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December
9, 2024
First Busey $1B Bid For CrossFirst Hit by Fair Finance Watch Now Fed Asks Sealed Question
by
Matthew R.
Lee, Patreon Substack
FEDERAL COURT, Dec 5
–
In the Midwest, Busey Bank is trying to move
into the Kansas City area via merger, with a
disparate lending record. Fair Finance Watch
with Inner City Press on the FOIA has filed a
timely first comment on, the Applications
Van Dukeman, First Busey's CEO called it a
"great fit from a cultural perspective." But
consider Busey Bank's culture - including
contempt for CRA, its disparate lending
record:
First
Busey's Busey Bank in Illinois in 2023 - data
not yet included in any CRA exam - made 1163
mortgage loans to whites, and only 772 loans to
African Americans. Meanwhile it denied only 216
applications from whites, and fully 24 from
African Americans. Busey Bank should be referred
to DOJ.
Busey
Bank in Missouri in 2023 - data not yet included
in any CRA exam - made 49 mortgage loans to
whites, and only seven loans to African
Americans. Meanwhile it denied only 21
applications from whites, and fully eight from
African Americans
Busey
Bank in Indiana in 2023 - data not yet included
in any CRA exam - made 22 mortgage loans to
whites, and only two loans to African
Americans.
Busey
Bank in Florida in 2023 - data not yet included
in any CRA exam - made 80 mortgage loans to
whites, and only ONE loan to an African
American.
Rather
than provide CRA info, First Busey's Monica L.
Bowe, Executive Vice President & Chief Risk
Officer of First Busey Corporation - and of the
Risk Management Association- submitted a letter
saying CRA conditions are never attached -
false, and telling.
Now
after questions Busey's outside counsel has
disclosed that Busey "has been the target of
multiple law firms’ efforts to solicit customers
via the internet to bring a mass arbitration
based on overdraft and NSF fees, specifically
Authorize Positive, Settle Negative and
Representment fees, both of which Busey Bank
stopped charging in 2022. Busey Bank first
became aware of these solicitations in February,
2024. Representatives of Busey have spoken with
representatives of some of these law firms and
have received demands for attorneys’ fees and
potential refunding of certain fees and Busey
management is currently discussing the path
forward with counsel."
On
December the Federal Reserve cc-ed Inner City
Press on its question to Busey Bank - but the
question was entirely withheld.
That's today Fed.
The
merger should be denied. Watch this site.
***
December
2, 2024
UMB Bank Application for Heartland Hit on Disparties Info Withheld Now Won Under FOIA
by
Matthew R.
Lee, Patreon Substack
SOUTH BRONX /
SDNY, Nov 29
–
When First Republic Bank failed / was given to
JP Morgan Chase, a small list of other regional
banks came into focus as in danger. Among them
was UMB - a bank whose lending Inner City Press
and Fair Finance Watch had been scrutinizing,
and now challenge.
UMB is asking its regulators to allow it to
expand, buying Denver-based Heartland. The
application, Fair Finance Watch on June 21
formally told the Fed, should not be
approved. In 2022, the most recent
year for which Federal data is available, UMB
Bank, N.A. made over 2000 mortgage loans to
whites, and only 117 loans to African Americans.
For
every denial to an African American, it made
only 2.02 loans. But for whites, for every
denial it made 3.45 loans. It should be referred
to DOJ.
There
is litigation, there is also this, reported at
the time of Silicon Valley Bank's failure: "UMB
Bank, a regional bank headquartered in Kansas
City, Missouri, and with branches across the
Midwest, Southwest, and Western United States,
has total assets of $38 billion and deposits
totaling $32 billion, according to the FDIC.
However, only 16% of deposits fall under the
$250,000 FDIC insurance threshold, leaving
74.11% (equivalent to $28.36 billion) vulnerable
to potential losses."
Why
would regulators even consider approving its
expansion? On June 21, Fair Finance Watch filed
a formal Community Reinvestment Act challenge to
UMB's application to the Federal Reserve, adding
state by state data:
UMB Bank in 2022 in Missouri made 842 mortgage
loans to whites, and only 76 loans to African
Americans. Meanwhile it denied 41 applications
from African Americans, and only 257 from
whites.
UMB Bank in Colorado - in which it seeks to
expand - in 2022 made 378 mortgage loans to
whites, and only 13 loans to African Americans.
Meanwhile it denied six applications from
African Americans, and only 107 from whites.
UMB Bank in 2022 in Texas made 78 mortgage loans
to whites, and only six loans to African
Americans. Meanwhile it denied two applications
from African Americans, and only 27 from
whites.
These disparities cry out for a referral to DOJ,
and public hearings on, and denial of, UMB's
major expansion application.
On
October 11 UMB's outside counsel Davis Polk sent
the Fed a response but withheld branch closing,
subsidiary, fintech and crypto information from
Fair Finance Watch - so Inner City Press cc-ed
them on a FOIA request.
On
November 29, the Fed responded with the branch
closing list and more - now on Inner City Press'
DocumentCloud here.
Watch
this site.
***
November
25, 2024
First Busey $1B Bid For CrossFirst Hit by Fair Finance Watch Now They Disclose Legal Threat
by
Matthew R.
Lee, Patreon Substack
FEDERAL COURT, Nov 20
–
In the Midwest, Busey Bank is trying to move
into the Kansas City area via merger, with a
disparate lending record. Fair Finance Watch
with Inner City Press on the FOIA has filed a
timely first comment on, the Applications
Van Dukeman, First Busey's CEO called it a
"great fit from a cultural perspective." But
consider Busey Bank's culture - including
contempt for CRA, its disparate lending
record:
First
Busey's Busey Bank in Illinois in 2023 - data
not yet included in any CRA exam - made 1163
mortgage loans to whites, and only 772 loans to
African Americans. Meanwhile it denied only 216
applications from whites, and fully 24 from
African Americans. Busey Bank should be referred
to DOJ.
Busey
Bank in Missouri in 2023 - data not yet included
in any CRA exam - made 49 mortgage loans to
whites, and onlyseven loans to African
Americans. Meanwhile it denied only 21
applications from whites, and fully eight from
African Americans
Busey
Bank in Indiana in 2023 - data not yet included
in any CRA exam - made 22 mortgage loans to
whites, and only two loans to African
Americans.
Busey
Bank in Florida in 2023 - data not yet included
in any CRA exam - made 80 mortgage loans to
whites, and only ONE loan to an African
American.
Rather
than provide CRA info, First Busey's Monica L.
Bowe, Executive Vice President & Chief Risk
Officer of First Busey Corporation - and of the
Risk Management Association- submitted a letter
saying CRA conditions are never attached -
false, and telling.
Now
after questions Busey's outside counsel has
disclosed that Busey "has been the target of
multiple law firms’ efforts to solicit customers
via the internet to bring a mass arbitration
based on overdraft and NSF fees, specifically
Authorize Positive, Settle Negative and
Representment fees, both of which Busey Bank
stopped charging in 2022. Busey Bank first
became aware of these solicitations in February,
2024. Representatives of Busey have spoken with
representatives of some of these law firms and
have received demands for attorneys’ fees and
potential refunding of certain fees and Busey
management is currently discussing the path
forward with counsel."
November
18, 2024
UMB Bank Application for Heartland Hit on Disparties Info Withheld Now FOIA Delay
by
Matthew R.
Lee, Patreon Substack
SOUTH BRONX /
SDNY, Nov 12
–
When First Republic Bank failed / was given to
JP Morgan Chase, a small list of other regional
banks came into focus as in danger. Among them
was UMB - a bank whose lending Inner City Press
and Fair Finance Watch had been scrutinizing,
and now challenge.
UMB is asking its regulators to allow it to
expand, buying Denver-based Heartland. The
application, Fair Finance Watch on June 21
formally told the Fed, should not be
approved. In 2022, the most recent
year for which Federal data is available, UMB
Bank, N.A. made over 2000 mortgage loans to
whites, and only 117 loans to African Americans.
For
every denial to an African American, it made
only 2.02 loans. But for whites, for every
denial it made 3.45 loans.
On
June 21, Fair Finance Watch filed a formal
Community Reinvestment Act challenge to UMB's
application to the Federal Reserve, adding state
by state data:
UMB Bank in 2022 in Missouri made 842 mortgage
loans to whites, and only 76 loans to African
Americans. Meanwhile it denied 41 applications
from African Americans, and only 257 from
whites.
UMB Bank in Colorado - in which it seeks to
expand - in 2022 made 378 mortgage loans to
whites, and only 13 loans to African Americans.
Meanwhile it denied six applications from
African Americans, and only 107 from whites.
UMB Bank in 2022 in Texas made 78 mortgage loans
to whites, and only six loans to African
Americans. Meanwhile it denied two applications
from African Americans, and only 27 from
whites.
These disparities cry out for a referral to DOJ,
and public hearings on, and denial of, UMB's
major expansion application.
On
October 11 UMB's outside counsel Davis Polk sent
the Fed a response but withheld branch closing,
subsidiary, fintech and crypto information from
Fair Finance Watch - so Inner City Press cc-ed
them on a FOIA request for:
This
is a formal FOIA request for the withheld
exhibits to UMB's October 11 submission to the
Federal Reserve in connection with its protested
application to acquire Heartland Financial, in
particular "Confidential" Exhibits A and B,
including about fintech and branch closings and
all activities engaged in by corporate
subsidiaries. This is presumptively public; if
any is withheld, all reasonably segregable
portions should be provided.
UMB
recites and responds: 1. Provide a description
of the activities conducted by the following UMB
subsidiaries: a. UMBCDC, Inc., Kansas City,
Missouri; b. UMB Financial Services, Inc.,
Kansas City, Missouri; c. UMB Management Equity
Holdings Inc., Kansas City, Missouri; d. UMB
Merchant LLC, Kansas City, Missouri; and e. UMB
Asset Management, LLC, Kansas City, Missouri The
requested information is included in AIR
Confidential Exhibit A. Convenience and Needs 2.
Provide an update on UMB Bank’s branch
consolidation analysis and confirm whether any
of the branches listed in Public Exhibit 3 of
the Additional Information Response, dated
August 5, 2024 (“August AI Response”) would be
consolidated, following consummation of the
proposed transaction. The requested information
is included in AIR Confidential Exhibit B.
Discuss any plans to engage in
crypto-asset-related activities or fintech
partnerships. The requested information is
included in AIR Confidential Exhibit
A.
Again,
this is both important for the public to know
and is presumptively public; if any is withheld,
all reasonably segregable portions should be
provided.
On
November 12 - a month after the request - the
Fed wrote that it was unilaterally extending its
time to respond to November 26.
Watch
this site.
***
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November
11, 2024
First Busey $1B Bid For CrossFirst Hit by Fair Finance Watch Info Hidden Now FOIA Delay
by
Matthew R.
Lee, Patreon Substack
FEDERAL COURT, Nov 4 –
In the Midwest, Busey Bank is trying to move
into the Kansas City area via merger, with a
disparate lending record. Fair Finance Watch
with Inner City Press on the FOIA has filed a
timely first comment on, the Applications
Van Dukeman, First Busey's CEO called it a
"great fit from a cultural perspective." But
consider Busey Bank's culture - including
contempt for CRA, its disparate lending
record:
First
Busey's Busey Bank in Illinois in 2023 - data
not yet included in any CRA exam - made 1163
mortgage loans to whites, and only 772 loans to
African Americans. Meanwhile it denied only 216
applications from whites, and fully 24 from
African Americans. Busey Bank should be referred
to DOJ.
Busey
Bank in Missouri in 2023 - data not yet included
in any CRA exam - made 49 mortgage loans to
whites, and onlyseven loans to African
Americans. Meanwhile it denied only 21
applications from whites, and fully eight from
African Americans
Busey
Bank in Indiana in 2023 - data not yet included
in any CRA exam - made 22 mortgage loans to
whites, and only two loans to African
Americans.
Busey
Bank in Florida in 2023 - data not yet included
in any CRA exam - made 80 mortgage loans to
whites, and only ONE loan to an African
American.
There
is litigation, for example under the FCRA, here
- dropped without explanation, presumable
settled, the FRB should ask First Busey about
all outstanding consumer litigation.
And
there was the First Busey board member,
Elisabeth Kimmel, caught in the college
admissions scandal, here.
When
the Fed provided the application, the banks had
withheld their CRA data. So, "This is a formal
FOIA request for the withheld exhibits to the
First Busey / CrossFirst application, in
particular "Confidential" Exhibits 9 ("First
Busey Community Reinvestment Act Data") and 10
("CrossFirst Community Reinvestment Act data").
This is presumptively public."
Rather
than provide the CRA info, First Busey's Monica
L. Bowe, Executive Vice President & Chief
Risk Officer of First Busey Corporation - and of
the Risk Management Association- submitted a
letter saying CRA conditions are never attached
- false, and telling.
Inner
City Press' FOIA request? The Fed on November 4
extended its time to reply - and unlike other
less arrogant banks, First Busey has provided
nothing. Watch this site.
***
November
4, 2024
Today's
FRB gives out
gifts to
redliners in
secret. Consider:
St. Louis
German
American
Bancorp, Inc.,
Jasper,
Indiana—waiver
of application
to acquire
Heartland
BancCorp,
Whitehall,
Ohio, and
simultaneously
merge
Heartland
Bank,
Whitehall,
Ohio, with and
into German
American Bank,
Jasper,
Indiana.
Granted:
October 22,
2024
From
September,
ongoing: Fair
Finance Watch
has been
concerned for
some time with
German
American
Bank's
outreach /
image and
lending. In
Indiana in
2023 - in HMDA
data not yet
taken into
account in any
CRA exam -
German
American Bank
based on its
marketing made
1743 mortgage
loans to
whites, and
only SIXTEEN
loans to
African
Americans.
Meanwhile it
denied 11
applications
from African
Americans, and
only 356 from
whites
October
28, 2024
From
the FRB of Chicago:
"Dear Matthew:
This is in
reference to
the filing by
First Busey
Corporation,
Champaign,
Illinois, to
merge with
CrossFirst
Bankshares,
Inc., Leawood,
Kansas
(“Applicant”),
and thereby
indirectly
acquire
CrossFirst
Bank, Leawood,
Kansas. This
will
acknowledge
receipt of
your comment
email dated
October 15,
2024. Your
comment has
been accepted
by the Federal
Reserve Bank
of Chicago
(“Reserve
Bank”)
relative to
this filing
and will be
made a part of
the record. A
copy of your
comment has
been forwarded
to Applicant
for an
opportunity to
respond and if
Applicant
responds, you
will be
provided a
copy of the
response. To
the extent the
comment letter
and request
for a hearing
dated October
15, 2024, also
seeks records
under the
Freedom of
Information
Act (“FOIA”),
it does not
comply with
section
261.11(a)(2)
of the Board’s
Rules relating
to the
submission of
FOIA requests
because you
have combined
a request for
records with
comments on an
application
and a hearing
request, 12
CFR
261.11(a)(2).
This
correspondence,
therefore,
will not be
processed as a
FOIA request.
Accordingly,
if you seek
information
under the
FOIA, you may
submit a
separate
request to the
Board’s
Freedom of
Information
Office that
complies with
the
requirements
of section
261.11 of the
Board’s
Rules."
But on FOIA
requests, even
when the Board
grants expedited
processing, no
records are
received on a
timely
basis...
October
21, 2024
Expedited? From
the Fed: This is
in response to
your
electronic
message dated
and received
by the Board
on October 11,
2024. Pursuant
to the Freedom
of Information
Act (“FOIA”),
5 U.S.C. §
552, you
request:
the withheld
exhibits to
UMB’s October
11 submission
to the Federal
Reserve in
connection
with its
protested
application to
acquire
Heartland
Financial, in
particular
“Confidential”
Exhibits A and
B, including
about fintech
and branch
closings and
all activities
engaged in by
corporate
subsidiaries.
You have
requested
expedited
processing
... I
have
determined to
grant your
request for
expedited
processing
because (1)
you are
primarily
engaged in
disseminating
information,
and (2) the
application
you seek is
pending with
the Board.
Accordingly,
your request
will be
processed as
soon as
practicable
and ahead of
other FOIA
requests.
We'll see.
October
14, 2024
On First Busey,
Inner City
Press has been
granted
expedited
processing: "I
have
determined to
grant your
request for
expedited
processing
because (1)
you are
primarily
engaged in
disseminating
information,
and (2) the
application
you seek is
open for"
comment...
October
7, 2024
First Busey $1B Bid For CrossFirst Hit by Fair Finance Watch As CRA Exhibits Withheld
by
Matthew R.
Lee, Patreon Substack
FEDERAL COURT, Oct
4 –
In the Midwest, Busey Bank is trying to move
into the Kansas City area via merger, with a
disparate lending record. Fair Finance Watch
with Inner City Press on the FOIA has filed a
timely first comment on, the Applications
Van Dukeman, First Busey's CEO called it a
"great fit from a cultural perspective." But
consider Busey Bank's culture, its disparate
lending record:
First
Busey's Busey Bank in Illinois in 2023 - data
not yet included in any CRA exam - made 1163
mortgage loans to whites, and only 772 loans to
African Americans. Meanwhile it denied only 216
applications from whites, and fully 24 from
African Americans. Busey Bank should be referred
to DOJ.
Busey
Bank in Missouri in 2023 - data not yet included
in any CRA exam - made 49 mortgage loans to
whites, and onlyseven loans to African
Americans. Meanwhile it denied only 21
applications from whites, and fully eight from
African Americans
Busey
Bank in Indiana in 2023 - data not yet included
in any CRA exam - made 22 mortgage loans to
whites, and only two loans to African
Americans.
Busey
Bank in Florida in 2023 - data not yet included
in any CRA exam - made 80 mortgage loans to
whites, and only ONE loan to an African
American.
There
is litigation, for example under the FCRA, here
- dropped without explanation, presumable
settled, the FRB should ask First Busey about
all outstanding consumer litigation.
And
there was the First Busey board member,
Elisabeth Kimmel, caught in the college
admissions scandal, here.
When
the Fed provided the application, the banks had
withheld their CRA data. So, "This is a formal
FOIA request for the withheld exhibits to the
First Busey / CrossFirst application, in
particular "Confidential" Exhibits 9 ("First
Busey Community Reinvestment Act Data") and 10
("CrossFirst Community Reinvestment Act data").
This is presumptively public." Watch this site.
***
September
30, 2024
The Fed
has granted
expedited
processing,
they say, to
Inner City
Press'
SouthState
FOIA - but
still no
documents...
September
23, 2024
SouthState Lending Disparities Triggered CRA Challenge Now after FOIA Withheld Exhibit 18
by
Matthew R.
Lee, Patreon Substack
SOUTH BRONX /
SDNY, Sept
19 –
When First Republic Bank failed / was given to
JP Morgan Chase, a small list of other regional
banks came into focus as in danger, banks whose
lending Inner City Press and Fair Finance Watch
had been scrutinizing, even more so that the
2023 data is out.
This week Inner City Press filed with the Fed, a
timely first comment on, the Applications of
SouthState Corporation to merge with Independent
Bank Group, Inc., and Independent
Bank.
SouthState in South Carolina in 2023 - data not
yet included in any CRA exam - made 5013
mortgage loans to whites, and only 228 loans to
African Americans. Meanwhile it denied only 670
applications from whites, and fully 195 from
African Americans. SouthState should be referred
to DOJ.
SouthState in North Carolina in 2023 - data not
yet included in any CRA exam - made 1334
mortgage loans to whites, and only FIFTY SEVEN
loans to African Americans. Meanwhile it denied
only 173 applications from whites, and fully 20
from African Americans.
SouthState in Georgia in 2023 - data not yet
included in any CRA exam - made 1176 mortgage
loans to whites, and only 318 loans to African
Americans. Meanwhile it denied only 304
applications from whites, and fully 88 from
African Americans.
Nationwide
in 2023, SouthState made 7798 mortgage loans to
whites, and only 947 loans to African Americans.
Meanwhile it denied only 2491 applications from
whites, and fully 558 from African
Americans.
Why would regulators even consider approving its
expansion?
On
August 9, SouthState submitted to the Fed a
response - that deals only with Independent
Bank.
On
September 18, the Fed asked SouthState questions
including "Confirm that no consumer products or
community development programs or services
offered by either organization will be
discontinued by the combined organization as a
result of the proposed transaction, other than
those identified in Confidential Exhibit 18 to
the application."
Inner
City Press has submitted a FOIA request with the
Fed for that obviously CRA-material Exhibits.
No thanks to the Fed, Inner City Press got the
exhibit - SouthState just withdrew its request
for confidential treatment, of this:
"CONFIDENTIAL SouthState Bank, N.A.
Independent Bank Discontinued Independent
Bank Products and Services June 2024
SSC and IBTX currently plan on discontinuing
Independent Bank’s mortgage warehouse program
and selling its Shared National Credits (SNC)
portfolio. Almost all purchased SNCs are in
Independent Bank’s commercial loan portfolio,
with the largest single industry concentration
in energy."
Inner City Press is requesting an extension of the public comment period, public / virtual evidentiary hearings and that, on the current record, the applications not be approved
***
September
16, 2024
The Fed
is a paper
tiger? Not
only still
nothing on the
Porticoes
application -
on September
11 the Fed
issued an
enforcement
action against
Fieldpoint,
which
immediately
put out "“We
have a strong
partnership
with our
regulators,”
said H.
Russell
Holland,
President and
CEO of
Fieldpoint
Private. "Private
Holdings,
Inc., is the
holding
company of
Fieldpoint
Private Bank
& Trust, a
boutique
private
banking firm
headquartered
in Greenwich,
Connecticut,
with offices
in New York
City, Atlanta
and
Orlando/Winter
Park.
Fieldpoint
Private was
established at
the onset of
the Great
Financial
Crisis by 31
individuals,
including
former
Chairmen and
CEOs of some
of the most
well-known and
successful
financial and
consumer firms
in America."
September
9, 2024
More from the
FRB Chicago,
but from FRBNY,
*still*
nothing on the
Porticoes
application...
September
2, 2024
The Fed
*still* hasn't
sent the
request Porticoes /
"blank
check" bank
application.
But from
the FRB Chicago,
this:
"Pursuant to
your email
request,
attached is
the public
portion of the
below
filing:
ChoiceOne
Financial
Services,
Inc., Sparta,
Michigan to
merge with
Fentura
Financial,
Inc., and
thereby
indirectly
acquire The
State Bank,
both of
Fenton,
Michigan
Please confirm
receipt of
this email
after
verifying that
the document
could be
opened." We
confirmed; OOO
August
26, 2024
And
SouthState's
response -
much of it
confined to a
"Confidential"
exhibit:
Provide the
IBTX
Disclosure
Schedule
referenced in
the Merger
Agreement. A
copy of the
IBTX
Disclosure
Schedule is
attached as
Confidential
Exhibit 1. 3.
Describe in
greater detail
the purpose
and activities
of the various
trusts held by
SouthState and
IBTX that are
described in
the
application.
Both
SouthState and
IBTX have
formed or
acquired
statutory
business
trusts (the
“Trusts”) for
the purpose of
issuing trust
preferred
securities to
investors.
These entities
do not
otherwise
conduct any
business
activities.
Each of the
Trusts has
issued capital
and common
securities and
invested the
proceeds
thereof in an
equivalent
amount of
junior
subordinated
debentures
(the
“Debentures”)
issued by
either
SouthState or
IBTX. The
interest rate
payable on and
the payment
terms of the
Debentures are
the same as
the
distribution
rate and
payment terms
of the
respective
issues of
capital and
common
securities
issued by the
Trusts. The
Debentures are
subordinated
and junior in
right of
payment to all
present and
future senior
indebtedness.
SouthState and
IBTX have
fully and
unconditionally
guaranteed the
obligations of
their
respective
Trusts with
respect to the
capital and
common
securities.
Except under
certain
circumstances,
the common
securities
issued to
SouthState or
IBTX by their
respective
Trusts possess
sole voting
rights with
respect to
matters
involving
those
entities.
Under certain
circumstances,
SouthState and
IBTX may, from
time to time,
defer the
debentures'
interest
payments,
which would
result in a
deferral of
distribution
payments on
the related
trust
preferred
securities.
The Debentures
are callable
after five
years from the
date of
issuance,
therefore all
Debentures
formed or
acquired by
SouthState and
IBTX are
callable as of
June 30, 2024.
SouthState and
IBTX have
$118.6 million
and $57.3
million of
Debentures,
respectively,
outstanding as
of June 30,
2024. It is
SouthState’s
intent to
assume all
Trusts
outstanding at
IBTX and treat
the Debentures
as Tier 2
capital for
regulatory
capital
purposes. 4.
Indicate
whether
SouthState or
any of its
subsidiaries
are subject to
any state
community
reinvestment
laws. If
applicable,
explain how
the proposed
transaction
complies with
such law(s).
SouthState
confirms that
neither
SouthState nor
any of its
subsidiaries
are subject to
any state
community
reinvestment
laws. 5.
Confidential
Appendix. For
our responses
to the
information
requested in
the
Confidential
Appendix of
the AIR,
please see the
Confidential
Annex, which
also contains
Confidential
Exhibits 1 and
2.
August 19,
2024