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June
18, 2018
As
Federal
Reserve Rubber
Stamps Merger
By Ameris
Jerome Powell
Omits
Regulatory
Duties
By
Matthew R. Lee, Patreon
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
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
By
Matthew R. Lee, Audio
By
Matthew R. Lee, Patreon
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, 2018Tthe 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
All
you need in a
crazen
headline
"Federal
Reserve Board
announces it
will not
object to the
capital plan
resubmitted by
Capital One
Financial
Corporation"
March
5, 2018
So new Fed
chairman Jay
Powell was
questioned
about the
Community
Reinvestment
Act in the
House
Financial
Services
Committee last
week - as if
he were coming
in fresh, and
hadn't for
some time been
rubber-stamping
contested
mergers and
denying FOIA
appeals to get
more
information...
February
26, 2018
After
ICP Protest to
Ameris Bank
Merger With
Atlantic
Coast, Ameris
Admits
Application
False
By
Matthew R. Lee, Patreon
February
19, 2018
US Bancorp Slapped by Federal Reserve for Money Laundering, Fee Gouger Ameris Still Silent
By
Matthew R. Lee
February
12, 2018
Something remains wrong with the Federal Reserve's website https://www.federalreserve.gov/apps/h2a/h2a.aspx - when searched by end of comment period, as of February 10 the most recent end is February 6. This hides applications and excludes the public. Inner City Press wrote to the Fed, without response or improvement. We'll have more on this.
February
5, 2018
After US OCC
Apologized to
Wells
Fargo, Fed
Imposes Cap on
Growth For
Abusing Consumers
By Matthew R. Lee
NEW YORK, February 2 – More than ten months after Wells Fargo Bank's Community Reinvestment Act rating was dropped two levels to "Needs to Improve," barring it from acquisitions, on February 2 the Federal Reserve said this: "Responding to recent and widespread consumer abuses and other compliance breakdowns by Wells Fargo, the Federal Reserve Board on Friday announced that it would restrict the growth of the firm until it sufficiently improves its governance and controls.. Until the firm makes sufficient improvements, it will be restricted from growing any larger than its total asset size as of the end of 2017." By contrast the Office of the Comptroller of the Currency has quietly said, in a footnote to a Bulletin issued on October 12, that "The OCC’s policy is not to lower a bank’s CRA composite or component rating by more than one rating level." See here, footnote 8. So when did this become the OCC's policy, after it dropped Wells by two levels? Call it a stealth sop to Wells Fargo - and seemingly a violation of the Administrative Procedures Act. We'll have more on thisJanuary
29. 2018
Fed
Asks Schwab
About
Community
Reinvestment
Act After Fair
Finance Watch
Protest
By Matthew R. Lee
WASHINGTON, January 24 – Earlier this month Inner City Press / Fair Finance Watch filed with the Federal Reserve for evidentiary hearings on the application by Charles Schwab Corporation to set up Charles Schwab Trust Bank in Henderson, Nevada, noting that Schwab has been sued by its own employees, about 401k plans. See, e.g., Severson v. Charles Schwab Corp. , N.D. Cal., No. 3:17-cv-00285-JCS, complaint filed 1/19/17. It is also noteworthy that, Inner City Press wrote to the Fed, despite the issues there, Schwab reportedly held merger talks with SoFi earlier this year. Now the Federal Reserve has written to Schwab, on January 24, with these three questions: "Provide a summary regarding the current status of litigation in Severson v. Charles Schwab Corp., No. 4:17-cv-00285-CW (N.D. Cal. 2017). 2. Provide the “home state” of CSC as that term is defined in section 10(e)(7)(B)(iv) ofJanuary
22, 2018
The Federal Reserve Board last week took up the application of Huron Community Bank (“Huron Bank”), the state member bank subsidiary of Huron Community Financial Services, Inc. (“Huron Financial”), both of East Tawas, Michigan, has requested the Board’s approval under section 18(c) of the Federal Deposit Insurance Act (“Bank Merger Act”)1 to acquire certain assets and assume certain liabilities of a branch of First Federal of Northern Michigan. Don't blame it on CRA...
January
15, 2018
In DC,
Fed Ends
Enforcement
Actions on 10
Including Citi
& Chase
After
Micro-Fine of
GS
By Matthew R. Lee
NEW YORK, January 12 – After the Federal Reserve let Goldman Sachs set up a bank, without any public comment, during the financial meltdown, today the Fed has announced it has fined Goldman Sachs Bank USA for violating the National Flood Insurance Act. But the fine is for only $90,000. Some wondered about this announcement - and then two minutes later, perhaps explaining, this: "The Federal Reserve Board on Friday announced the termination of enforcement actions related to residential mortgage loan servicing and foreclosure processing issued in 2011 and 2012 against 10 banking organizations: Ally Financial Inc.; Bank of America Corporation; CIT Group, Inc. (as successor to IMB HoldCo LLC); The Goldman Sachs Group, Inc.; HSBC North America Holdings, Inc.; JPMorgan Chase & Co.; Morgan Stanley; The PNC Financial Services Group, Inc.; SunTrust Banks, Inc.; and U.S. Bancorp." Wag the dog. In the battle for the US Consumer Financial Protection Bureau, on January 10 US District Judge Timothy Kelly ruled that Leandra English lacks a likelihood of success on the merits in removing Mick Mulvaney as acting director. Meanwhile Mulvaney is putting under “strictest review” the CFPB's fund to compensate victims of fraud. And fraud is more and more pervasive. Last week Inner City Press / Fair Finance Watch filed with the Federal Reserve for evidentiary hearings on the application by Charles Schwab Corporation to set up Charles Schwab Trust Bank in Henderson, Nevada. It has been reported that this bank would “focus on Schwab’s workplace benefit plan clients, such as employers who offer 401k plans, and the intermediaries who serve them.” But Schwab has been sued by its own employees, about 401k plans. See, e.g., Severson v. Charles Schwab Corp. , N.D. Cal., No. 3:17-cv-00285-JCS, complaint filed 1/19/17 ). Schwab “larded” its own 401(k) plan with expensive and poorly performing investment funds and services that earned fees for the company at the expense of workers’ retirement savings, according to the new lawsuit, filed Jan. 19. The lawsuit also targets the performance of Schwab’s stable value fund and claims that Schwab executives allowed the plan’s trustee to profit from the unallocated plan assets it held. It is also noteworthy that, Inner City Press wrote to the Fed, despite the issues there, Schwab reportedly held merger talks with SoFi earlier this year. Fair Finance Watch has also reviewed, in Nevada, Charles Schwab Bank's lending in the Reno MSA. For home purchase loans, all of the loans were to whites (none to Latinos or African Americans), all to applicants over 120% of MSA median income. The same is true of refinance lending. On the current record, these applications should not be approved." We'll have more on this.January
8, 2018
Something
to watch: "The
Federal
Reserve Board
on Thursday
requested
comment on
proposed
guidance that
would clarify
the Board's
supervisory
expectations
related to
risk
management for
large
financial
institutions.
The guidance
is part of a
broader
initiative to
develop a new
rating system
for large
financial
institutions
that will
align with the
post-crisis
supervisory
program. The
proposed
guidance would
apply to large
financial
institutions,
including:
domestic bank
holding
companies and
savings and
loan holding
companies with
$50 billion or
more in total
consolidated
assets;
foreign banks
operating in
the United
States with
$50 billion or
more in
combined U.S.
assets; and
nonbank
financial
companies
designated by
the Financial
Stability
Oversight
Council for
supervision by
the Board.
Comments on
this proposal
will be
accepted until
March 15,
2018." Watch
this site.
January
1, 2018
The Federal
Reserve, Inner
City Press
learned on
December 27,
held a
conference
call with the
OCC about
Sterling's
unreliable CRA
data. Too much
information is
being
withheld, and
Inner City
Press is
pursuing it.
For
transparency,
in 2018.
December
25, 2017
BrokenViews:
Powell has
already made
moves to relax
crisis-era
regulations,
which will
accelerate
under his new
vice chair,
Randal
Quarles. The
Fed is looking
to ease major
constraints on
banks,
including the
annual stress
tests, the
living wills
exercise and
the Volcker
Rule limiting
proprietary
trading....
December
18, 2017
Well
well well:
"The Federal
Reserve Board
on Friday
announced that
Vice Chairman
Randal K.
Quarles will
recuse himself
from
participating
in matters
specific to
Wells Fargo
& Company.
While this
action is
voluntary and
is not legally
required, it
is being taken
to avoid even
the potential
appearance of
a conflict of
interest.
Upon his
confirmation
as a Board
Member, Vice
Chairman
Quarles
divested all
applicable
stock holdings
related to
Wells Fargo.
However, in
light of his
extended
family's prior
sale of their
interest in a
bank to Wells
Fargo, he has
chosen to
recuse himself
from matters
specifically
involving the
firm.
As a result,
Vice Chairman
Quarles will
not vote on,
or participate
by decision or
recommendation
in, matters
specifically
involving
Wells Fargo.
He will
continue to
oversee the
Board's
supervision
and regulation
responsibilities
as Vice
Chairman for
Supervision,
including the
development of
supervisory
policies and
rules
applicable to
banking
organizations
generally."
December
11, 2017
On
Basel III:
"The federal
banking
agencies on
Thursday
announced
their support
for the
conclusion of
efforts to
reform the
international
bank capital
standards
initiated in
response to
the global
financial
crisis.
The Governors
and Heads of
Supervision
and the Basel
Committee on
Banking
Supervision
Thursday
announced the
finalization
of the reforms
to the "Basel
III" agreement
on bank
capital
standards.
With this
agreement, the
Basel
Committee will
bring to
conclusion the
international
reforms
initiated in
response to
the global
financial
crisis.
The Basel III
agreement,
which was
designed for
internationally
active banks,
was introduced
in 2010 and
was
instrumental
in
establishing
revised
minimum
standards that
increased both
the quality
and quantity
of regulatory
capital. The
reforms
finalized
today are
intended to
improve risk
sensitivity,
reduce
regulatory
capital
variability,
and level the
playing field
among
internationally
active banks.
The agencies
will consider
how to
appropriately
apply these
revisions to
the Basel III
reform package
in the United
States and any
proposed
changes based
on this
agreement will
be made
through the
standard
notice-and-comment
rulemaking
process."
And
we'll be
there.
December
4, 2017
So after Inner City Press' letter to the Fed, they "fixed" their online listing of mergers - but did not extend any of the flawed comment periods, nor explain...
November
27, 2017
Fair Finance Watch (and Inner City Press) has sent this to the Fed: Re: Formal request / complaint concerning FRB's failure to update its public notice of pending applications website, that it be corrected and comment periods extended
Dear
Chair Yellen,
Secretary
Misback and
others in the
FRS:
This is a
formal request
/ complaint
concerning
FRB's failure
to update its
public notice
of pending
applications
website, that
it be
corrected and
comment
periods
extended.
As of today
November 24,
the Fed's
online H2A
https://www.federalreserve.gov/apps/h2a/h2a.aspx
says that it
has not been
updated at all
since November
17 - a full
week ago.
But it's worse
- a search of
the database
today finds no
application
with a comment
period running
past November
28, putting
the date at
which the Fed
stopped
updating even
further back.
Please
explain,
correct, and
extend the
comment
periods.
November
20, 2017
When the Fed
approved South
State - Park
Sterling it
recited that
Fair Finance
Watch as "A
commenter
objected to
the proposal
on the basis
of alleged
disparities in
South State
Bank’s lending
to African
Americans and
Hispanics, as
compared to
whites, in the
Columbia,
South Carolina
Metropolitan
Statistical
Area
(“Columbia
MSA”), the
Charlotte,
North Carolina
MSA
(“Charlotte
MSA”), and the
Atlanta,
Georgia MSA
(“Atlanta
MSA”), as
reflected in
data reported
under the Home
Mortgage
Disclosure Act
(“HMDA”) for
2015." Here's
what FFW
provided to
the Fed:
" In the
Atlanta,
Georgia MSA in
2015 for home
purchase
loans, South
State denied
the
applications
of African
Americans and
Latinos 4.23
times more
frequently
than the
applications
of whites. Its
lending did
not reflect
the market or
other lenders:
54 home
purchase loans
to whites,
only two to
Latinos, and
only ONE to an
African
American
applicant.
This is
disparate. In
the Colombia
SC MSA in 2015
for home
purchase
loans, South
State denied
the
applications
of African
Americans 2.79
times more
frequently
than the
applications
of whites, and
denied the
applications
of Latinos'
3.75 times
more
frequently
than whites.
Its lending
did not
reflect the
market or
other lenders:
179 home
purchase loans
to whites,
only ten to
African
Americans and
only one to a
Latino
applicant.
This is
disparate. In
the Charlotte
NC MSA for
home purchase
loans in 2015,
South State
denied the
applications
of African
Americans 2.22
times more
frequently
than the
applications
of whites, and
denied the
applications
of Latinos'
6.58 times
more
frequently
than whites.
Its lending
did not
reflect the
market or
other lenders:
382 home
purchase loans
to whites,
only thirteen
to African
Americans and
only four to
Latino
applicants.
This is
disparate, and
a pattern
militating for
evidentiary
hearings and
the denial of
this
application."
But today's
Fed cares less
and less about
such
disparities...
November
13, 2017
Jay Powell. Capitol Hill. November 28. Be there.
November
6, 2017
Would Jay
Powell stay in
charge of
(denying) FOIA
appeals, as
Chairman of
the Fed?
BancorpSouth,
after settling
redlining
charges, has
escaped
Federal
Reserve
regulation,
announcing on
Oct 31 it has
approvals from
the "Federal
Deposit
Insurance
Corporation
and the
Mississippi
Department of
Banking and
Consumer
Finance... to
improve
efficiency
through the
elimination of
redundant
corporate
infrastructure
and
duplicative
regulatory
oversight."
October
30, 2017
Shameful: Mid America Bank and Trust Company has a Needs to Improve CRA rating but was allowed to pay $5 million and get acquired by Reliable Community Bancshares. Impunity.
October
23, 2017
On Associated
- Bank Mutual,
the Fed
e-mailed Inner
City Press
part of the
application
but not, it
seems, the
rest of the
file including
the multiple
protests.
Maybe we're
missing
something...
Meanwhile,
Bank Mutual
Corp. reported
third quarter
net income of
$3.8 million,
or 8 cents per
share, down
from $4.5
million, or 10
cents per
share, in the
third quarter
of 2016.
October
16, 2017
Inner
City Press /
Fair Finance
Watch filed:
"This is a
timely first
comment
opposing and
requesting an
extension of
the FRB's
public comment
period on the
Applications
by Associated
Banc-Corp to
merge with
Bank Mutual
Corporation,
Milwaukee,
Wisconsin and
acquire Bank
Mutual. The
Fed has
received many
substantive
comments on
this
application
and should
hold public
hearings,
including on
the
prospective
impacts of the
36 branches
that
Associated
would close or
consolidate.
See,
http://www.jsonline.com/story/money/2017/09/01/branch-network-pared-36-locations-associated-bank-takes-over-bank-mutual/624805001/
Fair Finance Watch has reviewed applicant Associated's home purchase lending in the just-out 2016 HMDA data in the Milwaukee MSA and finds serious disparities militating for evidentiary hearings and the denial of this application. For conventional home purchase loans, Associated denied the applications of African Americans 4.16 times more frequently than those of whites; it made 807 such loans to whites and only 41 to African Americans. Even cumulating Table 4-1 loans with Table 4-2, Associated's denial rate disparity in 2016 was 3.71; it made 861 loans to whites and only 48 to African Americans. This is outrageous. On the current record, these applications should not be approved."
October
9, 2017
It is
an outrage
that former
Fed governor
Duke cashes
out to the
Wells Fargo
board, while
Wells is
"regulated" by
the Fed...
October
2, 2017
While there are many toxic proposed bank mergers across the USA, the proposed in-market Wisconsin combination of Associated and Bank Mutual which would close branches is our focus this week - more than 300 comments filed, with the Federal Reserve comment period open until October 11 -- fire away!
September
25, 2017
South State Corporation, to the Federal Reserve, is making excuses for its record in the Atlanta MSA, and trying to withhold obviously public information. We'll have more on this.
September 18, 2017Sen.
Amy Klobuchar
(D-Minn.)
Sept. 14
introduced two
bills intended
to “modernize”
antitrust
enforcement,
including a
proposal to
require big
merging
companies to
prove their
tie-ups won’t
harm
competition...
One of
Klobuchar’s
proposals
would shift
the burden of
proof for
companies
involved in
“mega-mergers,”
a term that
the bill
doesn’t
define.
Merging
companies
would have to
prove to
regulators
that their
deal doesn’t
harm
competition.
Currently, it
works the
opposite way.
Regulators are
required to
prove that a
proposed
merger is
likely to harm
competition to
stop it....
The measure
also would add
the term
“monopsony” to
the Clayton
Antitrust Act
so that single
buyers
controlling a
market would
be illegal.
The bill would
create an
“Office of the
Competition
Advocate” to
help consumers
with
complaints,
encourage
antitrust
investigations,
and analyze
and publish
reports on
merger
activity.
September
11, 2017
UNreal that he was portrayed as a strong regulator... "Stanley Fischer submitted his resignation Wednesday as Vice Chairman and as a member of the Board of Governors of the Federal Reserve System, effective on or around October 13, 2017. He has been a member of the Board since May 28, 2014."
September
4, 2017
By
Matthew R. Lee, New
Platform
August
28, 2017
Watchdogging
Fair Lending
Evasion, FFW
Challenges
Redliner
BancorpSouth
at FDIC
By Matthew Russell Lee
South Bronx, New York, August 26 – The lack of seriousness in US bank regulation, the mechanical repeating of whatever a challanged bank says, is exemplified by the application by BancorpSouth, which Inner City Press / Fair Finance Watch challenged on disparities and which settled racial redlining charges, to drop its Federal Reserve charter and evade regulation. Now ICP/FFW has timely protested that application to the FDIC: "Dear Regional Director Elmquist, Ass't Regional Director Finnegan and others at the FDIC: "This is a first timely comment opposing, requesting hearings and an extension of the comment period on BancorpSouth's cynical application to evade regulation after its redlining and settlement. Inner City Press / Fair Finance Watch protested the applications of BancorpSouth to merge with Ouachita Bancshares Corporation and thereby indirectly acquire Ouachita Independent Bank, and with Central Community Corporation, and thereby indirectly acquire First State Bank Central Texas, Austin, Texas. - based on racial discrimination in lending... Now BancorpSouth makes this application, and its CEO Dan Rollins states that it wants to “alleviate... regulatory oversight,” and become the “only state-chartered bank not a part of the Federal Reserve system.” We oppose this cynical evasion, particularly by one of the few banks having settled redlining charges. Let's compare: reviewing the 2015 HMDA data released by the FFIEC, ICP examined BancorpSouth's conventional home purchase lending in the Jackson, Mississippi and Baton Rouge, Louisiana and finds them troubling. In 2015 in the Jackson MS MSA for conventional home purchase loans, BancorpSouth made 346 loans to whites, only 53 to African Americans. BancorpSouth's denial rate for whites was 7% while for African Americans it was 19% -- 2.71 times higher. This was troubling. In 2015 in the Baton Rouge LA MSA for conventional home purchase loans, BancorpSouth made 47 such loans to whites and NONE to African Americans, even less than the three it made in 2012. BancorpSouth has grown more disparate. ICP is requesting evidentiary hearings and that this proposed acquisition, on the current record, not be approved. There is no public benefit."
August
21, 2017
Inner
City Press /
Fair Finance
Watch has
filed this: This
is a timely
first comment
opposing and
requesting an
extension of
the FRS's
public comment
period on the
Application by
South State
Corporation to
acquire Park
Sterling
Corporation,
and thereby
indirectly
acquire Park
Sterling Bank.
Fair Finance
Watch has
reviewed
applicant
South State's
home purchase
lending in
three MSAs in
three states -
its
heardquarters
in Colombia
SC, the
targets
Charlotte NC,
and Atlanta GA
- and finds
serious
disparities
militating for
evidentiary
hearings and
the denial of
this
application.
And,
significantly,
the specifics
of which
branches would
be closed have
not been
publicized.
In the
Atlanta,
Georgia MSA in
2015 for home
purchase
loans, South
State denied
the
applications
of African
Americans and
Latinos 4.23
times more
frequently
than the
applications
of whites. Its
lending did
not reflect
the market or
other lenders:
54 home
purchase loans
to whites,
only two to
Latinos, and
only ONE to an
African
American
applicant.
This is
disparate.
In the
Colombia SC
MSA in 2015
for home
purchase
loans, South
State denied
the
applications
of African
Americans 2.79
times more
frequently
than the
applications
of whites, and
denied the
applications
of Latinos'
3.75 times
more
frequently
than whites.
Its lending
did not
reflect the
market or
other lenders:
179 home
purchase loans
to whites,
only ten to
African
Americans and
only one to a
Latino
applicant.
This is
disparate.
In the
Charlotte NC
MSA for home
purchase loans
in 2015, South
State denied
the
applications
of African
Americans 2.22
times more
frequently
than the
applications
of whites, and
denied the
applications
of Latinos'
6.58 times
more
frequently
than whites.
Its lending
did not
reflect the
market or
other lenders:
382 home
purchase loans
to whites,
only thirteen
to African
Americans and
only four to
Latino
applicants.
This is
disparate, and
a pattern
militating for
evidentiary
hearings and
the denial of
this
application.
Meanwhile, see
http://www.gastongazette.com/news/20170728/park-sterling-bank-head-says-merger-will-bring-little-fallout-for-gaston-employees:
“employees in
any branch
that closes or
is affected
might have to
relocate to
keep their
job, to
places, for
example, such
as Charleston,
South
Carolina...
Since last
year, Park
Sterling had
been carrying
out a local
expansion that
involved
consolidating
back-office
operations and
bringing jobs
from South
Carolina to
Gastonia.
Cherry said
their branches
on Main Avenue
and South New
Hope Road have
seen the
effects of
that, and one
of the
decisions
essentially
made prior to
the announced
merger was to
close the Main
Avenue branch.
'It has
limited hours
and is really
just handling
commercial
customers,'
said Cherry.
'That was
likely going
to be closed
as a result of
our moves
beforehand.'”
South State
should be
asked for
information
and criteria
about the
closings and
the comment
period must be
extended to
allow entry of
this
information
into the
record and to
allow comment
thereon.
On the current
record,
hearings
should be held
and the
application(s)
should not be
approved. The
comment period
must be
extended.
August
14, 2017
Passing
the buck? "A
proposed
guidance
addressing
supervisory
expectations
for boards of
directors at
banks and
holding
companies,
published by
the Federal
Reserve Board
this week,
suggests that
expectations
for boards and
senior
management
have become
increasingly
difficult to
distinguish"
August
7, 2017
Inner City
Press / Fair
Finance Watch
last week
filed this:
"This is a
timely first
comment
opposing and
requesting an
extension of
the FRS's
public comment
period on the
Application by
Sandy Springs
Sandy Spring
Bancorp to
acquire
WashingtonFirst
Bankshares,
WashingtonFirst
Bank and lst
Portfolio,
Inc., Fairfax,
Virginia.
These
transaction
raises
troubling
Community
Reinvestment
Act issues.
Sandy Spring
has a
disparate
lending
record, as
does
WashingtonFirst.
And,
significantly,
the specifics
of which
branches would
be closed have
not been made
public, see
below. The
comment period
must be
extended.
In the
Baltimore MSA
in 2015 for
home purchase
loans, Sandy
Spring denied
the
applications
of African
Americans
TWENTY TWO
times more
frequently
than the
applications
of whites. For
refinance
loans in the
Washington
MSA, Sandy
Spring denied
the
applications
of African
Americans 8.8
times more
frequently
than the
applications
of whites. In
the Washington
DC MSA in 2015
for home
purchase
loans, Sandy
Spring denied
the
applications
of African
Americans 2.8
times more
frequently
than the
applications
of whites.
In the
Washington DC
MSA for home
purchase loans
in 2015,
WashingtonFirst
made 13 loans
to whites and
NONE to
African
Americans or
Latinos (there
were similar
zeroes for
people of
people for
home
improvement
loans).
Meanwhile, see
http://wtop.com/business-finance/2017/05/sandy-spring-buying-washingtonfirst-becoming-largest-locally-based-community-bank/:
“Sandy Spring
said there
will be branch
closings as
part of the
merger, though
it says it is
too soon to
determine
where overlap
will require
closings.”
That is not
acceptable:
Sandy Springs
should be
asked for
information
and criteria
about the
closings and
the comment
period must be
extended to
allow entry of
this
information
into the
record and to
allow comment
thereon."
July
31, 2017
Fed
and Synovus
Talked
"Confidential
Supervisory
Matter" July 21, on
Cabela
Application
By
Matthew R. Lee, Full Doc on Patreon Here
NEW
YORK, July 28 – Two months after Inner City
Press reported
Capital One failing in its proposal to acquire
Cabela's "World's Foremost Bank," a way to try
to avoid the regulators and Capital One's
Community Reinvestment Act record emerged. The
scam involves Synovus buying the bank then
passing one the credit card receivables to
Capital One, while keeping the deposits, so
Capital One wouldn't be reviewed under CRA. The
Fair Finance Watch has now opposed this, in a
filing to the Federal Reserve, below. And now
the Federal Reserve has, with all formality,
informed Fair Finance Watch and Inner City Press
of a July 21 meeting with Synovus, to discuss a
"confidential supervisory matter," Fed "memo to
file, on Patreon here.
Date:
July 27, 2017
To: File
From: Federal Reserve staff
Subject: Telephone Conversation with Clifford S.
Stanford, Esq. and Synovus Bank Representatives
re: Application by Synovus
Bank to Acquire Substantially All of the Assets
and Liabilities of World’s Foremost Bank
On
July 21, 2017, staff of the Board of Governors
of the Federal Reserve System (Alison Thro, Jon
Stoloff, Andrew Hartlage, Brian Phillips, Betsy
HowesBean, and Donald Arrington) and the Federal
Reserve Bank of Atlanta (Jordan Light, Juan
Sanchez, Sabrina Francis, Dwight Blackwood,
Steve Wise, and
Kathryn Hinton) had a telephone conversation
with representatives of Synovus Bank (Kessel
Stelling, Kevin Blair, Mary Maurice Young, and
Allan E. Kamensky), Columbus, Georgia, and
Clifford S. Stanford and Mark Kanaly, counsel
for Synovus Bank, in connection with the
application filed by Synovus Bank to acquire
substantially all of assets and liabilities of
World’s Foremost Bank, Sidney, Nebraska,
pursuant to section 18(c) of the Federal Deposit
Insurance Act.
Staff discussed a confidential supervisory matter with Mr. Stanford and the Synovus Bank representatives." See here.
July
24, 2017
While
Fed & OCC
Paper Over
Sterling's CRA
Scam, Otting
& Quarles
In Senate July
27
By
Matthew R. Lee, New
Platform
July
17, 2017
While
Federal
Reserve Papers
Over
Sterling's CRA
Scam, Quarles
Nominated as
to Board
By
Matthew R. Lee, New
Platform
July
10, 2017
Regulators
Said
Sterling's CRA
Data
Unreliable,
Under FOIA Fed
Blacks-Out
Most of 400
Pages
By
Matthew R. Lee, New
Platform
NEW YORK, July 8 – Sterling Bank, which is applying for approvals to acquire Astoria Bank, is known by its regulators to have filed unreliable Community Reinvestment Act data from at least 2014 through 2016, a document obtained by Inner City Press shows. The story, and outrage, was picked up by the American Banker newspaper here, by Paul Davis and Allison Prang, crediting Inner City Press - and Sterling Bank had no comment. Inner City Press immediately on May 13 submitted a Freedom of Information Act request to the Federal Reserve. The Fed repeatedly extended its time to respond then finally on July 7 provided more than 400 pages - almost entirely redacted. All references to the unreliable CRA data (and needs to improve rating) have been redacted. Sample here; the rest on Patreon, here. Inner City Press immediately submitted a FOIA appeal: "Amazingly, despite taking seven weeks to respond to ICP's immediate FOIA request, all information about this consumer compliance / CRA issue has been redacted from the records produced. CRA and CRA data are presumptively of public interest and public impact. The redacted response implies that the public could be entirely excluded from the FRS' review of this important CRA issues. It is unacceptable and inconsistent with the purpose, spirit and letter of FOIA. ICP is hereby appealing each and every redaction in the records belated provided to ICP on July 7. This should be ruled on before the comment period closed; the comment period should be extended." Watch this site.
July
3, 2017
Regulators
Said
Sterling's CRA
Data
Unreliable,
Now Admits
Needs to
Improve 2017,
Denial?
By Matthew R.
Lee, New
Platform
NEW YORK, July
1 – Sterling Bank, which is applying for
approvals to acquire Astoria Bank, is known by
its regulators to have filed unreliable
Community Reinvestment Act data from at least
2014 through 2016, a documentobtained
by Inner City Press shows. The story, and
outrage, has been picked
up by the American
Banker newspaper here,
by Paul Davis and Allison Prang, crediting Inner
City Press - and Sterling Bank had no comment.
Instead, Sterling's outside counsel Wachtel
Lipton chose to snail-mail its response to the
wrong address, and not e-mail it to Fair Finance
Watch. Via here, with
envelope re-submitted to Fed and OCC. Now
another snail-mailed response from Sterling's
Wachtel, which we've put online here
on Patreon: "Please see Exhibit 1 and
Confidential Exhibit C" -- Inner City Press has
now requested it under FOIA, but the agencies
have already repeatedly extended their time.
This is a scam. But crucially, even Wachtel says
"Sterling did receive a Needs to Improve rating
for the State of New York in Sterling Bank's
most recent CRA Performance Evaluation dated
January 18, 2017." We'll have more on this - the
application must be denied. The OCC has now put
up a roadblock to releasing the records Inner
City Press has requested under the Freedom of
Information Act, writing: "The purpose of this
letter is to seek additional information
pertaining to your recent request for
information from the Office of the Comptroller
of the Currency. Your request dated May 13, 2017
was received in my office on May 15, 2017. You
requested any and all records related to
Sterling Bank's application(s) to acquire
Astoria and Sterling Bank's CRA data. Upon
further review, we determined that we need
clarification on the date range for search of
Sterling Bank’s CRA data. If I have not received
this information by COB June 19th I will assume
that you no longer seek this information and
consider your request closed." Inner City Press
has responded: " In response to
Inner City Press' now month-old FOIA request
concerning the CRA data the OCC knew and knows
to be unreliable, you have asked that by June 19
ICP specify the date range for the request.
While not understanding the OCC's delay in
requesting this, we hereby timely specify that
the date range is from three years ago to the
date of your response. Please confirm receipt of
this (including explaining your letter since you
wrote “we need clarification on the date range
for search”) and please provide the records as
we intend to comment on them, for obvious
reasons. Thank you." Meanwhile, Sterling's
lawyers at Wachtell Lipton chose to snail mail
their response to Fair Finance Watch, putting it
in the mail three days after it was dated (now
online via Patreon here.)
How did it take the OCC a full MONTH to come up
with its request? Why was the response snail
mailed? This while the Federal Reserve has
granted Inner City Press' request for expedited
treatment of its FOIA request for all records,
promising the responsive documents by June 1.
But then the Fed, in a June 1 letter,
unilaterally extended its time to June 22. First
Fed letter on Scribd, here.
June
26, 2017
Amazingly,
the Federal
Reserve has
for the second
time extended
its time to
respond - to
provide a
single
document - on
Inner City
Press' FOIA
request about
Sterling
Bank's
unreliable CRA
data. We'll
have more on
this.
June 19, 2017
Regulators Said
Sterling's CRA Data Unreliable, ICP
on FOIA Games, Sterling
Response Here
By
Matthew R. Lee, New
Platform
June 12, 2017
On
Brazil Land
Grabs & CRA Flaws,
Fed Parrots
TIAA, Which
Alludes To
Confidential
Info
By Matthew Russell Lee
UNITED NATIONS, June 8 – The lack of seriousness in US bank regulation, the mechanical repeating of whatever a challanged bank says, is exemplified by the Federal Reserve Board's June 7 approval of TIAA's application to acquire Everbank of Florida, which Inner City Press / Fair Finance Watch on October 29, 2016 challenged. After Inner City Press' challenge, the Fed asked some questions, and TIAA defended its investments in land grabs in Brazil. On this, the Fed's approval order repeats word for word, apparently without inquiry, the bank's law firm's defense. The bank wrote: "We are grateful for this opportunity to respond to the comment letter filed by Inner City Press / Fair Finance Watch on 29 October 2016 regarding the application submitted by TCT Holdings, Inc., Teachers Insurance and Annuity Association of America (“TIAA”)... that TIAA has engaged in improper business practices in Brazil should be considered by the Federal Reserve Board as a factor when considering the managerial resources of the Applicants. The news article cited in the Comment Letter does not provide a complete or accurate portrayal of how TIAA conducts business in Brazil and other markets... TIAA is a signatory to the U.N. Principles for Responsible Investment." The Fed's approval order also cites these UN "principles." On June 1, just before the approval, TIAA's law firm David Polk wrote in: You have asked us to supplement our responses to certain allegations made in protests by Inner City Press/Fair Finance Watch regarding the lending practices of TIAA-CREF Trust Company, FSB (“TIAA FSB”) and EverBank. As you are aware, we have provided substantial information in response to the allegations. We have received the following information from TIAA FSB: While the allegation of discriminatory lending focuses on the St. Louis MSA by TIAA FSB, we wish to make three important points in response. First, the allegation, using HMDA data for the St. Louis MSA, focuses on a small number of loans made in the MSA. We do not think the small sample, when analyzed, demonstrates a pattern or practice of discrimination. Second, TIAA, FSB operates no brick and mortar branches in the St. Louis MSA. Its participation in the MSA primarily results from the use of internet offerings as well as other broader-based channels. To focus on the results in the St. Louis MSA where there are no physical locations does not fairly reflect the nature of TIAA, FSB’s business strategy or its overall record of non-discriminatory lending. Third, as reflected above, the TIAA FSB mortgage offerings are nationwide in scope using the internet and other broad-based distribution channels. Focusing on a single market, regardless of its location, does not fairly reflect or represent TIAA FSB’s business strategy or its overall record. On May 25, 2017, TIAA FSB received the results from its Fair Lending Examination by the OCC. While the results of that examination constitute confidential supervisory information, it would be useful for the Federal Reserve to obtain a copy of the results of the examination. If you wish, TIAA FSB would be pleased to seek approval to share the results of the examination with you." How cozy. We'll have more on this.June
5, 2017
Regulators
Said
Sterling's CRA Data
Unreliable, Fed
Expedites Now
Delays ICPs
FOIA, OCC
Cover Up
By Matthew R.
Lee, New
Platform
NEW YORK, June 3 – Sterling Bank, which is applying for approvals to acquire Astoria Bank, is known by its regulators to have filed unreliable Community Reinvestment Act data from at least 2014 through 2016, a documentobtained by Inner City Press shows. The story, and outrage, has been picked up by the American Banker newspaper here, by Paul Davis and Allison Prang, crediting Inner City Press - and Sterling Bank had no comment. Instead, Sterling's outside counsel Wachtel Lipton chose to snail-mail its response to the wrong address, and not e-mail it to Fair Finance Watch. Via here, with envelope re-submitted to Fed and OCC. This while the Federal Reserve has granted Inner City Press' request for expedited treatment of its FOIA request for all records, promising the responsive documents by June 1. But now the Fed, in a June 1 letter, has unilaterally extended its time to June 22: "Dear Mr. Lee, This correspondence is to provide you with an update on the status of your FOIA request. The search for records is being completed and staff is beginning to review the search results for responsiveness and releasability. We will continue to process your request as quickly as possible. Accordingly, the Board hopes to be able to respond to your request, or provide a status update, on or before June 22, 2017. Very truly yours, Jeanne M. McLaughlin Manager, Freedom of Information Office." Why expedite and then extend? Why did the OCC rush a cover-up "Satisfactory" rating? We'll have more on this. First Fed letter on Scribd, here.
May
29, 2017
After
Fair Finance
Watch
Protested
Synovus -
Cabela,
Federal
Reserve Asks
Synovus 7
Questions
By Matthew R. Lee
NEW YORK, May 22 – The Federal Reserve has asked Synovus more than a half dozen questions on May 22, on its (straw-man) application to acquire Cabela's World's Foremost Bank, the questions annexed on May 22 here. Two months after Inner City Press reported Capital One failing in its proposal to acquire this "World's Foremost Bank," a way to try to avoid the regulators and Capital One's Community Reinvestment Act record emerged. The scam involves Synovus buying the bank then passing one the credit card receivables to Capital One, while keeping the deposits, so Capital One wouldn't be reviewed under CRA. The Fair Finance Watch has now opposed this, in a filing to the Federal Reserve. NCRC has commented as well. We'll have more on this.
May
22, 2017
Regulators
Said
Sterling's CRA Data
Unreliable, Sterling
Mis-Sends
Response, Fed
Expedites ICPs
FOIA
By
Matthew R. Lee, New
Platform
NEW YORK, May 20 – Sterling Bank, which is applying for approvals to acquire Astoria Bank, is known by its regulators to have filed unreliable Community Reinvestment Act data from at least 2014 through 2016, a document obtained by Inner City Press shows. The story, and outrage, has been picked up by the American Banker newspaper here, by Paul Davis and Allison Prang, crediting Inner City Press - and Sterling Bank had no comment. Instead, Sterling's outside counsel Wachtel Lipton chose to snail-mail its response to the wrong address, and not e-mail it to Fair Finance Watch. Via here, with envelope re-submitted to Fed and OCC. This while the Federal Reserve has granted Inner City Press' request for expedited treatment of its FOIA request for all records, promising the responsive documents by June 1. Fed letter on Scribd, here.
Regulators Said Sterling's CRA Data Unreliable, Sterling Mis-Sends Response, Fed Expedites ICPs FOIA, Here by Matthew Russell Lee on Scribd
Fair Finance Watch has asked both the Fed and OCC to extend their comment periods