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Inner City Press
has had to
FOIA the Fed:
"This is a
for the all
not limited to
exhibits as as
Exhibit 1 to
This is scam.
November 5, 2018
told the Fed,
after Fair Finance Watch's
the 2017 CRA
being located in
income area was reclassified
in a moderate
that is some
has written to
section 3 of
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
October 22, 2018
Cadence Bank Bid For State Bank in Georgia Challenged by Fair Finance Watch to Fed Revolving Door
Matthew R. Lee, Video,
From a Fed approval order last week : "The HHI in this market would increase by 261 points, from 1604 to 1865."
Synovus Financial Corporation
General Counsel & Secretary
1111 Bay Avenue, Suite 500
Columbus, Georgia 31901
Dear Mr. Kamensky:
This refers to the application by (1) Synovus Financial Corp., Columbus, Georgia to acquire
FCB Financial Holdings, Inc. and thereby acquire Florida Community Bank, N.A., both of
Weston, Florida (Bank), pursuant to section 3(a)(3) and 3(a)(5) of the Bank Holding Company
Act; and (2) Synovus Bank, Columbus, Georgia to merge with Bank, pursuant to section 18(c) of
the Federal Deposit Insurance Act. Enclosed is a copy of a letter received from Fair Finance
Watch and Inner City Press commenting on the application.
Neither the Bank Holding Company Act nor the Board's Regulation Y requires a response from
Applicant. However, if you wish to respond, your comments should be received by this Reserve
Bank within eight business days from the date of this letter.
Jean Nellie Liang of Illinois, to be a Member of the Board of Governors of the Federal Reserve System for the remainder of a 14-year term expiring January 31, 2024. Ms. Liang is a Senior Fellow in Economic Studies at the Brookings Institution and a Visiting Scholar at the International Monetary Fund’s Monetary and Capital Markets Department. Previously, Ms. Liang served as Director of the Division of Financial Stability at the Board of Governors of the Federal Reserve System. Ms. Liang is a member of the Congressional Budget Office’s Panel of Economic Advisors and was a lecturer at the Yale School of Management. She earned her B.A. in economics from the University of Notre Dame and Ph.D. from the University of Maryland.
She wrote about subprime...
September 10, 2018
From Fed Reserve Bank: If you seek any “confidential” information regarding the application under the Freedom of Information Act (“FOIA”), you must submit a request to the Board’s Freedom of Information Office.
it's why you
such as in
Exhibits D and
E in their
Fed: Dear Mr. Lee: Applications staff reviewed the exhibits designated as “confidential” by the applicant and considered these exhibits to contain nonpublic information. If you seek copies of confidential information under the Freedom of Information Act, you must submit a request to the Board’s Freedom of Information Office, as described in my earlier email.
So will the
Reserve end up
Otting gamed their
to CIT? We'll
August 27, 2018
gotten too big
-- more market
share in fewer
are some of
days, and the
to meet in
will be the
But the Fed
has allowed and
ended its "enforcement
for murderous drug
gangs. Plus ca
August 13, 2018
Aug 10: "The
The $8.6 million penalty addresses the deficient execution and notarization of certain mortgage-related affidavits prepared by a subsidiary, CitiFinancial. The improper practices occurred in 2015 and were corrected. CitiFinancial exited the mortgage servicing business in 2017.
Also on Friday, the Board announced the termination of an enforcement action from 2011 against Citigroup and CitiFinancial related to residential mortgage loan servicing. The termination of this action was based on evidence of sustainable improvements." What improvements?
August 6, 2018
August 3 the Fed
ensure compliance with U.S. law and for its operations in general, and these will be continued at Nordea Finland following the Merger.
Finland is a member of the Financial Action Task Force and subscribes to its recommendations on measures to combat money laundering and international terrorism. "
banks want to
would intentionally choose to avoid minority areas. Nonetheless, some banks treat minority
neighborhoods less favorably.
For example, redlining risk may increase because of a failure to market products or locate
branches in the minority areas in the bank’s market, or because of changes in the bank’s
business model, such as through mergers, acquisitions, or new lending patterns. The Federal
Reserve conducts a risk-focused review of potential redlining risk, consistent with the
2009 Interagency Fair Lending Examination Procedures.5
Below are the key risk factors considered by the Federal Reserve in the redlining review as
well as some practical steps controls for mitigating risk.
Community Reinvestment Act (CRA) assessment area. Federal Reserve examiners
review whether the bank’s assessment areas appear to inappropriately exclude majority
minority census tracts.
Lending record. Federal Reserve examiners review whether the bank’s record of Home
Mortgage Disclosure Act (HMDA) mortgage lending and/or CRA small business lending
shows statistically significant disparities in majority minority census tracts when compared
with similar lenders.
Branching strategy. Federal Reserve examiners review whether the bank’s strategy for
branch or loan production office locations appears to exclude majority minority census
tracts. Marketing and outreach strategy. Federal Reserve examiners review whether the
bank’s marketing and outreach strategy appears to treat majority minority census tracts
Complaints. Federal Reserve examiners review whether any complaints by consumers
or consumer advocates raise concerns that the bank treats certain geographies differently
on a prohibited basis." we'll see...
Speaking of NY
the Fed last
week ended an
- from 2009...
July 2, 2018
Reserve had to
admit that Deutsche Bank again
failed the stress
test. Now what
out the stress
Matthew R. Lee, Patreon
a 60 day
comment period on
and tailor 'Volcker
June 4, 2018
Matthew R. Lee, Audio
Matthew R. Lee, Audio
Matthew R. Lee, Patreon
Fed-speak / Fed - spun “A commenter objected to the proposal alleging that, based on data reported under the Home Mortgage Disclosure Act of 1975 (“HMDA”), Charles Schwab Bank lent only to white borrowers with incomes above 120 percent of the area median income in the Reno, Nevada, Metropolitan Statistical Area..The commenter also criticized the workplace benefit plans of Charles Schwab, noting that employees of Charles Schwab had filed a lawsuit alleging that the 401(k) plans of Charles Schwab have expensive fees and poor performance that have benefited Charles Schwab at the expense of its employees. See Severson v. Charles Schwab Corp., No. 4:17-cv-00285-CW (N.D. Cal. 2017). Charles Schwab has denied any wrongdoing. The allegations regarding the performance of 401(k) plans and fees charged by plan sponsors are matters that are reviewed under the Employee Retirement Income Security Act of 1974. See 29 U.S.C. § 1001 et seq. The allegations are currently under review in the appropriate legal forum, and action on this proposal would not interfere with the court’s ability to resolve the pending litigation. See Natcom Bancshares Inc., FRB Order No. 2017-37 at 6 n.18 (December 18, 2017); M&P Community Bancshares, Inc., 92 Federal Reserve Bulletin C156, C156 n.7 (2006).”March 19, 2018
Tthe bank with the worst record in the United States for gouging consumers with overdraft fees, Ameris, has applied to the Federal Reserve to buy Hamilton State Bancshares - which, in the Atlanta MSA in 2016 for home purchase loans received 52 applications from whites, originated 37 of those as loans, denying only 12 applications. But for African Americans for home purchase loans, Hamilton State Bank denied every single on of the five applications that, based on its disparate marketing, it received or acknowledged. This is outrageous as is Ameris' record, and mis-statements. Ameris when it applied to buy Atlantic Coast Financial Corporation, and thereby directly acquire shares of Atlantic Coast Bank, falsely stated in its application that it would continue the CRA policies of Atlantic - see response to AI question 3, incorporated herein by reference. On the current record, public evidentiary hearings are needed on Ameris' Hamilton (and Atlanic) applications....