Inner City Press: Federal Reserve Beat (FOIA, FOMC, CRA, Predatory Finance)

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November 12, 2018

Inner City Press has had to FOIA the Fed: "This is a FOIA request for the all withheld portions of the applications and applications additional information submitted by Synovus to acquire FCB Financil including but not limited to presumptively mis-labeled “Confidential” exhibits as as “Confidential” Exhibit 1 to Synovus' October 31 response, which appears to be personnel to be integrated into fair lending, while Synovus discloses its own staff's names..". This is scam.

November 5, 2018

Synovus has told the Fed, after Fair Finance Watch's protest, that "since the 2017 CRA Performance Evaluation, a Nashville area branch that was previously classified as being located in a middle income area was reclassified to being located in a moderate income branch." Wow, that is some great performance.

October 29, 2018

The Fed has written to Synovus again: "In connection with the application filed under section 3 of the Bank Holding Company Act by
Synovus Financial Corp. (“Synovus Financial”), Columbus, Georgia, to merge with FCB
Financial Holdings, Inc. (“FCB Financial Holdings”) and thereby indirectly acquire Florida
Community Bank, N.A. (“Florida Community Bank”), both of Weston, Florida, and the
application filed under section 18(c) of the Federal Deposit Insurance Act by Synovus Bank,
Columbus, Georgia, to merge with Florida Community Bank, the following additional
information is requested. Supporting documentation should be provided as appropriate.
1. In the submission dated October 19, 2018 (“AI Response”), in response to question 6 of
the Board’s October 16, 2018 additional information request (“AI Request”), Synovus
Financial represented that the CRA and consumer compliance-related (including fair
lending) governance and oversight systems described in the AI Response would be
adopted by the combined bank upon consummation. Indicate on a pro forma basis, the
key individuals who would be responsible for providing such oversight, including
management, of these programs, and their qualifications. For each key individual,
specify the organization he or she currently works for (e.g., Synovus Bank, Florida
Community Bank, or another entity), as well as his or her current position and title at that
organization. Finally, indicate to what extent Synovus Bank’s consumer compliance
(including fair lending) program would be adopted at the merged bank following
consummation of the proposed transaction.
2. Question 1 of the AI Request included a request for an “update on Synovus Bank’s
[CRA] activities since its November 2017 CRA Performance Evaluation and Florida
Community Bank’s CRA activities since its March 2017 CRA Performance Evaluation,
in general, and in particular with respect to the assessment areas listed as a concern by
either commenter” to the extent that information had not already been provided in the
application or in any other submission. Provide this update with respect to small business
lending in the following areas (and their corresponding assessment areas) raised as a
concern "
October 22, 2018

Cadence Bank Bid For State Bank in Georgia Challenged by Fair Finance Watch to Fed Revolving Door

By Matthew R. Lee, Video, 7/31 story

SOUTH BRONX, October 18 – Cadence Bancorporation which has a disparate lending record has applied to buy State Bank in Georgia, and has seemingly jumped the gun before having the required Federal Reserve Board approval. On October 18, Fair Finance Watch submitted a timely comment to the Federal Reserve Board in Washington, below - and got back a copy of a letter from the Federal Reserve Bank of Dallas forwarding its comment to Cadence's outside counsel at Wachtell Lipton -- Patricia Robinson, who used to be with the Fed's Legal Division. Inner City Press will have more on that. For now, here's from FFW's comment: "This is a request for a full copy of, and a 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

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.”

Inner City Press is also concerned about this statement imply gun-jumping, in the investors' call announcing the proposal, here.

Paul Murphy: “Oh boy, you’re right. It’s not in the model. It’s significant. I mean, there is just a lot of overlap. I’ve got a prospect for AloStar. I’m going to see them this afternoon. We can start it on a great potential new piece of business for them today. And there will be more and more of that.”

ICP is requesting evidentiary hearings and that this proposed acquisition, on the current record, not be approved. There is no public benefit."

October 15, 2018

From a Fed approval order last week : "The HHI in this market would increase by 261 points, from 1604 to 1865."

October 8, 2018

Allan Kamensky
Synovus Financial Corporation
General Counsel & Secretary
1111 Bay Avenue, Suite 500
Columbus, Georgia 31901
Dear Mr. Kamensky:
This refers to the application by (1) Synovus Financial Corp., Columbus, Georgia to acquire
FCB Financial Holdings, Inc. and thereby acquire Florida Community Bank, N.A., both of
Weston, Florida (Bank), pursuant to section 3(a)(3) and 3(a)(5) of the Bank Holding Company
Act; and (2) Synovus Bank, Columbus, Georgia to merge with Bank, pursuant to section 18(c) of
the Federal Deposit Insurance Act. Enclosed is a copy of a letter received from Fair Finance
Watch and Inner City Press commenting on the application.
Neither the Bank Holding Company Act nor the Board's Regulation Y requires a response from
Applicant. However, if you wish to respond, your comments should be received by this Reserve
Bank within eight business days from the date of this letter.

October 1, 2018

Now

The Federal Reserve Board on Thursday announced the termination of the enforcement action listed below:

Presidential Holdings, Inc., Bethesda, Maryland
Supervisory Agreement, issued by the Office of Thrift Supervision, dated May 3, 2010 (PDF)
Terminated September 25, 2018

September 24, 2018

President Donald J. Trump today announced his intent to nominate the following individuals to key positions in his Administration:
Jean Nellie Liang of Illinois, to be a Member of the Board of Governors of the Federal Reserve System for the remainder of a 14-year term expiring January 31, 2024. Ms. Liang is a Senior Fellow in Economic Studies at the Brookings Institution and a Visiting Scholar at the International Monetary Fund’s Monetary and Capital Markets Department. Previously, Ms. Liang served as Director of the Division of Financial Stability at the Board of Governors of the Federal Reserve System. Ms. Liang is a member of the Congressional Budget Office’s Panel of Economic Advisors and was a lecturer at the Yale School of Management. She earned her B.A. in economics from the University of Notre Dame and Ph.D. from the University of Maryland.
She wrote about subprime...

September 17, 2018

The Federal Reserve is, for now, withholding CRA information under this statement, "Exhibit H include information not disclosed to the general public. Competitors of Applicant should not be allowed access to this information because Applicant cannot access its competitors' strategic practices. This information could provide competitors with valuable insights into Applicant's business focus and plan of operations." We'll have more on this.

September 10, 2018

From Fed Reserve Bank: If you seek any “confidential” information regarding the application under the Freedom of Information Act (“FOIA”), you must submit a request to the Board’s Freedom of Information Office.

Inner City Press: Thanks. While I'm thinking it's why you put quotation marks around "Confidential," we'd be seeking all information that the applicant mis-characterized as withholdable under FOIA. Does your Federve Bank review the propriety of the applicant's argument that portions are withholdable under FOIA, such as in this case "Confidential" Exhibits D and E in their entirety?

Fed: Dear Mr. Lee: Applications staff reviewed the exhibits designated as “confidential” by the applicant and considered these exhibits to contain nonpublic information. If you seek copies of confidential information under the Freedom of Information Act, you must submit a request to the Board’s Freedom of Information Office, as described in my earlier email.

"Contain"? So segregable information is not released? FOIA-lite?

September 3, 2018

So will the Federal Reserve end up following Joe Otting in trashing community reinvestment? Does the Fed remember how Otting gamed their system when his OneWest Bank was selling itself to CIT? We'll see.

August 27, 2018

Bloomberg says "Have U.S. companies gotten too big and too powerful? Does growing concentration -- more market share in fewer corporate hands -- explain why wage growth has stagnated, income inequality has gotten worse and investment and innovation have fallen behind? These are some of the hottest questions in economic circles these days, and the U.S. Federal Reserve is looking for answers. As central bankers start to meet in Jackson Hole, Wyoming, for the Federal Reserve Bank of Kansas City’s annual symposium, it will be the main topic." But the Fed has allowed and encouraged the "concentration" in the financial services sector...

August 20, 2018

Last straw: The Federal Reserve has ended its "enforcement action" against HSBC for money laundering - which included for murderous drug gangs. Plus ca change...

August 13, 2018

From the Fed, Aug 10: "The Federal Reserve Board on Friday announced an $8.6 million fine against Citigroup for the improper execution of residential mortgage-related documents.

The $8.6 million penalty addresses the deficient execution and notarization of certain mortgage-related affidavits prepared by a subsidiary, CitiFinancial. The improper practices occurred in 2015 and were corrected. CitiFinancial exited the mortgage servicing business in 2017.

Also on Friday, the Board announced the termination of an enforcement action from 2011 against Citigroup and CitiFinancial related to residential mortgage loan servicing. The termination of this action was based on evidence of sustainable improvements." What improvements?

August 6, 2018

On August 3 the Fed went Finnish: "Nordea Bank Sweden has established controls and procedures for the proposed branch to
ensure compliance with U.S. law and for its operations in general, and these will be continued at Nordea Finland following the Merger.
Finland is a member of the Financial Action Task Force and subscribes to its recommendations on measures to combat money laundering and international terrorism. "

July 30, 2018

The Fed says, "The Federal Reserve recognizes that most banks want to serve all consumers and few
would intentionally choose to avoid minority areas. Nonetheless, some banks treat minority
neighborhoods less favorably.
For example, redlining risk may increase because of a failure to market products or locate
branches in the minority areas in the bank’s market, or because of changes in the bank’s
business model, such as through mergers, acquisitions, or new lending patterns. The Federal
Reserve conducts a risk-focused review of potential redlining risk, consistent with the
2009 Interagency Fair Lending Examination Procedures.5
Below are the key risk factors considered by the Federal Reserve in the redlining review as
well as some practical steps controls for mitigating risk.
Community Reinvestment Act (CRA) assessment area. Federal Reserve examiners
review whether the bank’s assessment areas appear to inappropriately exclude majority
minority census tracts.
Lending record. Federal Reserve examiners review whether the bank’s record of Home
Mortgage Disclosure Act (HMDA) mortgage lending and/or CRA small business lending
shows statistically significant disparities in majority minority census tracts when compared
with similar lenders.
Branching strategy. Federal Reserve examiners review whether the bank’s strategy for
branch or loan production office locations appears to exclude majority minority census
tracts. Marketing and outreach strategy. Federal Reserve examiners review whether the
bank’s marketing and outreach strategy appears to treat majority minority census tracts
less favorably.
Complaints. Federal Reserve examiners review whether any complaints by consumers
or consumer advocates raise concerns that the bank treats certain geographies differently
on a prohibited basis." we'll see...

July 23, 2018

On July 19, the Federal Reserve Board announced the termination of the enforcement action against Community Banks of Georgia, Inc., Jasper, Georgia...

July 16, 2018

Now the Fed has terminated its enforcement action against UNITED BANK LIMITED, Karachi, Pakistan and UNITED BANK LIMITED's NY branch.. Speaking of NY branches, see here...

July 9, 2018

So the Fed last week ended an enforcement against Amboy Bancorporation - from 2009...

July 2, 2018

Even the Federal Reserve had to admit that Deutsche Bank again failed the stress test. Now what - Commerzbank? Watch this site.

June 25, 2018

Check out the stress tests: https://www.federalreserve.gov/publications/files/2018-dfast-methodology-results-20180621.pdf

June 18, 2018

As Federal Reserve Rubber Stamps Merger By Ameris Jerome Powell Omits Regulatory Duties

By Matthew R. Lee, Patreon

NEW YORK, June 14 – The bank with the worst record in the United States for gouging consumers with overdraft fees, Ameris, has nevertheless gotten a rubber stamp approval from the Federal Reserve Board, to buy Hamilton State Bancshares in Georgia. Fair Finance Watch submitted formal opposition with the Fed, citing the gouging, Ameris' disparate mortgage lending record in Atlanta, Georgia and Florida, and the Community Reinvestment Act. See below. Earlier this year Ameris admitted in a responses that one of its filed application was false when it said it would continue the CRA policies of Atlantic - see full response on Patreon, here, question 3. Still, the Fed's June 13 order blandly recites " a commenter objected to the proposal on the basis of alleged disparities in the number of home mortgage loans made by Ameris Bank to, and/or in the rate of denials for home mortgage applications from, African Americans and/or Hispanics, as compared to whites, in Atlanta, Georgia; Jacksonville, Florida; and Tallahassee, Florida, based on data reported under the Home Mortgage Disclosure Act of 1975 (“HMDA”). The commenter also alleged that Ameris Bank engaged in predatory collection of overdraft fees and expressed concern over Ameris’s recent record of mergers and acquisitions." The concerns continue to grow. Inner City Press requested records under the Freedom of Information Act - but the Fed these days can take months to respond. On June 13, alongside the Ameris approval, Fed chair Jerome Powell answered a pre-picked question that the Fed's job involves interest rates and maximum employment. He did not mention the Fed's bank regulatory responsibilities. Seems he thinks someone else is doing that - but that someone is no longer the Consumer Financial Protection Bureau, nor the OCC.

June 11, 2018

Now there's a 60 day comment period on what's called the "proposal to simplify and tailor 'Volcker rule,'" here.
June 4, 2018

Weakening of Volcker Rule Promoted By Fed's Powell and Quarles Without Wells Fargo Recusal

By Matthew R. Lee, Audio

NEW YORK, May 30 – The US Federal Reserve Board, with more than half of its seats vacant and one of its three Governors conflicted out on Wells Fargo now wants to weaken the so-called Volcker Rule, for the benefit of the largest banks. This is the same Federal Reserve which recently delayed for months in responding to Inner City Press' request under the Freedom of Information Act, and which has taken to rubber stamping mergers even by banks with interest rates described as usurious, like Ameris Bank. Fed Chair Jerome Powell said, "Firms that do more modest amounts of trading will face fewer requirements." Randal K. Quarles, the Governor ostensibly recused on Wells Fargo which has an interest in the Volcker Rule said "I view this proposal as an important milestone in comprehensive Volcker rule reform, but not the completion of our work." There is a commnt period, here. We'll have more on this. When the International Monetary Fund reviews developed countries' banking sectors, particularly in Europe, some banks' participation in predatory lending gets over looked. Consider Deutsche Bank, and the IMF's May 14 assessment of the Germany banking sector, which Inner City Press published below when it was just out from under embargo. Now consider the US Federal Reserve's solicitude, expressed by new Governor Randal Quarles: "Willingness by the United States to reconsider its calibration may prompt other jurisdictions to do the same, which could better the prospects of successful resolution for both foreign G-SIBs operating in the United States, and for U.S. G-SIBs operating abroad... Any such balance is likely to be improvable with experience, reflection, and debate. We are interested in views from the firms and the public on how the regimes can be improved." This while draft legislation pends that would allow global banks to low-ball their US holdings, and US Comptroller of the Currency Joseph Otting targets the Community Reinvestment Act of 1977. We'll have more on this. From the IMF on May 14 "The German banking and life insurance sectors should accelerate their restructuring to bolster profitability and reduce risks. In the banking sector, the regulatory capital ratio has increased, but the cost-to-income ratio and leverage remain high. The high cost structure, alongside low net interest margins, provisions for compliance violations, and the need to adjust to the new regulatory environment, continue to weigh on profitability. Restructuring is ongoing in the banking sector, but the process must be accelerated through faster implementation of restructuring plans, continued development of fee-based income, and further consolidation. In the life insurance sector, low interest rates have dented solvency ratios, and further progress is needed to reduce reliance on guaranteed return products. In this context, supervisory attention to interest rate risk and progress in implementing restructuring plans both in banking and insurance should continue." What about abuse of consumers, participation in predatory lending schemes and other abuses? What about Greece? What about Deutsche bank as the riskiest bank? May 28, 2018

We note that in Federal Reserve governor Brainard's speech on CRA there is no mention of enforcement of CRA, or of the word "merger" or "expansion" or "application" -- we'll have more on this. https://www.federalreserve.gov/newsevents/speech/brainard20180518a.htm

May 21, 2018

De-Regulation of Global Banks Pitched by Fed's Quarles After As IMF Ignores Predatory Deutsche

By Matthew R. Lee, Audio

NEW YORK, May 14 – When the International Monetary Fund reviews developed countries' banking sectors, particularly in Europe, some banks' participation in predatory lending gets over looked. Consider Deutsche Bank, and the IMF's May 14 assessment of the Germany banking sector, which Inner City Press published below when it was just out from under embargo. Now consider the US Federal Reserve's solicitude, expressed by new Governor Randal Quarles: "Willingness by the United States to reconsider its calibration may prompt other jurisdictions to do the same, which could better the prospects of successful resolution for both foreign G-SIBs operating in the United States, and for U.S. G-SIBs operating abroad... Any such balance is likely to be improvable with experience, reflection, and debate. We are interested in views from the firms and the public on how the regimes can be improved." This while draft legislation pends that would allow global banks to low-ball their US holdings, and US Comptroller of the Currency Joseph Otting targets the Community Reinvestment Act of 1977. We'll have more on this. From the IMF on May 14 "The German banking and life insurance sectors should accelerate their restructuring to bolster profitability and reduce risks. In the banking sector, the regulatory capital ratio has increased, but the cost-to-income ratio and leverage remain high. The high cost structure, alongside low net interest margins, provisions for compliance violations, and the need to adjust to the new regulatory environment, continue to weigh on profitability. Restructuring is ongoing in the banking sector, but the process must be accelerated through faster implementation of restructuring plans, continued development of fee-based income, and further consolidation. In the life insurance sector, low interest rates have dented solvency ratios, and further progress is needed to reduce reliance on guaranteed return products. In this context, supervisory attention to interest rate risk and progress in implementing restructuring plans both in banking and insurance should continue." What about abuse of consumers, participation in predatory lending schemes and other abuses? What about Greece? What about Deutsche bank as the riskiest bank? May 14, 2018

On Ameris, the Fed recited "a commenter objected to the proposal on the basis of alleged disparities in the number of home mortgage loans to and/or in the rate of denials for home mortgage applications from African Americans and/or Hispanics, as compared to whites,
in Atlanta, Georgia; Jacksonville, Florida; and Tallahassee, Florida, based on data reported under the Home Mortgage Disclosure Act of 1975. The commenter also alleged that Ameris Bank engaged in predatory collection of overdraft fees and expressed concern over Ameris’s recent record of mergers and acquisitions and planned branch closures." That's right - and we'll stay on this.

May 7, 2018

On May 1, the Fed announced " Federal Reserve Board on Tuesday announced that it has fined The Goldman Sachs Group, Inc., $54.75 million for the firm's unsafe and unsound practices in its foreign exchange (FX) trading business." Sounds more like April 1, April Fool's Day - Goldman doesn't even flinch at this size of fine...

April 30, 2018

The Treasury Department recommends that the Federal Reserve (and FDIC) follow the OCC is removing one of the only teeth the CRA, denying applications after a needs to improve CRA rating. The Fed better not...

April 23, 2017

A Fed proposal introduces a stress capital buffer (SCB) a concept designed to produce capital requirements for large banking organizations that are firm-specific and risk-sensitive. “Our regulatory measures are most effective when they are as simple and transparent as possible, and this proposal significantly simplifies our capital regime while maintaining its strength,” the Fed’s Vice Chairman for Supervision Randal Quarles said. “It is a good example of how our work can be done more efficiently and effectively, and in a way that bolsters the resiliency of the financial system.” Quarles has recused himself from decisions on Wells Fargo...

April 16, 2018

The Federal Reserve Bank of Atlanta has asked some questions of Ameris, on Hamilton - without addressing or acting on Ameris' false statements in the other still pending proceeding. We'll have more on this.

April 9, 2018

At NY Fed, Dudley Replaced By SF's Williams, Who Oversaw Wells Fargo's Many Frauds

By Matthew R. Lee, Patreon

NEW YORK, April 3 – After much focus on who at the Federal Reserve Bank of New York should replace outgoing William Dudley, on April 3 the Fed did the expected, picking insider John Williams from the San Fransisco Fed who oversaw Wells Fargo's many frauds. We'll have more on this. This comes days after Dudley himself on March 30 misrepresented the bill S.2155 as offering relief to "small banks" -- actually, it's banks up to $250 billion in assets, and foreign mega-banks larger than that. Dudley's misleading comment came on the New York public radio show of Brian Lehrer, who erroneously said that the bill has been enacted "by Congress" when it has only passed the Senate. Meanwhile everyone from Mayor Bill de Blasio to Senator Kirsten Gillibrand has been saying the Fed's process for naming the President of its Reserve Bank is not transparent enough. Now that the expected Williams has been picked, what next?

April 1, 2018

... Collusion between payday lenders and national banks has been invited by US Comptroller of the Currency Joseph Otting, under whose watch OneWest Bank generated fake public comments urging approval of its merger with CIT. Otting has lifted the 2002 consent order prohibiting ACE Cash Express from "partnering" with national banks. Speaking earlier in, where else, Las Vegas Otting said, "We think there’s a big market there that’s underserved, that really has the ability to be served by capital going forward." When he was selling off OneWest, those whose e-mail addresses and identities were stolen in order to promote the merger were thanked by David Finnegan of the OCC Otting now runs. Finnegan then asked OneWest's and Otting's lawyer Stephen M. Salley at Sullivan & Cromwell to explain. We'll have more on this - there's a lot of explaining to do. On March 14 as what was presented as a community bank regulatory relief bill was passed in the U.S. Senate 67-31 as S.2155, along with undercutting fair lending enforcement the bill would provide particular benefit to the US subsidiaries of some of the largest global banks. These include at least one which helped evade North Korea sanctions: Bank of Tokyo - Mitsubishi...

March 26, 2018

Fed-speak / Fed - spun “A commenter objected to the proposal alleging that, based on data reported under the Home Mortgage Disclosure Act of 1975 (“HMDA”), Charles Schwab Bank lent only to white borrowers with incomes above 120 percent of the area median income in the Reno, Nevada, Metropolitan Statistical Area..The commenter also criticized the workplace benefit plans of Charles Schwab, noting that employees of Charles Schwab had filed a lawsuit alleging that the 401(k) plans of Charles Schwab have expensive fees and poor performance that have benefited Charles Schwab at the expense of its employees. See Severson v. Charles Schwab Corp., No. 4:17-cv-00285-CW (N.D. Cal. 2017). Charles Schwab has denied any wrongdoing. The allegations regarding the performance of 401(k) plans and fees charged by plan sponsors are matters that are reviewed under the Employee Retirement Income Security Act of 1974. See 29 U.S.C. § 1001 et seq. The allegations are currently under review in the appropriate legal forum, and action on this proposal would not interfere with the court’s ability to resolve the pending litigation. See Natcom Bancshares Inc., FRB Order No. 2017-37 at 6 n.18 (December 18, 2017); M&P Community Bancshares, Inc., 92 Federal Reserve Bulletin C156, C156 n.7 (2006).”

March 19, 2018

Tthe bank with the worst record in the United States for gouging consumers with overdraft fees, Ameris, has applied to the Federal Reserve to buy Hamilton State Bancshares - which, in the Atlanta MSA in 2016 for home purchase loans received 52 applications from whites, originated 37 of those as loans, denying only 12 applications. But for African Americans for home purchase loans, Hamilton State Bank denied every single on of the five applications that, based on its disparate marketing, it received or acknowledged. This is outrageous as is Ameris' record, and mis-statements. Ameris when it applied to buy Atlantic Coast Financial Corporation, and thereby directly acquire shares of Atlantic Coast Bank, falsely stated in its application that it would continue the CRA policies of Atlantic - see response to AI question 3, incorporated herein by reference. On the current record, public evidentiary hearings are needed on Ameris' Hamilton (and Atlanic) applications....

March 12, 2018