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May 25, 2020

  Now the Fed takes 12 days to acknowledge an emailed FOIA request, while preparing to rubber stamp the underlying bank merger application - UNacceptable. From May 22: "May 22, 2020   FOIA Request No. F-2020-00214   Dear Mr. Lee:     This will acknowledge receipt of your correspondence dated May 10, 2020 and received by the Board’s Information Disclosure Section on May 11, 2020, in which you request, pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, “all withheld portions of the additional information submitted by Banco Bradesco on or about May 6, 2020.”     The Board makes every effort to fulfill requests in a timely manner; however, there may be delays in fulfilling complex requests or those that require consultation." Really?
May 18, 2020

As US Bank Regulators Suspend Non Critical Exams Or Go 95% Off-Site New Project on Abuses

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

UN GATE / SDNY COURT, May 11 –     Amid the COVID-19 pandemic, fair lending and Community Reinvestment Act are taking a back seat, or worse.

While U.S. Comptroller of the Currency Joseph Otting is pushing forward with his proposal to weaken the CRA, his new chief national bank examiner Blake Paulson said bank examinations have gone 95% off-site.

  The Federal Reserve says it is suspending "non-critical" examinations, even at the largest institutions.

Meanwhile the Fed is pushing forward to approve bank merger applications, like Banco Bradesco - BAC which Fair Finance Watch has been opposing, as it has commented to the OCC against the acquisition of State Farm's health savings account business by Webster Bank, based in part of Webster's problematic Paycheck Protection Program performance.

   Fintechs and other non-bank financial firms are now at the PPP trough and are getting sued. For example, there is the lawsuit filed as a class action against Fountainhead Commercial Capital LLC on May 6, noting the finance firm advertised that it would process loan requests on a first-come, first-served basis and then stealthly shuffled its line of PPP applicants so that it would lock down the largest lending fees first.

     Meanwhile Paulson of the OCC, which wants to admit fintechs into banking without regulation, says no one is in PPP for the money. This while in response to Inner City Press' FOIA request for Otting's schedule the OCC redacted the names of banks that he met without, and obscured others. (A FOIA appeal has been filed.)

   Amid all this, Fair Finance Watch and Inner City Press / Community on the Move are launching a new project. Watch this site.

May 11, 2020

Federal Reserve Amid Covid Lets Banco Bradesco Redact Exhibit Names As Fair Finance Watch Says No

By Matthew R. Lee, Exclusive

SOUTH BRONX, SDNY, May 10 – 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.

 Now amid the Coronavirus pandemic, it continues 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.

  Inner City Press has written to the Fed: "This is a FOIA request for the all withheld portions of the additional information submitted by Banco Bradesco on or about May 6, 2020 as part of its challenged but still being processed amid the COVID-19 pandemic to aquire BAC including the exhibits the name of one of which, required to be sent to Fair Finance Watch and Inner City Press under the ex parte rules, was redacted. This follows up on our previous and still outstanding FOIA request which we voluntarily narrowed on April 30 in response to the inquiry by Katrina Allen-Austin of the Legal Division dated the same date. Note: processing of this application should be suspended while lock-down conditions continue in these parts of the US."

May 4, 2020

EDNY Probe of FIFA Makes Bank Hapoalim Pay $30M For Money Laundering, More to Fed

By Matthew Russell Lee, Patreon, Thread Video
Honduras - The Source - The Root - etc

SDNY COURTHOUSE, April 30 -- From the U.S. District Court for the Eastern District of New York, this: "Bank Hapoalim B.M. (“BHBM”), an Israeli bank with international operations, and its wholly owned subsidiary, Hapoalim (Switzerland) Ltd. (“BHS”), have agreed to forfeit $20,733,322 and pay a fine of $9,329,995 to resolve an investigation into their involvement in a money laundering conspiracy that fueled an international soccer bribery scheme."

From DC: "Federal Reserve Board announces it has fined Bank Hapoalim B.M. $37.35 million for the firm’s unsafe and unsound practices resulting in violations of U.S. tax laws."

More EDNY: "Specifically, BHBM and BHS have admitted that they, through certain of their employees, conspired to launder over $20 million in bribes and kickbacks to soccer officials with Fédération Internationale de Football Association (“FIFA”) and other soccer federations."

 EDNY prosecutors' FIFA cases include 26 publicly announced individual guilty pleas (including Blazer, Rocha, Hawilla, Callejas all 4 are deceased).  Several defendants who pleaded guilty were sentenced, including Takkas, Hector Trujillo, Li, Jimenez, Salguero, Pletsch.  They have completed their sentences (except for supervised release and financial components).  Others who pleaded guilty are awaiting sentencing - 2 individual defendants (Napout and Marin) convicted at trial. They have been sentenced.  Napout is in prison.  Marin was granted compassionate release last week and is in Brazil - 4 corporate guilty pleas (two Traffic entities, Mimo, US Imagina LLC) - 1 corporate Deferred Prosecution Agreement - 2 corporate Non Prosecution Agreement."

  Regarding those cases with particular regard to Honduras (which saw another indictment on April 30 across the East River in the SDNY, here), The death of FIFA scandal plagued former Honduras president Rafael Callejas was confirmed by current drug scandal plagued president Juan Orlando Hernandez on April 5; AP reported that "Callejas, 76, pleaded guilty in 2016 and was reportedly being held at a prison in Atlanta when he died."

Richard P. Donoghue, United States Attorney for the Eastern District of New York, Brian A. Benczkowski, Assistant Attorney General of the Justice Department’s Criminal Division, William F. Sweeney, Assistant Director-in-Charge, Federal Bureau of Investigation, New York Field Office (FBI), and Ryan L. Korner, Special Agent-in-Charge, Internal Revenue Service Criminal Investigation, Los Angeles Field Office (IRS-CI), made the announcement. “Today’s resolution marks another successful chapter in this District’s effort to hold accountable those corporations and individuals who participated in a bribery scheme that corrupted international soccer,” stated United States Attorney Donoghue. “This Office, along with our law enforcement partners, will continue to identify wrongdoers who manipulate international soccer in order to reap illicit profits and bring them to justice.” “For nearly five years, Bank Hapoalim employees used the U.S. financial system to launder tens of millions of dollars in bribe payments to corrupt soccer officials in multiple countries,” stated AAG Benczkowski. “Today’s announcement demonstrates the Department’s commitment to holding financial institutions to account when they knowingly facilitate corruption and other criminal conduct.”  2  “This announcement illustrates another aspect in the spider web of bribery, corruption and backroom deals going on behind the scenes as soccer games were played on the field. Bank Hapoalim admits executives looked the other way, and allowed illicit activity to continue even when employees discovered the scheme and reported it. The New York FBI Eurasian Organized Crime Task Force and our law enforcement partners have doggedly pursued every strand uncovered in this criminal investigation, and  will keep at it until they root out all of the bad actors,” stated FBI Assistant Director-in- Charge Sweeney.  “This forfeiture sends a clear message that no matter how complex or far reaching the conspiracy, justice will prevail. Bank Hapoalim B.M. and its subsidiary, Hapoalim Ltd., participated in a conspiracy that corrupted international soccer, its confederations, and member associations,” stated IRS-CI Special Agent-in-Charge Korner. “IRS-CI is proud to work alongside our international law enforcement partners, the FBI, and the United States Attorney’s Office to bring closure to this egregious international scandal that corrupted the sport of soccer.”  According to admissions in the statement of facts stipulated to by BHBM and BHS as part of the agreement, from approximately December 10, 2010 to February 20, 2015, BHBM and BHS personnel conspired with sports marketing executives, including executives associated with Full Play Group S.A. (“Full Play”), a sports media and marketing business based in Argentina, and others, to launder at least $20,733,322 in bribes and kickbacks to soccer officials. In exchange for those bribes and kickbacks, the soccer officials awarded or steered broadcasting rights for soccer matches and tournaments to the sports marketing executives and their companies. Full Play allegedly executed the illegal payments from accounts held at BHS and BHBM’s branch in Miami, Florida, which were held in the names of Full Play subsidiaries and affiliates. BHBM and BHS admitted they, through BHS and BHBM’s Miami branch, conspired to launder money for Luis Bedoya, who at various times served as the president of the Federación Colombiana de Futbol, a vice president of the Confederación Sudamericana de Fútbol (CONMEBOL), and a member of FIFA’s executive committee. BHBM and BHS allowed accounts controlled by Bedoya to be used to receive illicit bribe and kickback payments. In November 2015, Bedoya pleaded guilty to racketeering conspiracy and wire fraud conspiracy in the Eastern District of New York. He is awaiting sentencing.  Despite BHS compliance personnel repeatedly raising concerns about certain payments made to soccer officials from the accounts associated with Full Play, BHBM and BHS failed to take action. Instead, the banks’ relationship managers continued executing illicit bribe and kickback payments on behalf of Full Play. As outlined in the agreement, the government’s decision to enter into a three-year, non-prosecution agreement with BHBM and BHS was premised upon the banks’ thorough and complete cooperation, BHBM’s pledge to review and improve its  3  anti-money laundering program, and the banks’ other substantial remedial efforts, which include closing Bank Hapoalim (Latin America) S.A. and BHBM’s branch in Miami. BHS is also in the process of closing its operations." Inner City Press will follow these cases as much as possible.

  As to previously SDNY target on FIFA Rafael Callejo there was only one problem with that. Even a cursory search of the U.S. Bureau of Prisons website for Rafael Callejas finds one, 76,  Register Number: 81120-053, released from U.S. custody on 12/17/2015.

  Inner City Press will have more on these cases. Watch this site.

April 27, 2020

Federal Reserve Amid Covid 19 Letting Banco Bradesco Redact All on Virus Fair Finance Watch Says No

By Matthew R. Lee, Exclusive

SOUTH BRONX, SDNY, April 25 – 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.

 Now amid the Coronavirus pandemic, it still appears 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 has written to the Fed: "This is a FOIA request for the all withheld portions of the applications and applications additional information submitted by Banco Bradesco to aquire BAC including but not limited to the redacted portions of the April 24 submission, required to be sent to Fair Finance Watch and Inner City Press under the ex parte rules, which redacted the ENTIRE RESPONSE as to the impact of the Coronavirus economic downturn on the banks and merger. This is unacceptable."


If the Fed approves this, it's a joke - public hearings are impossible and it seems illegal, there is no rationale for approving this.

April 20, 2020

  Let the conflicts of interest begin, while many small businesses are excluded by the big banks getting the PPP cash (and leaving their ATMs empty) - "The Federal Reserve Board on Friday announced a rule change to bolster the effectiveness of the Small Business Administration's (SBA) Paycheck Protection Program (PPP). The change will temporarily modify the Board's rules so that certain bank directors and shareholders can apply for PPP loans for their small businesses.  To prevent favoritism, Board rules limit the types and quantity of loans that bank directors, shareholders, officers, and businesses owned by these persons can receive from their related banks. These requirements have prevented some small business owners from accessing PPP loans—especially in rural areas.  The SBA recently clarified that PPP lenders can make PPP loans to businesses owned by their directors and certain shareholders, subject to certain limits and without favoritism. The Board's change will allow those individuals to apply for PPP loans... The rule change is effective immediately and will be in place while the PPP is active. Comments will be accepted for 45 days after publication in the Federal Register."
April 13, 2020

Federal Reserve Amid Covid 19 Rubber Stamp Prepared For Banco Bradesco Fair Finance Watch Says No

By Matthew R. Lee, Exclusive

SOUTH BRONX, SDNY, April 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.

 Now amid the Coronavirus pandemic, it would appear that the Federal Reserve is still 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. If the Fed approves this, it's a joke - public hearings are impossible and it seems illegal, there is no rationale for approving this. But: "April 7, 2020

Reena Agarwal Sahni, Esq.
Shearman & Sterling LLP
599 Lexington Avenue
New York, New York 10022
Dear Ms. Sahni:
We refer to the application filed on behalf of Banco Bradesco, S.A., Lecce Holdings
S.A., Fundação Bradesco, BBD Participações S.A., Nova Cidade de Deus Participações S.A.,
and Cidade de Deus Cia. Commercial de Participações, all of Osasco, São Paulo, Brazil, to
become bank holding companies by acquiring substantially all of the shares of BAC Florida
Bank, Coral Gables, Florida, pursuant to Section 3 of the Bank Holding Company Act, as
amended (“BHC Act”).
Based on our review of the current record, the following additional information is
requested. Supporting documentation should be provided, as appropriate.
1. Discuss the impact of current economic conditions on Bradesco’s global operations and
the proposed acquisition of BAC Florida Bank, Coral Gables, Florida. Your response
should include information regarding any changes to the consideration or purchase price
due to changed economic conditions, as well as revised pro forma and projected financial
information, including asset quality and capital ratios, as of the most recent available
reporting period for Banco Bradesco and BAC, and the basis for those revisions.
2. Indicate whether there has been any change in timing regarding planned
consummation.

3. Provide an update on the FDIC’s review of the related Bank Merger Act application.
Please provide your response addressed to the undersigned within twenty business days
of the date of this letter. Any information for which confidential treatment is desired should be so
labeled and separately bound in accordance with Section 261.15 of the Board's Rules Regarding
Availability of Information. In addition, in accordance with the Federal Reserve's ex parte
procedures, provide a copy of the public portion of your response (together with any
attachments) directly to the commenter." These are the only questions the Fed could think of or had? Not, how are the banks serving the impacted public? Fair Finance Watch is proposing a CRA requirement on all Payroll Protection Program lenders - all of them - and raised this to Congressional leadership. #TreasureCRA. Watch this site.

April 6 2020

As Regulators Give Even Volcker Rulers More Time Community Reinvestment Act Comment Period Must Be Extended

By Matthew Russell Lee, Patreon  Periscope
BBC - Decrypt - LightRead - Honduras - Source

BRONX / SDNY, April 2 --   With the Community Reinvestment Act under attack by US Comptroller of the Currency Josephy Otting, Fair Finance Watch and Inner City Press on March 11 submitted a third comment this time making an obvious request.

They ask that in light of Coronavirus / COVID-19 the comment period on the assault on CRA be extended for months. See also here. Though it shouldn't have been necessary, Fair Finance Watch commented again on March 20, noting postponements by SEC and others.

  With Otting even still resisting postponing his dream of weakening the CRA, his OCC has joined not only his sometime partner in crime the FDIC but also the Fed providing a TWO YEAR extension for big banks, while still threatening to push through his attack on CRA, ghoulishly using Coronavirus, see below.

   On April 2, an even more telling move involving the OCC (and the FDIC, Fed and others) - to refuse to extend a comment period, in this case ending April 1, but to say that for those commenting on the Volcker Rule, comments will be considered for at least a month after the "expiration" of the comment period.

  If the OCC and Otting think it would be sufficient or acceptable to wait until April 9 then say Otting will consider (read, shred) comments until May 9, it is not. The communities that need CRA are even more impacted by Coronavirus, in terms of commenting. And the ghoulishness of Otting's assault on CRA, when these communities are struggling more than ever, is clear. Otting has already pushed it to the limit. Postpone or resign. "Five federal financial regulatory agencies on Thursday announced that they will consider comments submitted before May 1, 2020, on their proposal to modify the Volcker rule’s general prohibition on banking entities investing in or sponsoring hedge funds or private equity funds—known as “covered funds.”  The agencies will continue to consider comments to provide interested persons more time to analyze the issues and prepare their comments in light of potential disruptions resulting from the coronavirus. The proposal asked for comments to be submitted by April 1, 2020.  The agencies will continue to work together on policy issues as the coronavirus pandemic unfolds.  Media Contacts: Federal Reserve Board Eric Kollig202-452-2955... OCC Bryan Hubbard202-649-6870."

March 30, 2020

Troubling: Why does the Fed need BlackRock? Parts of the Fed’s bond-buying program fit more squarely in an asset manager’s wheelhouse. While the Fed’s main job is to set big-picture monetary policy by purchasing Treasury debt, a fund firm like BlackRock can be tapped for its expertise in evaluating and managing different kinds of debt, like portfolios of corporate bonds -- something that’s not a main skill set of the central bank. BlackRock Financial Markets Advisory, an arm that consults with government agencies and institutions, will manage the projects. Aladdin, the risk-monitoring software that BlackRock will use in the process, already watches over more than $20 trillion, with a client base including insurers, pensions and fellow asset managers

March 23, 2020

  Given the Coronavirus crisis, how can the Federal Reserve be closing the public comment period on mergers on which public hearings can be requested? We'll have more on this, from Inner City Press and Fair Finance Watch which is also raising the issue to the other bank regulatory agencies.

March 16, 2020

  On March 14 President Trump said of Jerome Powell, I could remove him, or demoted him to regular Governor status and appoint another Chair.

 How long can this go on?

March 9, 2020

  It begins: "After careful consideration of the growing public health concerns associated with the coronavirus (COVID-19), the organizing sponsors of the 2020 National Interagency Community Reinvestment Conference (NICRC), scheduled March 9-12 in Denver, Colorado, have made the decision to postpone the conference.  The Federal Reserve, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation jointly made this decision out of an abundance of caution to help safeguard the health and well-being of the more than 1,300 registered conference participants.  The NICRC planning team is working to confirm a date to reschedule the conference as soon as possible later this year. "

March 2, 2020

 Look who's promoting Joe Otting and his assault on CRA, March 10 in Denver: "Esther L. George President and CEO Federal Reserve Bank of Kansas City  introduced by  Jackson Winsett Assistant Vice President and Community Affairs Officer Federal Reserve Bank of Kansas City  Remarks on Modernizing the CRA  Joseph M. Otting Comptroller of  the Currency  introduced by  Barry Wides Deputy Comptroller for Community Affairs Office of the Comptroller of the Currency."

February 24, 2020

Morgan Stanley, Made a Bank Holding Company Without Comment by FRB, Now Makes $13B Offers For E-Trade, Highlighting Community Reinvestment Act Fight

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

SOUTH BRONX, Feb 20 –   Morgan Stanley's proposed $13 billion takeover of E-Trade Bank not only might trigger other acquisitions: it also steps right in the middle of a bank deregulatory move in which E-Trade Bank was almost shielded from the Community Reinvestment Act by rogue US Comptroller of the Currency Joseph Otting. Fair Finance Watch and Inner City Press will be raising the issues.

February 17, 2020

Community Reinvestment Act Attack by Otting Triggers Fed Powell Half True Answer in House

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

SOUTH BRONX, Feb 11–   The current US Comptroller of the Currency Joseph Otting cashed out of his position with OneWest Bank in California by overseeing fake comments in favor its acquisition by the CIT Group.

   Then, emboldened, he devoted the Office of the Comptroller of the Currency to weakening or destroying the Community Reinvestment Act which provides for the public process that he subverted with fake comments.

  On February 11, Federal Reserve chairman Jerome Powell answered but was not held to task on the CRA. Rep. Nydia Velazquez, D-N.Y., asked Powell if he "would agree... that it's more important to get the rule right than to do it quickly."

"Yes, I mean I think that's been our approach and will continue to be," Powell said in response. 

 But the Fed's approach has also been to allow applicants like Banco Bradesco to withhold for a month their answers in CRA protested proceedings. We'll have more on this.

   Inner City Press, which along with CRC opposed the merger and then pursued a Freedom of Information Act request for all documents about Otting's fraud, soon found its and Fair Finance Watch's comments to the OCC being rejected, or ignored, or returned. 

  While Inner City Press' FOIA requests get fee waivers from the Federal Reserve and a range of agencies in the US and beyond, Otting's OCC suddenly started denying them, hindering access to the merger applications on which CRA is enforced.   

Otting is trying to push through this CRA-killing proposal on a short comment period, cognizant of the other CRA, the Congressioal Review Act. But it is obvious that even banks want more time.

On January 26, in advance of Otting's belated January 29 House of Representatives appearance, Inner City Press / Fair Finance Watch submitted a formal comment, and since then another. Watch this site.

February 10, 2020

Received from an increasingly untransparent US Federal Reserve: all portions that Banco Bradesco chose ot withheld, and late-send, will be withheld. Well, we will be appealing. Watch this site.

February 3, 2020

  While some are praising the Federal Reserve on CRA, note that when Banco Bradesco without explanation withheld its submission from Fair Finance Watch during a CRA protest, the Fed ignored it, leading Bradesco's lawyer Reena Agrawal Sahni to arrogantly write to the Fed, smail mail to Inner City Press, that "we do not believe that there was been any gaming of a system." Well, we do - no explanation of withholding the document for a month is even offered. In a court, there would be sanctions for contempt. At the Fed, with banks? It's all among friends. We'll have more on this.

January 27, 2020

 Here a report Inner City Press is looking into: Iraqi Union Bank is owned by the brothers Aqil and Ali Muftin, who according to the report have close ties with pro-Iran former Iraqi PM Nuri al-Maliki.  In 2016, the American Federal Reserve placed $200 million of the bank's funds on hold due to suspicion of corruption.

 But the Fed's slow and worse response to FOIA on Bangladesh Bank does not bode well..

January 20, 2020

To Fed Bradesco Late Sent CRA Redacted Info to Inner City Press But FRBNY Ignores It

By Matthew R. Lee, Exclusive

SOUTH BRONX, SDNY, Jan 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.

On December 12 on a two and a half week delay the Federal Reserve sent Inner City Press a terse summary of an ex parte meeting it held with Bradesco. The delay was not explained; if the past is any guide, this may just be the Fed ticking the boxes in order to rubber stamp Bradesco's application despite its record.

  Now the Fed has entirely ignored evidence that Banco Bradesco and its outside law firm gamed the system and violated the Fed's own Rules Against Ex Parte Communications by withholding for a month from Inner City Press a letter they emailed to Fed - and snail mailed a month late to Inner City Press.

   And the Fed's delay spawned even more outrageous behavior by Bradesco and its outside law firm Shearman and Sterling. Inner City Press / Fair Finance Watch on January 11 complainted to the Federal Reserve Board: "Re: Outraged Supplemental Comment on Application by Banco Bradesco to acquire BAC Florida in Extraordinary Circumstances: redacted CRA answer of Dec 11 sent to us Jan 9 

Dear Chair Powell, Secretary Misback and others in the FRS:  

This is a supplemental comment opposing and requesting redacted information late sent -- cynically mailed a month late - and in this connection an extension of the FRB's public comment period on the Application by Banco Bradesco to acquire BAC Florida.    As we stated in August, 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.       Troublingly, today I received in regular mail an envelope mailed on January 9 by Bradesco's outside law firm. Inside the envelope was a submission including about CRA, redacted - and the letter to the Fed was dated December 11, four weeks prior.   

So Bradesco is trying to redacted CRA information - and cynically snail mailed its submission to Inner City Press four weeks after they submitted it to the Fed.   

We have today submitted a FOIA request for all of the redacted information - in fact, it should be provided forthwith under the Ex Parte Rules. But the Fed must act on this, the four week delay. The comment period must be reopened and this application should - must - be denied. Otherwise banks will game the system and the Fed simply accept it. This letter should be responded to forthwith."

 But here on January 15 is the Federal Reserve Bank's non-responsive response: "Dear Mr. Lee:  January 15, 2020  We acknowledge receipt on January 13, 2020 of your e-mail dated January 11, 2020 ("Comment Letter"), commenting on the application submitted by Banco Bradesco, S.A., Lecce Holdings S.A., Fundacao Bradesco, BBD Partipacoes S.A., Nova Cidade de Deus Participacoes S.A., and Cidade de Deus Cia. Comercial de Participcoes ( collectively, the "Applicants"), all of Osasco, Sao Paulo, Brazil for prior approval of the Board of Governors of the Federal Reserve System (the "Board") pursuant to Section 3(a)( I) of the Bank Holding Company Act of 1956, as amended, and Section 225.15 of Regulation Y, to become bank holdings companies by acquiring substantially all of the shares of SAC Florida Bank, Coral Gables, Florida. The Board generally provides a period of at least 30 days for interested members of the public to comment on applications submitted under the BHC Act. See 12 C.F.R. §§ 225.16 and 262.3(e). Comments received after the end of the public comment period generally will not be made pa1i of the record considered by the Board, though the Board may, in its sole discretion and without notifying the paiiies, take into consideration the substance of late comments. See 12 C.F.R. § 262.3( e ). The public comment period for this application ended on August 12, 2019. Since your Comment Letter was received after the end of the public comment period, it will not be made a part of the record of this application unless the Board in its sole discretion determines to consider your late comments. By email dated August 10, 2019, however, you previously submitted timely comments that have been made a part of the application record that the Board will consider. Sincerely,  cc: Board of Governors Reena Sahni, Esq.- Shearman & Sterling LLP  ~ Brian S. Steffey Assistant Vice President Bank Applications Function." Really? Watch this site.

January 13, 2020

To Fed Bradesco Late Sends Community Reinvestment Act Redacted Info to Fair Finance Watch

By Matthew R. Lee, Exclusive

SOUTH BRONX, SDNY, Jan 11 – 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.

On December 12 on a two and a half week delay the Federal Reserve sent Inner City Press a terse summary of an ex parte meeting it held with Bradesco. The delay was not explained; if the past is any guide, this may just be the Fed ticking the boxes in order to rubber stamp Bradesco's application despite its record.

   And the Fed's delay spawned even more outrageous behavior by Bradesco and its outside law firm Shearman and Sterling. Inner City Press / Fair Finance Watch on January 11 complainted to the Federal Reserve Board: "Re: Outraged Supplemental Comment on Application by Banco Bradesco to acquire BAC Florida in Extraordinary Circumstances: redacted CRA answer of Dec 11 sent to us Jan 9 

Dear Chair Powell, Secretary Misback and others in the FRS:  

This is a supplemental comment opposing and requesting redacted information late sent -- cynically mailed a month late - and in this connection an extension of the FRB's public comment period on the Application by Banco Bradesco to acquire BAC Florida.    As we stated in August, 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.       Troublingly, today I received in regular mail an envelope mailed on January 9 by Bradesco's outside law firm. Inside the envelope was a submission including about CRA, redacted - and the letter to the Fed was dated December 11, four weeks prior.   

So Bradesco is trying to redacted CRA information - and cynically snail mailed its submission to Inner City Press four weeks after they submitted it to the Fed.   

We have today submitted a FOIA request for all of the redacted information - in fact, it should be provided forthwith under the Ex Parte Rules. But the Fed must act on this, the four week delay. The comment period must be reopened and this application should - must - be denied. Otherwise banks will game the system and the Fed simply accept it. This letter should be responded to forthwith." Watch this site.

January 6, 2020

  Last week Inner City Press reported on its complaint to the Federal Reserve about the Fed having hid merger proposals until the comment periods closed. Now they've posted a few - but no written response to the complaint or the formal requests in it. We'll have more on this.

December 30, 2019

Community Reinvestment Act Assault By OCC Joined In By Federal Reserve Hiding Mergers CFPB Hiding Data

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

SDNY / BRONX, Dec 28 – The assault against the U.S. Community Reinvestment Act, begun by Comptroller of the Currency Joseph Otting then joined in by the FDIC and the Consumer Financial Protection Bureau withholding mortgage data, has reached the Federal Reserve. 

 For months the Federal Reserve has first slowed down its disclosure of pending merger applications on which the public can comment under CRA, and now outright hide them, such that on its website no proposed mergers have open comment periods. Call it the death, or attempted murder, of the Community Reinvestment Act.

  Alongside comments to the OCC and FDIC, Inner City Press / Fair Finance Watch on December 28 filed comments with the Federal Reserve: Dear Chair Powell, Secretary Misback, others in FRB:   On behalf of Inner City Press / Fair Finance Watch and in my personal capacity, this is questionlessly tiemly protest to one sample application, a complaint about the FRB's failure update its H2A, and on the withholding of 2018 HMDA data in online form by CFPB and other FFIEC regulators including the FRB - and a demand for actions.     Currently as of December 28, the most recent application on the FRB's online H2A has a comment period ending December 20 - that is, already closed. This negligence, or intentional exclusion of the public, has been the case at the FRB for months. All comment periods must be re-opened.    

Here is a timely protest to one sample application that (only) the Federal Register tells us has a comment period expiring "not later than December 30, 2019.A. Federal Reserve Bank of Chicago (Colette A. Fried, Assistant Vice President) 230 South LaSalle Street, Chicago, Illinois 60690-1414:1. Bosshard Financial Group, Inc., La Crosse, Wisconsin; to merge with Northern Bankshares, Inc., and thereby indirectly acquire Mc  Farland State Bank, both of McFarland, Wisconsin.Board of Governors of the Federal Reserve System, November 25, 2019."    

Second and more systematic problem, that must be solved or all comment periods extended: the Consumer Financial Protection Bureau for 2018 data has unilaterally removed the ability of the public to view HMDA data by race on its website, which the FFIEC / Federal Reserve allowed in previous years and the CFBP did even in 2017. Inner City Press / Fair Finance Watch contends that the CFPB's move is both anti-public and illegal.     

Given this situation, which must be addressed, for now Inner City Press timely submitted the two attached photos from the CFPB's disturbingly and intentionally stripped down site. In 2018 in Wisconsin, McFarland made 206 loans to white, and only three to African Americans. This is an interim protest; the comment period(s) must be extended.  

Here are some more applications not in the FRB's H2A, requiring explanation and extension of comment periods: 

not later than December 20, 2019.  A. Federal Reserve Bank of Atlanta (Kathryn Haney, Assistant Vice President) 1000 Peachtree Street NE, Atlanta, Georgia 30309. 1. BCI Financial Group, Inc., Miami, Florida; to merge with Executive Banking Corporation, and thereby indirectly acquire Executive National Bank, both of Miami, Florida. In connection with this proposal, Bci Financial Group, Inc.'s parent companies, Empresas Juan Yarur SpA and Banco de Credito e Inversiones S.A., both of Santiago, Chile, to indirectly acquire Executive Banking Corporation and Executive National Bank.   not later than December 20, 2019.  A. Federal Reserve Bank of St. Louis (David L. Hubbard, Senior Manager) P.O. Box 442, St. Louis, Missouri 63166-2034. 1. Citizens Union Bancorp of Shelbyville, Inc., Shelbyville, Kentucky; to merge with Owenton Bancorp, Inc., and thereby indirectly acquire Peoples Bank & Trust Company, both of Owenton, Kentucky.   

not later than January 23, 2020.  A. Federal Reserve Bank of St. Louis (David L. Hubbard, Senior Manager) P.O. Box 442, St. Louis, Missouri 63166-20341. Comments can also be sent electronically to Comments.applications@stls.frb.org:   First Horizon National Corporation, Memphis, Tennessee; to acquire IBERIABANK Corporation and thereby indirectly acquire IBERIABANK, both of Lafayette, Louisiana.   

B. Federal Reserve Bank of New York (Ivan Hurwitz, Senior Vice President) 33 Liberty Street, New York, New York 10045-0001. . Barclays US Holdings Limited, New York, New York; a company organized under the laws of the Cayman Islands, to become a bank holding company by acquiring Barclays US LLC, also of New York, New York, and thereby indirectly acquire Barclays Bank Delaware, Wilmington, Delaware. In addition, Barclays PLC and Barclays Bank PLC, both of London, England, to retain Barclays US Holdings Limited and thereby indirectly acquire Barclays US LLC and Barclays Bank Delaware.  

not later than January 9, 2020.  A. Federal Reserve Bank of New York (Ivan Hurwitz, Senior Vice President) 33 Liberty Street, New York, New York 10045  1. First Bancorp, San Juan, Puerto Rico; to acquire Santander BanCorp and thereby indirectly acquire Banco Santander Puerto Rico, both of San Juan, Puerto Rico. In addition, FirstBank Puerto Rico, San Juan, Puerto Rico, to become a bank holding company for a moment in time by acquiring Santander BanCorp and thereby indirectly acquiring Banco Santander Puerto Rico.

      In this context, Inner City Press / Fair Finance Watch is demanding an extension of all comment periods by the FRB, its intervention with the CFPB to restore access on the website itself to 2018 HMDA data, and on the current record the denial by the FRB of these application(s). Thank you for your prompt attention, Matthew R. Lee Inner City Press / Fair Finance Watch

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