impact of COVID-19 on this proposed transaction.      All of these records were withheld, and BAC's CRA and fair lending records was ignored, to deliver up an approval on the applicant's timeline. This "servicing" of the industry cannot continue on this timely request, which the full Board should consider at an in person meeting.    As we stated in August 2019, this is a proposal by a bank in Brazil where authorities are reviewing the bank for corruption, to buy a US bank with a disparate lending record in order to use it to serve disproportionately the affluent. There is no public benefit; the application should be denied...  We submitted a FOIA request for all of the redacted information - in fact, it should have been provided forthwith under the Ex Parte Rules. But it never was."

  On October 20 Inner City Press got a voice mail then an email stating that the request for reconsideration had not even gone to the insulated Board members (two seats are vacant), but was denied by the Fed's General Counsel. We'll have more on this.

October 19, 2020

Banco Bradesco Over Inner City Press Protest Rubber Stamped So Filing to Federal Reserve

By Matthew R. Lee, Exclusive

SOUTH BRONX, Oct 15 – Amid escalating attacks on the U.S. Community Reinvestment Act, Inner City Press / Fair Finance Watch back in August filed comments under the CRA opposing Banco Bradesco's application to acquire BAC Florida, see below.

 Amid the Coronavirus pandemic, it has continued to appear that the Federal Reserve is churning forward to try to rubber stamp a bank merger. On April 7 the Fed asked Banco Bradesco's New York law firm to supplement the record with how it is dealing with current economic situation. On April 24 the bank's law firm Shearman & Sterling sent an answer to the Fed - with the entire Covid section, as sent as required to Fair Finance Watch and Inner City Press, entirely redacted. Inner City Press FOIA-ed that, then was asked to narrow the request.

 So S&S submitted another filing, with even the name of the exhibits redacted. As of June 7, the Fed simply extended its time to reply.

 Now on October 7 the Federal Reserve has rubber stamped the troubled and troubling merger, stating in part that "A commenter objected to the proposal and alleged disparities in the number of home purchase loans made by BAC Bank to African Americans and Hispanics, as compared to Asians, in the New York City Metropolitan Statistical Area (“New York City MSA”), based on data that BAC Bank reported under the Home Mortgage Disclosure Act of 1975 (“HMDA”) for its 2017 mortgage-related lending activities. 29 In  27 12 U.S.C. § 2903. 28 Bradesco’s New York branch is not authorized to take insured deposits and is not subject to the CRA. 29 12 U.S.C. § 2801 et seq. - 12 - addition, the commenter asserted that BAC Bank denied 100 percent of home purchase applications from Hispanics in the New York City MSA based on the bank’s 2017 HMDA data. The commenter also alleged disparities in the number of home purchase loans made by BAC Bank to African Americans as compared to Whites in the Miami, Florida MSA, based on 2017 HMDA data. Furthermore, the commenter alleged that the proposal does not have a public benefit, including under the CRA, and that Bradesco plans to acquire BAC Bank to disproportionately serve affluent clients. BAC Bank’s Business and Applicants’ Response to the Public Comments BAC Bank offers a variety of products and services in the areas of personal banking, wealth management, corporate banking, institutional banking, and real estate financing. BAC Bank serves domestic and international customers, and, as previously noted, the bank’s sole deposit-taking office is located in Florida. In response to the public comments, Bradesco asserts that the fair lending and CRA records of BAC Bank do not support a conclusion that the bank has engaged in improper lending practices." Yeah.

 Now on October 15, we have filed this timely request for reconsideration: "Re: Timely Request for Reconsideration of FRB approval, with information about COVID-19 Impacts withheld and BAC lending record ignored, of Banco Bradesco to acquire BAC Florida  Dear Chair Powell"   This is a timely request for reconsideration of the above-captioned application. As you may know, Inner City Press / Fair Finance Watch timely opposed the application on CRA and then other grounds, including the need to publicly disclose the financial irregularities of Banco Bradesco and the impact of COVID-19 on this proposed transaction.      All of these records were withheld, and BAC's CRA and fair lending records was ignored, to deliver up an approval on the applicant's timeline. This "servicing" of the industry cannot continue on this timely request, which the full Board should consider at an in person meeting.    As we stated in August 2019, this is a proposal by a bank in Brazil where authorities are reviewing the bank for corruption, to buy a US bank with a disparate lending record in order to use it to serve disproportionately the affluent. There is no public benefit; the application should be denied...  We submitted a FOIA request for all of the redacted information - in fact, it should have been provided forthwith under the Ex Parte Rules. But it never was." We'll have more on this.

October 12, 2020

Federal Reserve Banco Bradesco Q&A After Inner City Press Protest Leads To Rubber Stamp

By Matthew R. Lee, Exclusive

SOUTH BRONX, SDNY, Oct 7 – Amid escalating attacks on the U.S. Community Reinvestment Act, Inner City Press / Fair Finance Watch back in August filed comments under the CRA opposing Banco Bradesco's application to acquire BAC Florida, see below.

 Amid the Coronavirus pandemic, it has continued to appear that the Federal Reserve is churning forward to try to rubber stamp a bank merger. On April 7 the Fed asked Banco Bradesco's New York law firm to supplement the record with how it is dealing with current economic situation. On April 24 the bank's law firm Shearman & Sterling sent an answer to the Fed - with the entire Covid section, as sent as required to Fair Finance Watch and Inner City Press, entirely redacted. Inner City Press FOIA-ed that, then was asked to narrow the request.

 So S&S submitted another filing, with even the name of the exhibits redacted. As of June 7, the Fed simply extended its time to reply.

 Now on October 7 the Federal Reserve has rubber stamped the troubled and troubling merger, stating in part that "A commenter objected to the proposal and alleged disparities in the number of home purchase loans made by BAC Bank to African Americans and Hispanics, as compared to Asians, in the New York City Metropolitan Statistical Area (“New York City MSA”), based on data that BAC Bank reported under the Home Mortgage Disclosure Act of 1975 (“HMDA”) for its 2017 mortgage-related lending activities. 29 In  27 12 U.S.C. § 2903. 28 Bradesco’s New York branch is not authorized to take insured deposits and is not subject to the CRA. 29 12 U.S.C. § 2801 et seq. - 12 - addition, the commenter asserted that BAC Bank denied 100 percent of home purchase applications from Hispanics in the New York City MSA based on the bank’s 2017 HMDA data. The commenter also alleged disparities in the number of home purchase loans made by BAC Bank to African Americans as compared to Whites in the Miami, Florida MSA, based on 2017 HMDA data. Furthermore, the commenter alleged that the proposal does not have a public benefit, including under the CRA, and that Bradesco plans to acquire BAC Bank to disproportionately serve affluent clients. BAC Bank’s Business and Applicants’ Response to the Public Comments BAC Bank offers a variety of products and services in the areas of personal banking, wealth management, corporate banking, institutional banking, and real estate financing. BAC Bank serves domestic and international customers, and, as previously noted, the bank’s sole deposit-taking office is located in Florida. In response to the public comments, Bradesco asserts that the fair lending and CRA records of BAC Bank do not support a conclusion that the bank has engaged in improper lending practices." Yeah. We'll have more on this.

October 5, 2020

Fed Inaction As Amid PPP Abuse Lenders Like Live Oak Bank Issue Prurient Denial To Inner City Press Data Q

By Matthew Russell Lee, Patreon
BBC - Guardian UK - Honduras - CJR - PFT

SDNY COURT / SOUTH BRONX, Oct 1 –     Amid the COVID-19 pandemic, fair lending and the Community Reinvestment Act are taking a back seat, or worse. Some banks to which CRA applies are excluding smaller businesses and those in communities of color. And some banks bragging about the PPP loans won't provide any information - we are Pressing.

   Inner City Press / Community on the Move has begun contacting both banks and non-banks for their Paycheck Protection Program data. Without yet getting into the full results, note that Inner City Press asked Live Oak Bank, twice: "On behalf of Inner City Press / Community on the Move and its Fair Finance Watch project, and in my personal capacity, this is a formal request for Live Oak's full CRA Public File and pressingly for the following with regard to the Paycheck Protection Program (PPP) and Economic Injury Disaster Loans (EIDL), in light of the COVID-19 pandemic and the need for this information:  1. How many loans has Live Oak made pursuant to the programs?  2. What is the total dollar amount of loans made pursuant to the program  3. What is the average loan size? ... 9. What percentage of your PPP loans are to borrowers with a previous borrowing relationship with your institution?"

  Their SVP for communications sent only the CRA file, performance evaluation and strategic plan - no date. Now after months of non response on data by Live Oak Bank, on October 1 came this:

"Thank you for your interest in Live Oak Bank Based on your responses, our loan programs are not a fit for your business at this time. Some of the most common reasons for this are listed below:   Loan amount is below our minimum   Business is not based in the United States   FICO credit score does not meet our minimum requirements   Prior bankruptcy   Prior loss to creditors or government   Pending legal action   Presently suspended, debarred, proposed for debarment, declared ineligible or voluntarily excluded from participation in this transaction by any Federal department or agency   Revenues derived from gambling, loan packaging, or from the sale of products or services, or the presentation of any depiction, displays or live performances, of a prurient sexual nature."
Oh really... We'll have more on this.

Meanwhile the Fed is pushing forward to approve bank merger applications, like Banco Bradesco - BAC which Fair Finance Watch has been opposing

September 28, 2020