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

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March 25, 2019

On SDNY Bangladesh Bank Heist Case Federal Reserve Delays to April 2 FOIA Response to Inner City Press

By Matthew Russell Lee

FEDERAL COURTHOUSE, March 23 – The Bangladeshi Central Bank which was hacked for $81 million in February 2016, on January 31 sued in the US District Court for the Southern District of New York. Now the first pre-trial conference in the case has been set, for 2 April 2019 before SDNY Judge Lorna G. Schofield. Inner City Press will be there.

To the Federal Reserve, Inner City Press requested records relating to the Fed's role with response officially due in 20 working days. But now this from the Federal Reserve: "Re: Freedom of Information Act Request No. F-2019-00095 Dear Mr. Lee, On February 19, 2019, the Board of Governors (“Board”) received your electronic message dated February 17, pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, for records regarding the Federal Reserve System's [role] including the FRBNY's role in what is known as the Bangladesh Bank hack or cyber heist and assistance provided to Bangladesh Bank and investigative authorities since the heist, including but limited to in connection with the SDNY case Bangladesh Bank v Rizal Commercial Banking Corp et al, U.S. District Court, Southern District of New York, No. 19-00983. Pursuant to section (a)(6)(B)(i) of the FOIA, we are extending the period for our response until April 2, 2019, in order to consult with two or more components of the Board having a substantial interest in the determination of the request. If a determination can be made before April 2, 2019, we will respond to you promptly. It is our policy to process FOIA requests as quickly as possible while ensuring that we disclose the requested information to the fullest extent of the law." And April 2 is the day of the SDNY hearing. We'll have more on this.

In Dhaka, the Criminal Investigation Department which failed to submit its probe report into the heist on time has now been ordered by Metropolitan Magistrate Sadbir Yasir Ahsan Chowdhury to do so by March 13 in Bangladesh Bank cyber heist case.

In the U.S. District Court for Central California, the unsealed criminal complaint against Park Jin Hyuk lists four email addresses involved in spear-phishing Bangladesh Bank and among others an unnamed "African Bank;" one of these addresses is said to also have communicated with an individual in Australia about importing commodities to North Korea in violations of UN sanctions.

In the SDNY, the case is Bangladesh Bank v Rizal Commercial Banking Corp et al, U.S. District Court, Southern District of New York, No. 19-00983.

March 18, 2019

Federal Reserve Governor Lael Brainard response to Inner City Press question on information blacked up and no FOIA ruling until after the Fed has approved merger applications: "I certainly can say we will follow up. Generally speaking as I said earlier we think one of the unique and valuable aspects of the CRA is its public nature. That we as examiners and regulators are directed to make ratings and underlying analysis public. And we certainly are looking for ways to have more public input so that we have richer information on performance context, on activities. That public aspect of the CRA is extraordinarily valuable and is one of the things that provides oxygen to that community development ecosystem that I was talking about earlier."

We'll have more on this...

March 11, 2019

As BB&T Tries Taking Over Suntrust Its Susquehanna Abuses Lead To Fine Disparate Lending To Be Raised

By Matthew R. Lee, FOIA docs

SOUTH BRONX, March 6 – When BB&T announced a $66 billion proposal to take over Suntrust Bank, which would close a still undisclosed number of branches and extend BB&T disparate lending patterns, many linked it to deregulatory moves in Washington. These include an assault on the Community Reinvestment Act, being led by Comptroller of the Currency Joseph Otting, who while at OneWest Bank led a false commenting process to push through a merger with CIT Group. (Otting is trying to change the OCC's practices on FOIA fee waivers and is even refusing to consider comments on some Business Combinations. But this BB&T proposal will go to the Fed whose Jerome Powell has vowed, credibly or not, to conduct a full review. And so consider this: BB&T has been ordered to return $5.2 million to investors, according to the Securities and Exchange Commission, over charges it it acquired misled clients about the cost of advisory services. The SEC said the firm that BB&T acquired with Susquehanna Bancshares, known then as Valley Forge Asset Management, misled about 1,200 clients into believing they were receiving full service brokerage services at a discount. We'll have more on this.

Fair Finance Watch, which has been tracking BB&T as well as Otting's and the Federal Reserve's anti-CRA moves, finds that for example in the Atlanta Metropolitan Statistical Area in 2017 BB&T denied the home purchase mortgage applications of African Americans 2.2 times more frequently than whites, while making only 50 such loans to African Americans, and 23 to Latinos, compared to 458 to whites, all more disparate that other lenders in the market.

While some portray the proposed merger as a fait accompli, the Fed and OCC must hold public comment periods and consider the banks' CRA records, even as they race to undermine the law. Inner City Press will submit requests under the Freedom of Information ActMarch 4, 2019

In DC Federal Reserve Powell Spins Rubber Stamp Of WSFS Merger Bad Omen on Suntrust

By Matthew R. Lee, Video, story, FOIA docs

SOUTH BRONX, February 27 – Federal Reserve Board chairman Jay Powell told Congress he will run transparent reviews of mergers like BB&T - Suntrust. But on February 27 while still not acting on Inner City Press' Freedom of Information Act request for withheld information, his Fed Board rubber stamped the application by WSFS to buy Beneficial and close at least 25 branches. This was announced online at 3 pm, with a phone message to Fair Finance Watch which protested the deal an hour later. On Capitol Hill Fed chairman Jay Powell was asked, "could you share the criteria that the Fed uses in evaluating bank merger applications? POWELL: I'd be glad to. So, it's -- it's quite detailed. There's a -- there's a Federal Reserve section that lays out a lot of detail. And there's also plenty of guidance on -- on that issue. Actually, I -- I have a picture of it here. So, we look at competitive factors, making community factors, managerial resources. We -- we look at compliance with consumer and fair lending laws and CRA record and that kind of thing. We look at the combined financials of course of the two companies. We also invite public comment. We have -- we have a pretty thoroughly carefully worked out process. We go through this process carefully for -- for mergers. And look at all those factors and then make a decision." Really? His WSFS order says, "A commenter objected to the proposal alleging, based on data reported under the Home Mortgage Disclosure Act (“HMDA”)25 for 2017, that WSFS Bank denied home purchase mortgage loans to African American and Latino applicants at significantly higher rates than to white applicants in the Wilmington, DelawareMaryland-New Jersey Metropolitan Division (“MD”) and the Salisbury, MarylandDelaware Metropolitan Statistical Area (“MSA”). The commenter also raised concerns regarding branch closures anticipated in connection with the proposed mergers." The comment, which the Fed seems not to want to name in order to try to deny legal standing, is Fair Finance Watch / Inner City Press.
The Fed wrote, "On January 15, 2019, the Board of Governors (“Board”) received your electronic message dated January 15, pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, for all withheld and redacted portions of the submissions by WSFS to the FRS to acquire Beneficial, including but not limited to the absurdly withheld answer to FRB Question 8 about the Community Reinvestme[nt] Act. Pursuant to section (a)(6)(B)(i) of the FOIA, we are extending the period for our response until February 28, 2019, in order to consult with two or more components of the Board having a substantial interest in the determination of the request." And the day before that extension, the Fed rubber stamped the application. We'll have more on this.

February 25, 2019

Here's from the Fed: "This is in reference to your email dated February 17, 2019, and received by the Board's Freedom of Information Office on February 19. Pursuant to the Freedom of Information Act (“FOIA"), 5 U.S.C. $ 552, you request: records regarding the Federal Reserve System's [role] including the FRBNY's role in what is known as the Bangladesh Bank hack or cyber heist and assistance provided to Bangladesh Bank and investigative authorities since the heist, including but limited to in connection with the SDNY case Bangladesh Bank v Rizal Commercial Banking Corp et al, U.S. District Court, Southern District of New York, No. 19-00983. You have requested expedited treatment for your request. The Board's Rules Regarding Availability of Information ("Board's Rules") require a requester to "demonstrate a compelling need for expedited processing." The Board's Rules provide two methods by which this need may be demonstrated. One requires a showing that "[t]he requester is a representative of the news media ... and there is urgency to inform the public concerning actual or alleged Board activity.” The other requires a showing that “[t]he failure to obtain the records on an expedited basis could reasonably be expected to pose an imminent threat to the life or physical safety of an individual.” 12 C.F.R. § 261.13(c). There is nothing in your letter suggesting that there is a compelling need to inform the public on this topic." So the theft of $81 million using the Federal Reserve, there's no compelling need to inform the public?

February 18, 2019
Filed: This is a FOIA request for record regarding the Federal Reserve System's including the FRBNY's role in what is known as the Bangladesh Bank hack or cyber heist and assistance provided to Bangladesh Bank and investigative authorities since the heist, including but limited to in connection with the SDNY case Bangladesh Bank v Rizal Commercial Banking Corp et al, U.S. District Court, Southern District of New York, No. 19-00983

February 11, 2019

Clearing the decks to try to rubber stamp? The Federal Reserve Board on February 7 announced the execution of the enforcement action listed below: Consent Prohibition against Alison Keefe, former employee of SunTrust Bank, Atlanta, Georgia, for violating bank overdraft policies for her own benefit. And there's the proposed BB&T merger...

February 4, 2019

To Federal Reserve Cadence Bank Redacted 80% of Letter Now Fed Extends Time To Unredact Any Of It

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

SOUTH BRONX, January 29 – Cadence Bancorporation which has a disparate lending record while apply to buy State Bank in Georgia and urging faster regulatory approvals, seemingly jumped the gun before having the required Federal Reserve Board approval. Now a new low: a letter that Cadence and its outside counsel, former Federal Reserve lawyer Patricia Robinson, were required to provide a copy to Inner City Press / Fair Finance Watch they on purpose only sent by mail (rather than e-mail), then delayed weeks in resending. Photo here. When it arrived, as intended after the Fed's rubber stamp approva, the letter was more than 80% redacted, arguing for a fast approval. This is a new low, and something we will be confronting and combating in 2019. We have begun with this new FOIA request: "This is a FOIA request for the all withheld and redacted portions of the submissions by Cadence to the FRS to acquire State Bank, including but not limited to the outrageously 80% redacted Nov 1, 2018 letter which Cadence' counsel, rather than emailing to us, sent by mail, one and then twice, the second on Dec 14 AFTER the Fed approved the merger. In this connection we are also request any and all FRB records concerning this and all other Cadence submissions in the last year, and any records reflecting regulatory disciplining by the Fed of banks or BHCs for withholding information in bad faith, for the past three years. Each portions of this request can be considered separately so as to ensure receipt as fast as possible of the unredacted, wrongfully delayed Nov 1, 2018 letter." But now on January 29 the Fed extends its time even further past its approval: "January 29, 2019 Mr. Matthew R. Lee Inner City Press / Fair Finance Watch PO Box 20047 Dag Hammarskjold Station New York, NY 10017 Re: Freedom of Information Act Request No. F-2019-00053 Dear Mr. Lee, On December 28, 2018, the Board of Governors (“Board”) received your electronic message dated December 28, pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, for all withheld and redacted portions of the submissions by Cadence to the FRS to acquire State Bank, including but not limited to the outrageously 80% redacted Nov. 1, 2018 letter; and any and all FRB records concerning this and all other Cadence submissions in the last year, and any records reflecting regulatory disciplining by the Fed of banks or BHCs for withholding information in bad faith, for the past three years. Pursuant to section (a)(6)(B)(i) of the FOIA, we are extending the period for our response until February 12, 2019, in order to consult with two or more components of the Board having a substantial interest in the determination of the request. If a determination can be made before February 12, 2019, we will respond to you promptly. It is our policy to process FOIA requests as quickly as possible while ensuring that we disclose the requested information to the fullest extent of the law. Thank you, Freedom of Information Office Board of Governors of the Federal Reserve System." No thanks.

January 28, 2019

Just how much of a rubber stamp has the Fed become? Inner City Press / Fair Finance Watch timely requested an extension of the Fed's comment period on CenterState Bank - NCC. The Fed's Deputy Secretary nearly automatically denied it in a letter dated January 15, saying that ICP has only until January 21 to comment. But the letter was never emailed to Inner City Press, instead sent by snail mail that arrived AFTER the January 21 deadline. Is it any wonder that a certain law firm, flush with former Fed lawyers, is bragging about how easy it is getting for them at the Fed? We'll have more on this.

January 21, 2019

Amid Targeting of Community Reinvestment Act Fed Delays on FOIA for WSFS No Notices Since Dec 21

By Matthew R. Lee, Video, story, FOIA docs

SOUTH BRONX, January 15 – The US Treasury Department is the next stage of a process to try to weaken and take the community out of the 1977 Community Reinvestment Act. Docket file here. The protagonist, akin to Scott Pruitt when he was at the US Environmental Protection Agency or Ryan Zinke at Interior, is Comptroller of the Current Joseph Otting. On September 12 Fair Finance Watch (and on FOIA, Inner City Press) commented to the OCC, here. At the November 19 deadline, not yet posted was Inner City Press' November 17 fourth comment, just as Otting's OCC absurdly waited 13 days to try to rule it does not have to consider Fair Finance Watch's comments on WSFS Bank's application to acquire Beneficial. Now, after the OCC gleefully closed its comment period on that, WSFS on December 13 announced it will close 25 branches. One would think Otting would have to re-open the comment period. But that's not how Otting rolls. And the Fed, on FOIA and now public notice, is absurd. It has allowed WSFS to withhold its answer on CRA, in a letter it sent late to Inner City Press, while on January 15 the most recent H2A list of applications the public has 30 days to comment on is dated December 21 - nearly 30 days old. And this is not due to the shutdown - the Fed h as its own money. Inner City Press on January 15 submitted: "a FOIA request for all withheld and redacted portions of the submissions by WSFS to the FRS to acquire Beneficial, including but not limited to the absurdly withheld answer to FRB Question 8 about the Community Reinvestment Act ("See Confidential Exhibit 7") in the supposedly New Years Day letter by WSFS which was not emailed to us but rather put in the mail, a week later. (In light of the absuridity we are challenging all withholdings.) In this connection we are also request any and all FRB records concerning this and all other WSFS submissions in the last year, and any records reflecting regulatory disciplining by the Fed of banks or BHCs for withholding information in bad faith, for the past three years. Each portions of this request can be considered separately so as to ensure receipt as fast as possible of wrongfully withheld information so we can comment on it."

January 14, 2019

Amid Targeting of Community Reinvestment Act Centerstate Bank NCC Takeover and Withholding Challenged on Disparate Lending

By Matthew R. Lee, Video, story, FOIA docs

NEW YORK CITY, January 11 – The US Treasury Department is the next stage of a process to try to weaken and take the community out of the 1977 Community Reinvestment Act. Docket file here. On January 7, Fair Finance Watch and Inner City Press filed comments and a Freedom of Information Act request with the Federal Reserve on Centerstate Bank's application to acquire National Bank of Commerce, despite Centerstate's disparate lending record, see below. On January 11, having been sent documents showing that Centerstate is trying to withhold most of its exhibits, Inner City Press filed "This is a second timely comment on the over-withheld Applications of Centerstate Bank Corporation, Winter Haven, Florida to merge with National Commerce Corporation, and thereby indirectly acquire National Bank of Commerce. On January 7 Inner City Press / Fair Finance Watch submitted an initial comment and requested a copy of the full Application, under FOIA and through the Reserve Bank. So far, what has been sent to Inner City Press has no portion at all of the only substantive Exhibits, B, C and D. The only Exhibits provided are the merger agreements and the form of newspaper notice. This is an abuse, and the comment period must be extended so that comment on the wrongfully withheld exhibits can be made. It is impossible to believe that there are no segregable non exempt portions of those exhibits. Inner City Press already has a FOIA request pending and so is not confusing the matter by submitting another FOIA request. The FRB should not countenance such strategic secrecy by this applicant. This is a specific timely request that the comment period be extended and the information provided.

January 7, 2019

As Federal Reserve Chair Powell Says Would Not Resign If Asked Contrast to FOIA Denials and Merger Rubber Stamping

By Matthew R. Lee, Video, story, FOIA docs

NEW YORK CITY, January 4 – Today Federal Reserve Board Chairman Jerome Powell said he would not resign from his post if asked by President Donald Trump. He said this in response to a question at an American Economic Association event in Atlanta. It sounds transparent - but his Federal Reserve, at least on complying with the Freedom of Information Act (FOIA), is not transparent. And Powell was the Governor in charge of denying the Press' FOIA appeals, which he did time after time. The context: the US Treasury Department is the next stage of a process to try to weaken and take the community out of the 1977 Community Reinvestment Act. Docket file here. The protagonist, akin to Scott Pruitt when he was at the US Environmental Protection Agency or Ryan Zinke at Interior, is Comptroller of the Current Joseph Otting. On September 12 Fair Finance Watch (and on FOIA, Inner City Press) commented to the OCC, here. At the November 19 deadline, not yet posted was Inner City Press' November 17 fourth comment, just as Otting's OCC absurdly waited 13 days to try to rule it does not have to consider Fair Finance Watch's comments on WSFS Bank's application to acquire Beneficial. Now, after the OCC gleefully closed its comment period on that, WSFS on December 13 announced it will close 25 branches. One would think Otting would have to re-open the comment period. But that's not how Otting rolls. And the Fed, on FOIA, is absurd. On January 2 the Federal Reserve unilaterally extended its time to respond to Inner City Press' FOIA request about WSFS and CRA - without any commitment to no haul off and rubber stamp the application. Here's what the Fed wrote: "Mr. Matthew R. Lee Inner City Press P.O. Box 20047 Dag Hammarskjold Station New York, NY 10017 Re: Freedom of Information Act Request No. F-2019-00040 Dear Mr. Lee, On December 3, 2018, the Board of Governors (“Board”) received your electronic message dated December 1, pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, for all withheld portions of the applications by WSFS to acquire Beneficial, including but not limited to presumptively mis-labeled “Confidential” exhibits about WSFS's CRA program (“Confidential” Exhibit 9)... Pursuant to section (a)(6)(B)(i) of the FOIA, we are extending the period for our response until January 16, 2019, in order to consult with two or more components of the Board having a substantial interest in the determination of the request. If a determination can be made before January 16, 2019, we will respond to you promptly. It is our policy to process FOIA requests as quickly as possible while ensuring that we disclose the requested information to the fullest extent of the law. Thank you, Freedom of Information Office Board of Governors of the Federal Reserve System."

December 31, 2018

To Federal Reserve Cadence Bank Redacts 80% of Letter Urging Fast Approval and Withholds from Inner City Press

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

SOUTH BRONX, December 28 – Cadence Bancorporation which has a disparate lending record while apply to buy State Bank in Georgia and urging faster regulatory approvals, seemingly jumped the gun before having the required Federal Reserve Board approval. Now a new low: a letter that Cadence and its outside counsel, former Federal Reserve lawyer Patricia Robinson, were required to provide a copy to Inner City Press / Fair Finance Watch they on purpose only sent by mail (rather than e-mail), then delayed weeks in resending. Photo here. When it arrived, as intended after the Fed's rubber stamp approva, the letter was more than 80% redacted, arguing for a fast approval. This is a new low, and something we will be confronting and combating in 2019. We have begun with this new FOIA request: "This is a FOIA request for the all withheld and redacted portions of the submissions by Cadence to the FRS to acquire State Bank, including but not limited to the outrageously 80% redacted Nov 1, 2018 letter which Cadence' counsel, rather than emailing to us, sent by mail, one and then twice, the second on Dec 14 AFTER the Fed approved the merger. In this connection we are also request any and all FRB records concerning this and all other Cadence submissions in the last year, and any records reflecting regulatory disciplining by the Fed of banks or BHCs for withholding information in bad faith, for the past three years. Each portions of this request can be considered separately so as to ensure receipt as fast as possible of the unredacted, wrongfully delayed Nov 1, 2018 letter." The Fed in a December 7 order shrugged it all off...

December 24, 2018

An absurdity, or contempt by the Fed for the public and process: AFTER the Fed on Dec 7 approved Synovus' application, this:

Re: Freedom of Information Act Request No. F-2019-00031

Dear Mr. Lee,

On November 13, 2018, the Board of Governors (“Board”) received your electronic message dated November 10, pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, for all withheld portions of the applications and applications additional information submitted by Synovus to acquire FCB Financil including but not limited to presumptively mis-labeled “Confidential” exhibits as “Confidential” Exhibit 1 to Synovus' October 31 response, which appears to be personnel to be integrated into fair lending, while Synovus discloses its own staff's names, and for all records reflecting FRS communications with Synovus or FCB Financial or their affiliates for the past twelve (12) months.

Pursuant to section (a)(6)(B)(i) of the FOIA, we are extending the period for our response until December 27, 2018, in order to consult with two or more components of the Board having a substantial interest in the determination of the request.

If a determination can be made before December 27, 2018, we will respond to you promptly. It is our policy to process FOIA requests as quickly as possible while ensuring that we disclose the requested information to the fullest extent of the law.

Yeah, the law...

December 17, 2018

Targeting of Community Reinvestment Act by Otting Includes Excluding Comment on 25 Branch Closings by WSFS

By Matthew R. Lee, Video, story, FOIA docs

SOUTH BRONX, December 15 – The US Treasury Department is the next stage of a process to try to weaken and take the community out of the 1977 Community Reinvestment Act. Docket file here. The protagonist, akin to Scott Pruitt when he was at the US Environmental Protection Agency or Ryan Zinke at Interior, is Comptroller of the Current Joseph Otting. On September 12 Fair Finance Watch (and on FOIA, Inner City Press) commented to the OCC, here. At the November 19 deadline, not yet posted was Inner City Press' November 17 fourth comment, just as Otting's OCC absurdly waited 13 days to try to rule it does not have to consider Fair Finance Watch's comments on WSFS Bank's application to acquire Beneficial. Now, after the OCC gleefully closed its comment period on that, WSFS on December 13 announced it will close 25 branches. One would think Otting would have to re-open the comment period. But that's not how Otting rolls. Here's WSFS: "WSFS Financial Corporation (Nasdaq: WSFS) (“WSFS”) and Beneficial Bancorp, Inc. (Nasdaq: BNCL) (“Beneficial”), jointly announced a retail banking office optimization plan that aligns with the previously reported intent to merge Beneficial Bank into WSFS Bank. The plan includes the consolidation of 25% of the combined Beneficial and WSFS retail banking offices due to an overall decline in branch transactional activity, Customers’ rapid adoption and usage of digital services, geographic overlap and optimization opportunities. To continue delivering on its mission of “We Stand For Service” amidst evolving Customer expectations, WSFS also committed to reinvest an incremental $32 million of the estimated cost savings from the retail office optimization plan into a five-year transformational investment in technology and delivery systems to create a top-tier physical and digital servicing platform that will significantly enhance Customer experiences across all business lines.

Teams from both institutions conducted an extensive analysis of the combined franchise to study market overlap, transaction trends, space considerations, cost of ownership, business opportunities, the brand experience, visibility from high-traffic roadways, and the accessibility of each location. WSFS leveraged this due diligence to determine that it will consolidate 14 Beneficial and 11 WSFS retail banking offices of the combined network. WSFS also plans to sell five additional retail banking offices located on the outer edges of the combined core footprint. Most closures will occur at the conversion of Beneficial Bank into WSFS Bank, which is expected to occur in August 2019.

Eighty percent (80%) of the consolidating retail offices are less than three miles from remaining locations, including nearly a third that are less than a mile away. WSFS is offering jobs to all Beneficial and WSFS team members of the consolidating banking offices within the Retail Division of WSFS Bank. WSFS will also raise the minimum wage across the combined organization to WSFS’ current minimum of $15 an hour.

The planned combination and ongoing delivery transformation will make WSFS the largest, premier, longest-standing, locally-headquartered community bank for the Greater Delaware Valley with approximately $13 billion in assets and growing.

“We have worked quickly, but diligently, on our plan to combine our two institutions, which included identifying the retail space that will best help us deliver top-tier quality services and solutions for Customers across the Delaware Valley,” said Rodger Levenson, WSFS’ Executive Vice President and Chief Operating Officer, who will become President and Chief Executive Officer on January 1, 2019. “This retail banking office optimization initiative and our planned technology reinvestment, combined with a larger balance sheet and an intimate knowledge of the market, affirms our unique position to fill a long-standing gap between big banks and smaller community banks in the Philadelphia-Camden-Wilmington MSA.”

WSFS has posted on its website (wsfsbank.com/beneficial) the 25 retail banking offices that are slated to consolidate as part of the retail banking office optimization plan. WSFS will begin communicating these consolidations and other merger-related information to Beneficial and WSFS Customers in the first quarter of 2019 after the combination receives regulatory approval and the deal closes." The lists are by country, only for download. But Inner City Press has timely protested WSFS to the Federal Reserve - and has now found out that WSFS is even trying to withhold its CRA information from the public, photo here. So Inner City Press has submitted this Freedom of Information Act request: " This is a FOIA request for the all withheld portions of the applications by WSFS to acquire Beneficial, including but not limited to presumptively mis-labeled “Confidential” exhibits about WSFS's CRA program (“Confidential” Exhibit 9), (Beneficial's subsidiaries (“Confidential” Exhibit 3), Board of Directors resolutions, due diligence (“Confidential” Exhibit 10), operating economy / cost savings (there are branch closings projected), names of prospective managers (ages, requested on application, apparently not provided), and for all records reflecting FRS communications with WSFS or Beneficial or their affiliates for the past twelve (12) months."

December 3, 2018

The Federal Reserve, it seems, doesn't review banks' requests for confidential treatment. So "This is a FOIA request for the all withheld portions of the applications by WSFS to acquire Beneficial, including but not limited to presumptively mis-labeled “Confidential” exhibits about WSFS's CRA program (“Confidential” Exhibit 9), (Beneficial's subsidiaries (“Confidential” Exhibit 3), Board of Directors resolutions, due diligence (“Confidential” Exhibit 10), operating economy / cost savings (there are branch closings projected), names of prospective managers (ages, requested on application, apparently not provided)"

November 26, 2018

Cadence Bank Urges OCC To Speed Regulatory Approvals While Withholding Info on State Bank in Georgia

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

SOUTH BRONX, November 20 – Cadence Bancorporation which has a disparate lending record has applied to buy State Bank in Georgia, and has seemingly jumped the gun before having the required Federal Reserve Board approval. On October 18, Fair Finance Watch submitted a timely comment to the Federal Reserve Board in Washington, below - and got back a copy of a letter from the Federal Reserve Bank of Dallas forwarding its comment to Cadence's outside counsel at Wachtell Lipton -- Patricia Robinson, who used to be with the Fed's Legal Division. Inner City Press will have more on that. Now on November 20 the Fed has extended its time to respond to Inner City Press' FOIA request, the day after Cadence commented to Joseph Otting's OCC's Advance Notice of Proposed Rulemaking urging his OCC to "make the application process for expansionary actions less contentious." How about not making frivolous requests to have regulators withhold information until they hope the "expansionary action" is consummated? Here's from FFW's comment: "This is a request for a full copy of, and a timely first comment on, the Applications of Cadence Bancorporation, Houston, Texas; to acquire State Bank Financial Corporation, Atlanta, Georgia, and thereby indirectly acquire State Bank and Trust Company, Macon, Georgia

As an initial matter, this is a request that the FRS immediately send by email to Inner City Press all non-exempt portions of the applications / notices for which the Applicants have requested confidential treatment.

Fair Finance Watch has been tracking Cadence Bank: In 2017 in the Dallas, Texas MSA for convention home purchase loans, Cadence made 99 such loans to whites - and NONE, not a single origination, to African Americans.

In 2017 in the Houston Texas MSA for convention home purchase loans, Cadence made 236 such loans to whites - and only 15 to African Americans, and only 23 to Latinos. This is not in keeping with the aggregate, which made 37,128 such loans to whites, 3151 to African Americans and 8215 to Latinos.

In 2017 in the Birmingham, Alabama MSA for convention home purchase loans, Cadence made 66 such loans to whites - and only ONE to African Americans. Even combining in Table 4-1, it was 79 home purchase loans to whites and only THREE to African Americans.

This should also be address in this proceeding, including at the requested evidentiary hearing:

“Cadence Bank - Racist manager

2800 Post Oak Blvd Suite 101, Houston, TX 77056, USA

I had my 2 business accounts at the Williams tower location, I tried talking to the manager about small business loans she always avoided me looking at me kind of weird whenever I done withdrawals she always asked me why I'm taking money out after 3 months she sent me a Leter saying she's going to be closing my account because I take money out ones a week for payroll and she didn't like that.”

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

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

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

November 19, 2018

Step by step from the Fed on Synovus: "In connection with the application filed under Section 3 of the Bank Holding Company Act by Synovus Financial Corp., Columbus, Georgia, to merge with FCB Financial Holdings, Inc. and thereby indirectly acquire Florida Community Bank, N.A., both of Weston, Florida, and the application filed under section 18(c) of the Federal Deposit Insurance Act by Synovus Bank, Columbus, Georgia, to merge with Florida Community Bank, please respond to the additional question below.

Provide updated pro forma consolidated financial statements and capital ratios as of September 30, 2018.

In accordance with the Board’s procedures regarding ex parte communications, a copy of the attached request will be sent to the commenters in this case. Please provide a copy of the public portion of your response (together with any attachments) directly to the commenters. Any information for which you desire confidential treatment should be so labeled and separately bound in accordance with the Board’s rules regarding confidential treatment of information at 12 CFR 261.15. "
November 12, 2018

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

November 5, 2018

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

October 29, 2018

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

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

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

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

As an initial matter, this is a request that the FRS immediately send by email to Inner City Press all non-exempt portions of the applications / notices for which the Applicants have requested confidential treatment.

Fair Finance Watch has been tracking Cadence Bank: In 2017 in the Dallas, Texas MSA for convention home purchase loans, Cadence made 99 such loans to whites - and NONE, not a single origination, to African Americans.

In 2017 in the Houston Texas MSA for convention home purchase loans, Cadence made 236 such loans to whites - and only 15 to African Americans, and only 23 to Latinos. This is not in keeping with the aggregate, which made 37,128 such loans to whites, 3151 to African Americans and 8215 to Latinos.

In 2017 in the Birmingham, Alabama MSA for convention home purchase loans, Cadence made 66 such loans to whites - and only ONE to African Americans. Even combining in Table 4-1, it was 79 home purchase loans to whites and only THREE to African Americans.

This should also be address in this proceeding, including at the requested evidentiary hearing:

“Cadence Bank - Racist manager

2800 Post Oak Blvd Suite 101, Houston, TX 77056, USA

I had my 2 business accounts at the Williams tower location, I tried talking to the manager about small business loans she always avoided me looking at me kind of weird whenever I done withdrawals she always asked me why I'm taking money out after 3 months she sent me a Leter saying she's going to be closing my account because I take money out ones a week for payroll and she didn't like that.”

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

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

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

October 15, 2018

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

October 8, 2018

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

October 1, 2018

Now

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

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

September 24, 2018

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

September 17, 2018

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

September 10, 2018

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

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

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

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

September 3, 2018

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

August 27, 2018

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

August 20, 2018

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

August 13, 2018

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

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

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

August 6, 2018

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

July 30, 2018

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

July 23, 2018

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

July 16, 2018

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

July 9, 2018

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

July 2, 2018

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

June 25, 2018

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

June 18, 2018

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

By Matthew R. Lee, Patreon

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

June 11, 2018

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

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

By Matthew R. Lee, Audio

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

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

May 21, 2018

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