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

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March 17, 2025

Stock Fraudster Sterling Bancorp OKed To Sell Bank with Weak CRA to Everbank Shirking NY

by Matthew R. Lee, Patreon Substack

FEDERAL COURT, March 14 – Sterling Bancorp, which settled with DOJ on securities fraud, it trying to sell its Sterling Bank & Trust including in New York, where it has a need to improve CRA Investment Test rating to Everbank. Fair Finance Watch with Inner City Press on the FOIA has filed a timely first comment on, the Applications

This is a request for a full copy of, and a timely first comment on, the Applications of EverBank to acquire Sterling Bank & Trust (with a rare Needs to Improve CRA rating on Investment Test in New York), and not scandal plagued Sterling Bancorp. Sterling Bancorp was recently prosecuted by DOJ; EverBank purports that by buying the bank portion it is not touched by the scandal. But what is the showing that the criminal conduct at the Bancorp was entirely insulated from the bank and those who work there, and its practices? As a CRA matter, militating for a hearing, Sterling Bank has a rare Needs to Improve rating on the investment test in NY.

On December 24 Everbank wrote in to the Fed stating that "EverBank maintains the following two office locations in New York, neither of which is a “branch”... Islandia, NY: Located at 11 Oval Drive, Suite 107, Islandia, NY 11749.11 This location consists of an approximately 31,000 square-foot facility... EverBank notes that its lease for the Islandia, New York location is due to expire in 2025, after which EverBank expects to move the back-office operations currently conducted at that location to another non-branch office location on Long Island, New York." Needs to improve...

Nevertheless on Friday, March 14 the Fed hauled off and approved it, noting that FFW - "the commenter criticized the CRA record of Sterling Bank with respect to its “Needs to Improve” rating on the investment test (“Investment Test”) component of the bank’s statewide ratings in Michigan, New York, and Washington" - then saying "EverBank intends to renovate many of Sterling Bank’s existing branches." Yeah.

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March 10, 2025

In Florida Disparate United Community Banks Wants ANB Now Fed Qs Including on CRA

by Matthew R. Lee, Patreon Substack

FEDERAL COURT, March 6 – In Florida, United Community Bank is trying to move into the Miami 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 Application by UCB to acquire American National Bank.

But consider United Community Bank's disparate lending record:

In South Carolina in 2023, United Community Banks made 673 mortgage loans to whites with 282 denials. Meanwhile to African Americans in the state it made only FIFTY ONE loans, while denying fully 45 applications.

In Florida in 2023, United Community Banks made 240 mortgage loans to whites with 86 denials. Meanwhile to African Americans in the state it made only TWELVE loans, while denying five applications.

Nationwide, United Community Banks is scarcely better. In 2023 overall it made 5576 mortgage loans to whites with 4114 denials. Meanwhile to African Americans nationwide it made only 477 loans, while denying fully 1246 applications. That is to say, while UCB to whites had more loans then denial, to African Americans it had nearly three times as many denials as of loans.

To this, on February 11 UCB through outside counsel replied that while Fair Finance Watch "cites data for the Bank’s lending in South Carolina, Florida and 'nationwide,' the comment’s assertion that “nationwide” data is relevant is misplaced." What a surprise. They ignore their disparities.

In March the Fed asked questions, including on CRA (and a Confidential question), and "Discuss the purpose of each of the following provisions in the Merger Agreement and whether any provisions listed below would be considered to permit UCBI or United Community Bank to exercise prior control over the management or policies of Bank: i. ii. Article 5.1(u), which states that American Bank may not make or acquire or issue a commitment for (i) any commercial real estate Loan in an original principal amount in excess of $7,000,000, (ii) any residential Loan originated for retention in the Loan portfolio in an original principal amount in excess of $1,500,00 or (iii) any commercial or industrial Loan in an original principal amount in excess of $2,000,000."

Watch this site.

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March 3, 2025

Gov Philip Jefferson said in a speech last week, "Policymakers' approach to communication has evolved over time. In the past, policymakers were not focused on clarity and transparency in their communications as they are today. For example, former Fed Chair Alan Greenspan famously quipped in 1987, "If I seem unduly clear to you, you must have misunderstood what I said."" But how transparent is the Fed now? Long delays on FOIA, for example....

February 24, 2025

Federal Reserve Defended Terminating Master Accounts Now BSJI Cites Fed on Debanking

by Matthew Russell Lee, Patreon Book Substack

SDNY COURTHOUSE, Feb 17 – The Federal Reserve - both the Board of Governors in Washington and the FRBNY - have been sued by Banco San Juan International for the terminal of its master account(s).

On the motion to dismiss, oral arguments were held on December 12 before U.S. District Court for the Southern District of New York Judge John G. Koeltl. Inner City Press was there. Thread:

Fed's lawyers from Simpson Thacher law firm cite Custodia (crypto) case. Does this outside counsel rep raise conflicts of interest on mergers?

Note: Simpson Thacher represents many banks applying to the Fed for merger approvals - why did the Fed, which has many in house lawyers, have to hire them? And isn't there now a conflict of interest on the merger applications? Fed: The Reserve Banks are not govt

Plaintiff: The Fed never closed the master accounts of Deutsche Bank, despite wrongdoing - and what about "Toronto Dominion, which pled guilty to money laundering"?

[Note: TD's Leonardo Ayala is being prosecuted in the District of NJ]

On January 8, 2025 Judge Koeltl dismissed the amended complaint, setting a time to further amend: "the defendants' motions to dismiss are granted. All of BSJI's claims are dismissed without prejudice as discussed above. At oral argument, counsel for BSJI indicated that BSJI may wish to file a second amended complaint. Tr. 16. The time to file a motion to amend, attaching a copy of the second amended complaint and explaining how the second amended complaint solves the deficiencies noted in this opinion, is January 27, 2025. The defendants may respond by February 10, 2025. The plaintiff may reply by February 17, 2025. If the plaintiff does not file any such motion by January 27, 2025, the Court will issue an order directing that judgment be entered dismissing the Amended Complaint."

On February 17 BSJI through counsel Abbe Lowell wrote in citing Fed Chair Jerome Powell's recent testimony that he is (belatedly) troubled by de-banking by the Reserve Banks. Full letter on Patreon here

Inner City Press will stay on these cases.

This case is Banco San Juan Internacional, Inc. v. The Federal Reserve Bank of New York, et al., 1:23-cv-06414 (Koeltl)

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February 17, 2025

As CFPB Home Page Goes 404 HMDA Petition to Federal Reserve by Fair Finance Watch

by Matthew Russell Lee, Patreon Book Substack

Bronx / Federal Court, Feb 11 – When a "404: Page Not Found" message began on the homepage of the U.S. Consumer Financial Protection Bureau, a call went out among consumer advocates to dig deeper in the site and begin downloading data before it is deleted. Fine.

But the CFPB has become the platform on which new data under the Home Mortgage Disclosure Act is released. Simply downloading past years' data is not enough. Where will the 2024 data go, and be available to the public? Fair Finance Watch, with Inner City Press on the FOIA, filed a petition for rulemaking and emergency mitigation with the Federal Reserve Board:

Governor Powell, Ladies and Gentlemen:

Fair Finance Watch and Inner City Press are writing to petition the Board of Governors of the Federal Reserve System under section 553(e) of the Administrative Procedure Act to engage in rulemaking and, most immediately, to take emergency measures to ensure public access to data under the Home Mortgage Disclosure Act (HMDA), including the 2024 data.

When the Consumer Financial Protection Bureau was created, the hosting of HMDA data shifted from the FFIEC to CFPB website. Today February 10, 2025 the CFPB.gov website went dark. While portions of the site are as of this writing still available, it is foreseeable that the HMDA data site may be taken down. The Community Reinvestment Act, among other banking laws, is largely enforced by use and analysis of HMDA data. It is imperative that public access to HMDA data remain.

The FRB should begin a process to ensure access to HMDA data, on FFIEC or the FRB's own website - by rulemaking, if necessary long term, but immediate on an interim basis, if necessary mirroring the CFPB cite as long as it remains under threat.

This petition concerning the continued public access to HMDA data is also made with reference to Section 553(e) of the APA, and we respectfully request a response.

Watch this site. Others like NCRC are advocating. We aim to have more from DC

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February 10, 2025

Now the Fed has announced the termination of two enforcement actions with Wells Fargo - the one with the predatory lender Wells Fargo Financial...

February 3, 2025

Crime: John Harold Rogers, 63, a former Senior Adviser for the Federal Reserve Board of Governors was arrested on charges that he conspired to steal Federal Reserve trade secrets for the People’s Republic of China

Revolving door: Coinbase has added to its Global Advisory Council former New York Fed President Bill Dudley...

January 25, 2025

It was the Federal Reserve Bank of Atlanta that on January 23 asked "Provide a complete list of the non-branch offices of EverBank, National Association and Sterling Bank. " Watch this site.

January 20, 2025

On Capital One Discover OCC Doubled Down on FOIA Withholding Now Customers Cut Off

by Matthew R. Lee

SOUTH BRONX, Jan 17 – Capital One has applied to buy Discover, in an anticompetitive deal that should be rejected by regulators if they mean what they have been saying. After they applied late March 20, Inner City Press submitted a second Freedom of Information Act request to the Office of the Comptroller of the Currency (and to the Federal Reserve).

On May 14 - still without providing FOIA documents - the OCC and Fed set a July 19 virtual public meeting.

On the eve of it, Capital One announced a vague and less than credible plan - they previously violated their ING Direct pledge - including this time $75 billion in largely subprime auto loans. Fair Finance Watch testified for three minutes.

On June 25 the OCC belatedly responded to Inner City Press' FOIA request - by withholding in full 185 pages. OCC FOIA production on DocumentCloud here. Inner City Press appealed.

On July 24, the very day on which the OCC and Fed said they were closing the written comment period, the OCC upheld in full its FOIA denials, determination letter on Inner City Press' Document Cloud here. Inner City Press has requested an extension of the comment periods - the Fed hasn't even responded.

Nor does it seem the Fed has taken note of Capital One cutting off its own customers on January 16, then passing the buck to a third party vendor, Fidelity Information Services. Something is deeply wrong with Capital One, but the Fed and OCC don't seem to care.

Meanwhile Capitol One lobbying continues even now in 2024, from New Mexico even to Harlem by a social worker with bankers on the board. How is this Astroturfing organized?

Without approvals, now the banks have set shareholders' votes for February 18, 2025.

As documented by Fair Finance Watch, Discover Bank in 2022 denied mortgage loans application from African Americans more than twice as frequently as those of whites. It grew worse in the just-out 2023 data.

Previously, Inner City Press and NCRC challenged Capital One's acquisition of ING Direct, see here.This time, given the antitrust enforcement claims being made in DC, this proposal should be denied. But will it be? Watch this site.

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January 13, 2025

UMB Bank Heartland Merger Hit on Disparties and Uninsured Deposits Now Rubber Stamped

by Matthew R. Lee, Patreon Substack

SOUTH BRONX / SDNY, Jan 10 – 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.

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January 6, 2025

If the Federal Reserve Banks are not the government, how can they give out approval like this?

"New York NBT Bancorp Inc., Norwich, New York—waiver of application to acquire Evans Bancorp, Inc., Williamsville, New York, and thereby acquire Evans Bank, National Association (Evans Bank), Angola, New York, in connection with the merger of Evans Bank with and into NBT Bank, National Association, Norwich, New York.* Granted: December 18, 2024."

December 30, 2024

The Fed is supposed to sent copies of its question letters to banking to the community groups which have commented on, particularly against, the proposed merger. But on Capital One - Discover, the Fed just stopped. Capital One disclosed the letter, but not the contents, in SEC filings. A new low.

December 23, 2024

Fraudster Sterling Bancorp Bid To Sell Bank with Weak CRA to Everbank Questioned on NY

by Matthew R. Lee, Patreon Substack

FEDERAL COURT, Dec 20 – Sterling Bancorp, which settled with DOJ on securities fraud, it trying to sell its Sterling Bank & Trust including in New York, where it has a need to improve CRA Investment Test rating to Everbank. Fair Finance Watch with Inner City Press on the FOIA has filed a timely first comment on, the Applications

On December 4 Everbank's outside counsel wrote in that FFW "selectively criticizes a single component of Sterling Bank’s most recent CRA performance evaluation from states in which Sterling Bank either no longer operates, will no longer operate upon completion of the Proposed Transaction, or maintains only a de minimis banking presence" -- that would be New York, no commitment to improve on the Needs to Improve. As to Michigan the outside counsel says, or brags, "EverBank intends to close Sterling Bank’s only Michigan branch following completion of the Proposed Transaction."

On December 19, the Federal Reserve asked Everbank questions including "Explain whether EverBank’s office in New York is a “branch” within the meaning of 12 U.S.C. 1841(o)(3) and indicate whether loan proceeds are disbursed at that New York office.

3. The FR Y-3 notes: “following the Proposed Transaction, the combined organization intends to leverage the CRA and consumer protection compliance strengths of both banks to create a strong and comprehensive combined compliance program.” The FR Y-3 subsequently states that “EverBank does not anticipate any structural changes to its CRA program, CRA leadership, organizational structure, or oversight as a result of the Proposed Transaction.” Clarify whether the combined organization intends to continue to utilize EverBank’s existing CRA and consumer compliance programs following consummation. If the combined organization intends to incorporate specific aspects of Sterling Bank’s CRA and consumer those programs the combined organization intends to leverage from Sterling Bank’s existing operations.

4. The FR Y-3 notes that Sterling Bank would use commercially reasonable efforts to close its Southfield, Michigan branch... Indicate whether a branch closure notice has been submitted under section 42 of the FDI Act."

The proposal should be denied.

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December 16, 2024

SouthState Lending Disparities Triggered CRA Protest But Fed OKs Admitting Weak Carolinas

by Matthew R. Lee, Patreon Substack

SOUTH BRONX / SDNY, Dec 13 – 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."

But there is more being withheld. SouthState filed on September 30: "Please see Confidential Exhibit 1 to the Confidential Appendix for additional information on branch actions SouthState may plan to take that are unrelated to the proposed transaction."

On December 13 the Fed rubber stamped the deal, even as it admitted it is order poor performance in South Carolina and poor geographic distribution of SouthState's loans in North Carolina. This is today's Fed.

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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.

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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.

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.

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 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 November 29, the Fed responded with the branch closing list and more - now on Inner City Press' DocumentCloud here.

Watch this site.

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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:

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.

The merger should be denied. Watch this site.

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.

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 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.

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:

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.

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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:

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.

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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.

Why would regulators even consider approving its expansion?

On August 9, SouthState submitted to the Fed a response - that deals only with Independent Bank.

Inner City Press has submitted a FOIA request with the Fed for that obviously CRA-material Exhibits.

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

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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

The Fed has asked SouthState, "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)." That's it?

August 12, 2024

Back on June 26 on a smaller merger, Inner City Press requested records - and was granted expedited treatment, explicitly with reference to the July 25 expiration of the public comment period. But no records were given - and on July 26, this: "Pursuant to section (a)(6)(B)(i) of the FOIA, we are extending the period for our response until August 9, 2024, in order to consult with two or more components of the Board having a substantial interest in the determination of the request." And no response to the timely request to exetnd the comment period...

But even on August 9 by 10 pm, no documents, nothing. Meanwhile the underlying bank urges delegated rubber stamp. This is today's Fed.

August 5, 2024

On July 26, after a FOIA appeal - and after closing the public comment period - the OCC belatedly gave Inner City Press documents showing Capital One briefed the OCC on a "big" deal in November 2023; it was code named "Project Sirius."

Then overly chummy texts from Andy Navarrete, who testified at the public meeting, and Pient Tran to the OCC's Marci Heppner and others.

For example, Andy to Marci, sorry for the late ping, if Richard wanted to call, could you do a 1:1 Zoom at 7:30 [pm]. But of course. That and more now on Inner City Press' DocumentCloud here

July 29, 2024

The Fed's FOIA scam is no limited to Capital One / Discovery. On June 26 on a smaller merger, Inner City Press requested records - and was granted expedited treatment, explicitly with reference to the July 25 expiration of the public comment period. But no records were given - and on July 26, this: "Pursuant to section (a)(6)(B)(i) of the FOIA, we are extending the period for our response until August 9, 2024, in order to consult with two or more components of the Board having a substantial interest in the determination of the request." And no response to the timely request to exetnd the comment period...

July 22, 2024

From Testimony Opposing Capital One's Bid to Acquire Discover July 18, 2024

The day the banks announced the proposed merger, Inner City Press submitted Freedom of Information Act requests to both the Federal Reserve and the Office of the Comptroller of the Currency. The Fed, as has become a pattern, granted Inner City Press' FOIA request expedited treatment - and then did not provide any of the responsive documents, claiming it needed more time.

July 15, 2024

On Capital One Discover 3 Minutes Each OCC Withholds 185 Pages Inner City Press Appeals - Still Nothing from the Fed

by Matthew R. Lee

SOUTH BRONX, July 9 – Capital One has applied to buy Discover, in an anticompetitive deal that should be rejected by regulators if they mean what they have been saying. After they applied late March 20, Inner City Press submitted a second Freedom of Information Act request to the Office of the Comptroller of the Currency (and to the Federal Reserve).

On May 14 - still without providing FOIA documents - the OCC and Fed set a July 19 virtual public meeting.

On June 25 the OCC belatedly responded to Inner City Press' FOIA request - by withholding in full 185 pages. OCC FOIA production on DocumentCloud here. Inner City Press appealed.

At the July 19 public meeting, "each speaker will be allotted three minutes to speak at the meeting," the OCC and Fed on July 9 said.

Meanwhile Capitol One lobbying continues, for example with a Pennsylvania state legislator extolling Capital One's subprime, here.

July 8, 2024

Now belatedly the Federal Reserve has fined Silvergate $43 million - previously,

Inner City Press submitted to the Federal Reserve a Freedom of Information Act request including: "This is a FOIA request for all record regarding the FRS' approval for the application / request for membership in the Federal Reserve System by Farmington State Bank (giving rise to FRBSF president Daly's approval on a delegated basis in 2021), and the subsequent renaming of the bank to Mooonstone and taking of a stake by FTX/Alameda. Also, for Silvergate with its FTX connections, record reflecting any review by the FRS of Silvergate's (and Provident Bancorp Inc., Metropolitan Commercial Bank, Signature Bank, Customers Bancorp Inc.) of the banks' connections with crypto-currency firms... This is a request for expedited treatment, in light of the indictment of FTX / Alameda's Sam Bankman-Fried and Caroline Ellison (cooperating), and an upcoming January 3, 2023 hearing."

The Federal Reserve has so far acknowledged receipt: "Your request has been assigned number FOIA-2023-00178. Please reference this number in all future correspondence. Request description: This is a FOIA request for all record regarding the FRS' approval for the application / request for membership in the Federal Reserve System by Farmington State Bank [also] any review by the FRS of Silvergate's (and Provident Bancorp Inc., Metropolitan Commercial Bank, Signature Bank, Customers Bancorp Inc.) of the banks' connections with crypto-currency firms."

There is also a lawsuit in Federal court in California asserting that

"Silvergate, a publicly traded and federally regulated bank catering to cryptocurrency customers, maintained both FTX and Alameda accounts. It directly aided and abetted FTX’s fraud and breaches of fiduciary duty via first-hand participation in the commingling of funds, improper transfers, and lending out of customer money. Silvergate processed billions in transfers from FTX’s client account at Silvergate to the Alameda accounts. Silvergate also accepted deposits from FTX investors—intended to be stored, traded, or cashed out—that at Bankman-Fried’s direction were wired straight to Alameda bank accounts and misused."

July 1, 2024

Governor Bowman on June 27, thou dost protest too much: The processing timelines we see also seem inconsistent with a process that is operating truly as a rubber stamp. To be clear, I think we have room to do better when it comes to timely regulatory action, while maintaining a rigorous review of applications. But extended review periods are not uncommon, particularly when you include preliminary discussions and pre-filings with regulators in the published processing timelines.

June 24, 2024

Bowman in Salzburg: "Regulators must also understand, to the extent possible, the consequences of specific innovations. Take, for example, the increasing interest in tokenization. There is a risk that tokenized products and platforms could duplicate existing bank deposits and payment rails, potentially creating parallel systems. How would these parallel systems interact with, or even replace, current systems? Will the products and platforms that duplicate these deposit and payment functions provide the same legal protections for customers and the overall financial system that they currently receive?" Crypto....

June 17, 2024

While we *still* wait for documents under FOIA request purported to approve for expedited treatment, this: "Dear Matthew, We appreciate your interest in watching and testifying at the public meeting regarding the proposal by Capital One Financial Corporation, McLean, Virginia, to acquire Discover Financial Services, Riverwoods, Illinois, pursuant to the Bank Holding Company Act; and to merge Discover Bank, Greenwood, Delaware, into Capital One, National Association, McLean, Virginia, pursuant to the Bank Merger Act. The public meeting will start at 9:00 a.m. ET on Friday, July 19, 2024, and will be hosted virtually on an online meeting platform. The Federal Reserve Board and the Office of the Comptroller of the Currency have received your request to testify and are reviewing your request." Reviewing?

June 10, 2024

This month Inner City Press has received two letters from the FRB-Dallas, one responding to CRA protest filed in March, and only now transferred from FRB-KC to Dallas (but not the Board?) and the other to the Board. Why the delay?

June 3, 2024

Conflict of interest? Revolving door? "Numisma Bank in Greenwich, Conn., has received conditional approval for a Federal Reserve master account. Numisma, which focuses on banknote distribution, is a tier 3 institution that is state-chartered but isn’t backed by the Federal Deposit Insurance Corp. The Fed has rejected applications by other financial institutions, including Custodia Bank and The Narrow Bank, on the grounds that granting access would present an “undue risk.” NOTE: Numisma was co-founded by former Fed Vice Chair for Supervision Randal Quarles...

May 27, 2024

Fed sez: SVB lost $40 billion in deposits in a single day, with management expecting $100 billion more in outflows the next day. Together, these outflows represented about 85 percent of the bank's deposits. In contrast, both the failure of Wachovia and Washington Mutual in 2008 involved less severe outflows that evolved over more than a week (the failure of Wachovia in 2008 included about $10 billion in outflows over 8 days while the failure of Washington Mutual in 2008 included outflows of $19 billion over 16 days). Return to text 4. Signature Bank received in one day more than 1,600 withdrawal requests totaling approximately $18.6 billion, representing 20 percent of its deposits. Return to text 5. First Republic lost around 20 percent of its deposits in a single day

May 20, 2024

Capital One Should Discover Merger Dead July 19 Public Meeting Inner City Press FOIAed Fed

by Matthew R. Lee

SOUTH BRONX, May 14 – Capital One has applied to buy Discover, in an anticompetitive deal that should be rejected by regulators if they mean what they have been saying. While they applied late March 20, as of 1 pm on March 22 there was no notice of the Federal Reserve's or OCC's websites. Inner City Press submitted second FOIA requests to each agency. Public hearings should be held, not only on antitrust but also lending disparities at both companies.

On April 24 the Fed extended its comment period to May 31 - without (yet?) granting public hearings, nor providing the FOIA documents.

On May 14 - still without providing FOIA documents - the Fed and OCC set a July 19 virtual public meeting: "The public meeting will be held virtually on July 19, 2024, at 9:00 a.m. EDT. Members of the public seeking to present oral comments must register by 12:00 p.m. EDT on June 28, 2024, through the online registration webpage, which will be posted on the Board's Capital One-Discover Application Reading Room by May 28, 2024."

On April 19 the Fed wrote to extended its time to respond to Inner City Press' February 19 FOIA to May 3

The OCC first put its application in its reading room. And it is an outrage, Capital One gaming the CRA system. For example "the Proposed Transaction would result in CONA establishing a new assessment area in Delaware, which will include all census tracts in Sussex County and seven contiguous census tracts in Kent County."

That for a nationwide card and subprime auto lender...

As documented by Fair Finance Watch, Discover Bank in 2022 denied mortgage loans application from African Americans more than twice as frequently as those of whites.

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May 13, 2024

Fed Disappeared CRA Linkbancorp Condition on Approval Now NJ Branches out of CRA

By Matthew Russell Lee, Patreon Maxwell Book

SOUTH BRONX, May 10 – The Federal Reserve Board in considering the proposed merger on the rebound between New York-based Link Bank and Partners Bancorp omitted at the eleventh hour - or apparently the thirteenth hour - language about a Community Reinvestment Act condition imposed by the FDIC.

Now the Fed and its Governors have been asked Why - and when.

Inner City Press and Fair Finance Watch have long exposed redlining - and in this vein, on May 6 they filed a Community Reinvestment Act challenge with the FDIC and Federal Reserve.

In October, the FDIC required from LINKBANK a plan to improve its lending to African Americans, which Inner City Press has published on its DocumentCloud here.

But Link kept spinning, issuing a press release about these partial approvals without mentioning the condition, and concluding it "remains subject to the approval of the Board of Governors of the Federal Reserve System and other customary closing conditions. LINK anticipates closing the Merger in the fourth quarter of 2023." We asked, How do they know?

Well, they know that the Fed has boiler plate ready, ready to say it is concerned with HMDA disparities without acting on them, ready to say they conferred with the FDIC without acknowledging the condition the FDIC required.

The "Corrected" Fed approval emailed to Inner City Press on November 16 did not acknowledge the CRA condition. But the approval order first posted - and voted on?- did. We on November 16 filed:

Dear Chair Powell, Secretary Misback and others in the FRS: This is a formal request for reconsideration under 12 CFR Part 262.3(k) of the Board's "corrected" -- dropping the reference to FDIC's CRA Condition - Approval of the above-captioned applications by LINKBANCORP, Inc..

The Board's website currently says, of this order, that "Note: The initial version of this order was incorrect and inadvertently posted. A corrected version was posted on November 15, 2023."

Meanwhile, Deputy Associate Secretary Fennell's letter to me dated November 16 states that "today the Board of Governors of the Federal Reserve System has approved the proposal." If the approval was "today" / November 16, how was it corrected on November 15? The copy emailed to us on November 16 is entitled "Corrected."

It's worse, much worse. The original (real? approved?) version of the order stated "The FDIC’s approval of the merger of Bank with the Bank of Delmarva and Virginia Partners Bank includes a condition requiring the resultant institution to develop an action plan, including a marketing plan and additional outreach, to be submitted to the FDIC for approval, for monitoring and improving the extent of home mortgage applications from, and originations to, African American applicants in the resultant institution’s assessment areas. This condition will help ensure that the resultant institution continues to help in meeting the credit needs of the African American population in the resultant institution’s assessment areas."

It is true that the FDIC imposed a CRA condition, after receiving comments from Fair Finance Watch / Inner City Press. The FDIC sent the order with condition to us and we posted it online.

So why - and when - did the Federal Reserve, which claims to have conferred with the FDIC as primary supervisor, abruptly take out of its already-posted approval order the language about the CRA condition? Was it after the Board's approval? Who decided that the CRA condition language should be removed? Why? To make it unenforceable?

The "corrected" approval order, with the CRA language removed, is said to be: "Voting for this action: Chair Powell, Vice Chair Jefferson, Vice Chair for Supervision Barr, Governors Bowman, Waller, Cook, and Kugler." When did each vote? Were they made aware of, and is each Governor responsible for, the removal of the CRA condition language?

These are clearly facts that we could not present during the official comment period, or even prior to approval (or at least, "correction"). And they militate for reconsideration, for airing to each Governor and an explanation, given the Governors' claims and statements about their commitment to CRA.

On November 21 past 5 pm, a Federal Reserve staff attorney left Inner City Press a voicemail reading a script that the Fed General Counsel - without showing even this to the Board members - determined there was nothing new in the request. But Inner City Press didn't know about the removal of the condition language until after the Fed said it approved it - it could NOT have been shown before. UNreal. And the new(ish) Governnors? What do they think or do?

We still don't know. But now LINKBANCORP is selling branches that it acquired to a credit union, American Heritage Credit Union, and thereby taking more than $100 million of deposits out from the Community Reinvestment Act. We'll stay on this

May 6, 2024

Bowman watch, May 3 she said "the inflow of new immigrants to some geographic areas could result in upward pressure on rents, as additional housing supply may take time to materialize."

April 29, 2024

Capital One Should Discover Merger Dead FRB Extends to May 31 Inner City Press FOIAed Fed

by Matthew R. Lee

SOUTH BRONX, April 24 – Capital One has applied to buy Discover, in an anticompetitive deal that should be rejected by regulators if they mean what they have been saying. While they applied late March 20, as of 1 pm on March 22 there was no notice of the Federal Reserve's or OCC's websites. Inner City Press submitted second FOIA requests to each agency. Public hearings should be held, not only on antitrust but also lending disparities at both companies.

On April 24 the Fed extended its comment period to May 31 - without (yet?) granting public hearings, nor providing the FOIA documents.

On April 19 the Fed wrote to extended its time to respond to Inner City Press' February 19 FOIA to May 3

April 22, 2024

Capital One Should Discover Merger Dead Inner City Press FOIAed Fed Now Delay to May 3

by Matthew R. Lee

SOUTH BRONX, April 19 – ...On April 19, with the Fed's comment period coming to a close, the Fed wrote to extended its time to respond to Inner City Press' February 19 FOIA to May 3 - AFTER the close of the comment period.

As documented by Fair Finance Watch, Discover Bank in 2022 denied mortgage loans application from African Americans more than twice as frequently as those of whites.

April 15, 2024

Fair lending be damned? On April 11, 2024, the Fed hauled off and approved, noting Inner City Press / Fair Finance Watch "objected to the proposal, alleging that in 2021, Provident Bank and Lakeland Bank made no home loans to African American individuals in New York State.30 30 The data cited by the commenter corresponds to publicly available 2021 data by Provident Bank and Lakeland Bank under HMDA. Following consummation of the proposed transaction, the combined organization will add to its assessment area Bronx and Kings counties, each of which includes a significant number of majority-minority and LMI communities... The Board also has considered the DOJ Consent Order, including Lakeland Bank’s efforts towards meeting its obligations under the DOJ Consent Order, and that the DOJ Consent Order binds Provident without further action by the Board." We'll see.

April 8, 2024

Capital One Should Discover Merger Dead As Inner City Press FOIAs Fed Barr Talks Basel 3

by Matthew R. Lee

SOUTH BRONX, April 3 – Capital One has applied to buy Discover, in an anticompetitive deal that should be rejected by regulators if they mean what they have been saying. While they applied late March 20, as of 1 pm on March 22 there was no notice of the Federal Reserve's or OCC's websites. Inner City Press submitted second FOIA requests to each agency. Public hearings should be held, not only on antitrust but also lending disparities at both companies.

While the OCC has yet to provide some records requested under FOIA, it put its application in its reading room. And it is an outrage, Capital One gaming the CRA system. For example "the Proposed Transaction would result in CONA establishing a new assessment area in Delaware, which will include all census tracts in Sussex County and seven contiguous census tracts in Kent County."

That for a nationwide card and subprime auto lender...

Still no records from the Fed, so this:

This is a FOIA request for the entirety of Capital One's applications for regulatory approval of its Discover proposal, including all portions for which Capital One has requested confidential treatment, and all communications by your agency with the banks since February 19. As of March 22 at 1 am, the Fed's most recent H2A is from March 15

As documented by Fair Finance Watch, Discover Bank in 2022 denied mortgage loans application from African Americans more than twice as frequently as those of whites.

On April 3 speaking at NCRC's Just Economy conference Barr said the Fed will not follow the OCC and FDIC with merger processing reform proposals; then he walked Basel III endgame but not explanation why the Fed can't or won't give Capital One documents requested on Feb 19, as to which they purported to grant expedited processing. Watch this site.

April 1, 2024

On the Capital One / Discover merger application, the Fed has granted Inner City Press expedited FOIA processing - but as of March 29 had not provided a single document....

March 25, 2024

Backsliding? The Fed and the other agencies "extended the applicability date of the facility-based assessment areas and public file provisions from April 1, 2024, to January 1, 2026. Therefore, banks will not have to make changes to their assessment areas or their public files as a result of the 2023 CRA final rule until January 1, 2026." Meanwhile the Fed had not provided a single record, as of March 23, in response to Inner City Press' February 19 FOIA request about Capital One / Discover...

March 18, 2024

"The Federal Reserve Board on Thursday issued an enforcement action against JPMorgan Chase & Co. and fined the firm approximately $98.2 million for an inadequate program to monitor firm and client trading activities for market misconduct. The Board's action requires JPMorgan Chase to review and take corrective action to address the firm's inadequate monitoring practices, which occurred between 2014 and 2023" - but how many of JPM Chase's acquisition has the Fed rubber stamped during the time period?

March 11, 2024

Governon Bowman in New Jersey on March 7 bemoaned that "policy reforms may make bank M&A transactions more difficult for regulators to approve and slow the application processing timeline."

March 4, 2024

The Federal Reserve is getting worse and worse on FOIA, including on banks sued by DOJ for discrimination. They wrote to Inner City Press, you requested "the two exhibits withheld in full by Provident Financial Services, Inc., Jersey City, New Jersey in its January 18, 2024 Additional Information response in connection its pending application to acquire Lakeland Bancorp, Inc., Oak Ridge, New Jersey, and thereby indirectly acquire Lakeland Bank …. Staff searched Board records and located the documents that are responsive to your request. I have determined, however, that the withheld portions of the January 18, 2024, Additional Information submission that are responsive to your request contain confidential commercial and financial information (e.g., nonpublic business plans and strategies concerning compliance and lending). This information is subject to withholding and will be withheld from you pursuant to Exemption 4 of the FOIA, 5 U.S.C. § 552(b)(4). I have also determined that the information should be withheld because it is reasonably foreseeable that disclosure would harm an interest protected by an exemption described in subsection (b) of the FOIA, 5 U.S.C. § 552(b). The responsive documents have been reviewed under the requirements of subsection (b), but no reasonably segregable nonexempt information was found. Accordingly, approximately 18 pages of information will be withheld from you in full." In full...

February 26, 2024

The Fed just keeps extending its time on FOIA, and not only on Capital One / Discover: On February 20: "This is in response to your electronic message dated January 19, 2024, and received by the Board’s Information Disclosure Section on January 22. Pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, you request: the two exhibits withheld in full by Provident Financial Services, Inc., Jersey City, New Jersey in its January 18, 2024 Additional Information response in connection its pending application to acquire Lakeland Bancorp, Inc., Oak Ridge, New Jersey, and thereby indirectly acquire Lakeland Bank, which recently settled lending discrimination charges with DOJ[.] Pursuant to section (a)(6)(B)(i) of the FOIA, we are extending the period for our response until March 5, 2024, 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 March 5, 2024, we will respond to you promptly." Yeah.

February 19, 2024

Here's a question: What may have been the role of a Federal Reserve Governor in the lawsuit against the CRA regulation?

February 12, 2024

Before FNB Settled on Fair Lending Its Yadkin Merger Was Challenged But Fed Approved It

by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX, NY Feb 5 – When First National Bank of Pennsylvania applied to the Federal Reserve to buy Yadkin bank in North Carolina, Fair Finance Watch challenged it on Community Reinvestment Act and fair lending grounds.

The Federal Reserve, as usually, rubber stamped the merger. Now in February 2024 the Justice Department had sued and settled with FNB on fair lending grounds.

Inner City Press had wanted to ask DOJ about the Fed (including in its recent Patriot Bank action), but has been unable so far. Watch this site

February 5, 2024

On January 19 Inner City Press submitted a FOIA request; on January 31 the Federal Reserve wrote back: Pursuant to the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, you request: the two exhibits withheld in full by Provident Financial Services, Inc., Jersey City, New Jersey in its January 18, 2024 Additional Information response in connection its pending application to acquire Lakeland Bancorp, Inc., Oak Ridge, New Jersey, and thereby indirectly acquire Lakeland Bank, which recently settled lending discrimination charges with DOJ[.] You also seek expedited processing for your request. In support of your request for expedited treatment, you state that “[t]his information was submitted, unilaterally withheld in full, late in the application process – there is a need to release it for public knowledge BEFORE the Board acts on the application.” I have determined to grant your request for expedited processing. Accordingly, your request will be processed as soon as practicable and ahead of other FOIA requests." But still no documents...

January 29, 2024

What is happening to the Federal Reserve? Beyond misrating Patriot Bank just before its DOJ redlining settlement, how the Fed is withholding info about its inquiry into Lakeland Bank's discrimination deal. Ten days ago - with no documents yet - Inner City Press / Fair Finance Watch FOIA-ed the Fed: "This is a formal FOIA request for the two exhibits withheld in full by Provident Financial Services, Inc., Jersey City, New Jersey in its January 18, 2024 Additional Information response in connection its pending application to acquire Lakeland Bancorp, Inc., Oak Ridge, New Jersey, and thereby indirectly acquire Lakeland Bank, which recently settled lending discrimination charges with DOJ The January 18 response recites then states: Provide an update to all action items included in the Consent Order, reflecting those items which have been completed and any other pertinent updates, including, but not limited to, the status of any deliverables required under the Consent Order that have not yet been completed. Please refer to the attached Confidential Exhibit 1 for a response to this Item. The entire response is withheld, about fair lending compliance, including public commitments that are unfulfilled. This cannot stand; the information must be provided before the Board acts in any way on the application (other than denial.)

January 22, 2024

Lakeland Bank DOJ Deal Left Disparities So Protest & Fed Asks of DOJ Settlement Withheld

by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX, NY, Jan 19 – When the US Department of Justice sued and immediately settled with Lakeland Bank for fair lending violations, it announced a proposed merger with Provident Bank.

As if to sweep it under the carpet.

And when Fair Finance Watch looked into it, it found that the DOJ settlement did not address in any way the banks' disparities in New York. So on December 1, the FDIC's comment deadline, it filed a protest, with Inner City Press on the FOIA.

Jump cut to March 15, 2023, when Provident's Deputy General Counsel filed a letter with the New York Fed, cc-ing Rodgin Cohen - only on New Jersey, nothing on the disparities in New York.

On January 18 Provident asked two Board questions - by withholding the entire answers. Inner City Press immediately FOIAed: " The January 18 response recites then states: Provide an update to all action items included in the Consent Order, reflecting those items which have been completed and any other pertinent updates, including, but not limited to, the status of any deliverables required under the Consent Order that have not yet been completed. Please refer to the attached Confidential Exhibit 1 for a response to this Item. The entire response is withheld, about fair lending compliance, including public commitments that are unfulfilled. This cannot stand; the information must be provided before the Board acts in any way on the application (other than denial.) Inner City Press / Fair Finance Watch is a timely protestant to the application; this is also again request that the FRB begin putting all applications online, since the Fed has a new electronic system for applicants. What is the rationale for not doing this, and allowing for delay for the public and community organizations? In these contexts, this comment period should be extended."

Watch this site.

January 15, 2024

This is what the Fed is focused on: The Federal Reserve Board on Thursday announced the execution of the enforcement actions listed below: Consent prohibition order against John Freeze Former employee of Bank of Jackson Hole, Jackson, Wyoming Misappropriation of documents, including confidential supervisory information Consent cease and desist order and civil money penalty against Randy Johnson Former employee of Farmers and Merchants Savings Bank, Manchester, Iowa Misappropriation of confidential bank records

January 8, 2024

Corporate Fed, Dallas edition: Thomas J. Falk, retired chairman and chief executive officer, Kimberly-Clark Corporation, Dallas, Texas, renamed Chair.

January 1, 2024

The Federal Reserve is on Threads, UNlike even the United Nations....

December 25, 2023

Why not the Fed? U.S. Bank will pay $36 million over allegations the company illegally blocked out-of-work consumers from accessing unemployment benefits during the coronavirus pandemic, top federal banking regulators announced on Tuesday. At the onset of the COVID-19 pandemic, U.S. Bank had contracts with at least 19 states and the District of Columbia to deliver unemployment benefits to millions of newly out-of-work Americans through its prepaid card. But due to expanded antifraud controls, the nation's fifth-largest lender froze tens of thousands of prepaid card accounts without leaving users a way to regain access, according to the U.S. Office of the Comptroller of the Currency and U.S. Consumer Financial Protection Bureau.

December 18, 2023

From Basel III endgame to climate, the Fed has its finger in the wind. But on protests from low income areas of banks' redlining? Not so much.

December 11, 2023

The Fed didn't even ask Atlantic Union about this issues, which Inner City Press raised in September:

Re: Second Comments Opposing the Applications by Atlantic Union to acquire American National Bankshares - after Atlantic Union is fined by CFPB for exact issue raised in first comment

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

This is a second comment opposing Applications of Atlantic Union Bankshares Corporation, Richmond, Virginia to acquire American National Bankshares Inc., and American National Bank & Trust Company. Given the CFPB's December 7 fine and statement against Atlantic Union, on a precise issues raised in our first comment (and dismissed in AU's law firm's response, and not asked about by the FED in its AI letter), this comment must be considered timely.

See, "CFPB Finds Atlantic Union Bank Misled Customers About Fees The Consumer Financial Protection Bureau (CFPB) has ordered Atlantic Union Bank to pay $6.2 million, saying the bank misled customers and improperly enrolled them into paying overdraft fees. The $6.2 million in payments includes refunding at least $5 million to consumers and paying a $1.2 million penalty to the CFPB’s victim relief fund, the regulator said in a Thursday (Dec. 7) press release. The CFPB found that Atlantic Union Bank violated federal law when enrolling thousands of customers in checking account overdraft programs by phone, according to the release. Specifically, the bank charged fees without proper consent and misled customers about the terms and costs of overdraft coverage, the release said. “Atlantic Union Bank harvested millions of dollars in overdraft fees through a host of illegal practices,” CFPB Director Rohit Chopra said in the release. “Americans are fed up with junk fee scams and the CFPB will continue its work to ensure families are treated fairly.” https://www.pymnts.com/news/cfpb/2023/cfpb-finds-atlantic-union-bank-misled-customers-about-fees/

The comment period should be extended; evidentiary hearings should be held; and on the current record, the application should not be approved

December 4, 2023

On December 1 Fed Government Michael Barr said, "Foreign banks that have branches in the United States have access to the discount window. Outside the United States, some of these firms also have access to dollar liquidity from their own central banks" -- which as Argentina moves to disband its central bank....

November 27, 2023

Fed Dropped CRA Condition on Linkbankcorp Approval after Posting now Governors Not Told

By Matthew Russell Lee, Patreon Maxwell Book

SOUTH BRONX, Nov 21 – The Federal Reserve Board in considering the proposed merger on the rebound between New York-based Link Bank and Partners Bancorp omitted at the eleventh hour - or apparently the thirteenth hour - language about a Community Reinvestment Act condition imposed by the FDIC.

Now the Fed and its Governors have been asked Why - and when. But the Fed General Counsel dismissed the request for reconsideration without the Governors even seeing it.

Inner City Press and Fair Finance Watch have long exposed redlining - and in this vein, on May 6 they filed a Community Reinvestment Act challenge with the FDIC and Federal Reserve.

In October, the FDIC required from LINKBANK a plan to improve its lending to African Americans, which Inner City Press has published on its DocumentCloud here.

A "Corrected" Fed approval emailed to Inner City Press on November 16 did not acknowledge the CRA condition. But the approval order first posted - and voted on?- did. We on November 16 filed a request for reconsideration, on this site.

Watch this site.

November 20, 2023

Fed Dropped CRA Condition on Linkbankcorp Approval After Posting or Even Voting On It

By Matthew Russell Lee, Patreon Maxwell Book

SOUTH BRONX, Nov 16 – The Federal Reserve Board in considering the proposed merger on the rebound between New York-based Link Bank and Partners Bancorp omitted at the eleventh hour - or apparently the thirteenth hour - language about a Community Reinvestment Act condition imposed by the FDIC.

Now the Fed and its Governors have been asked Why - and when.

Inner City Press and Fair Finance Watch have long exposed redlining - and in this vein, on May 6 they filed a Community Reinvestment Act challenge with the FDIC and Federal Reserve.

In October, the FDIC required from LINKBANK a plan to improve its lending to African Americans, which Inner City Press has published on its DocumentCloud here.

The "Corrected" Fed approval emailed to Inner City Press on November 16 did not acknowledge the CRA condition. But the approval order first posted - and voted on?- did. We have on November 16 filed:

The Board's website currently says, of this order, that "Note: The initial version of this order was incorrect and inadvertently posted. A corrected version was posted on November 15, 2023."

It is true that the FDIC imposed a CRA condition, after receiving comments from Fair Finance Watch / Inner City Press. The FDIC sent the order with condition to us and we posted it online.

November 13, 2023

Amid a climate change protest at the IMF on November 9, who said "Shut the f---ing door"?

November 6, 2023

The Fed last week ended an enforcement order against Citigroup, starting "xWHEREAS, Citigroup Inc., New York, New York (“Citigroup”), a registered bank holding company, owns and controls Citibank, N.A., Sioux Falls, South Dakota (the “Bank”), other U.S. insured depository institutions, various Edge Act corporations organized under section 25A of the Federal Reserve Act (12 U.S.C. § 611 et seq.), and multiple other nonbank subsidiaries" -

October 30, 2023

As CRA Rule Launched by Fed Ameris Pre DOJ Deal Was Protested But Merger Rubber Stamped

By Matthew R. Lee, Patreon

NEW YORK, Oct 24 – Will the Federal Reserve (and OCC and FDIC) actually strengthen Community Reinvestment Act enforcement, as they today belatedly release the rule? Well, the bank with the worst record in the United States for gouging consumers with overdraft fees, Ameris, nevertheless got a rubber stamp approval from the Fed, to buy Hamilton State Bancshares in Georgia. Now this month it has settled discrimination charges with DOJ. Tellingly, the Fed could or would not see the discrimination.

In October 2023, "The resolution with Ameris Bank was filed in the U.S. District Court for the Middle District of Florida, along with the Department’s complaint, and is subject to court approval. The Department’s complaint alleges that, from 2016 through 2021, Ameris Bank avoided providing mortgage services to majority-Black and Hispanic neighborhoods in Jacksonville and discouraged people seeking credit in those communities from obtaining home loans." Here's what we said:

From Fair Finance Watch's (and Inner City Press') filings with the Fed: "Fair Finance Watch has reviewed Ameris' lending in 2016, the most recent year for which Home Mortgage Disclosure Act (HMDA) data [wa]s available, in both the Atlanta and the Jacksonville Metropolitan Statistical Areas (MSAs) and finds both to be disparate.. In the Jacksonville MSA in 2016 for home purchase loans, Ameris denied the applications of African Americans 2.69 times more frequently than those of whites. Ameris made 203 such loans to whites and only SEVEN to African Americans. In the Jacksonville MSA in 2016 for home improvements loans, Ameris made five such loans to whites and none to African Americans or Latinos. In the Jacksonville MSA in 2016 for refinance loans, Ameris denied the applications of African Americans 2.2 times more frequently than those of whites. Ameris made 100 such loans to whites and only FOUR to African Americans. This is disparate.

Now DOJ belatedly agrees. And the Fed, even as it releases a new CRA regulation? Watch this site.

October 23, 2023

In October, FDIC has required from LINKBANK a plan to improve its lending to African Americans, which Inner City Press has published on its DocumentCloud here.
But Link keeps spinning, issuing a press release about these partial approvals without mentioning the condition, and concluding it "remains subject to the approval of the Board of Governors of the Federal Reserve System and other customary closing conditions. LINK anticipates closing the Merger in the fourth quarter of 2023." How do they know?

October 16, 2023

So Governor Bowman went in person to Morocco and gave a speech, in front of a painting of the King. Bowman's views on Western Sahara aren't known...

October 9, 2023

It was said that the Fed would belatedly release the CRA reg on October 6. But this is all they released: "October 06, 2023 Federal Reserve Board finalizes a rule establishing capital requirements for insurers supervised by the Board "

October 2, 2023

It's said the CRA reg will belated by released on October 6- watch this site.

September 25, 2023

Fed wants to hear more from bankers: Governor Michelle W. Bowman to the Independent Community Bankers of Colorado: "I strongly encourage your participation to inform the rulemaking process. This audience is uniquely positioned to provide real-world feedback about the intended and unintended consequences of agency rulemakings."

September 18, 2023

In SDNY, Fed trial moved: " Gardner-Alfred et al v. Federal Reserve Bank of New York Case Number: 1:22-cv-01585-LJL Filer: Document Number: 187(No document attached) Docket Text: ORDER granting [186] Letter Motion to Continue Trial Date addressed to Judge Lewis J. Liman from Alex Leonard dated September 14, 2023 filed by Federal Reserve Bank of New York. The Court adjourns the previously set trial and pretrial deadlines and adopts the following trial schedule. The joint pretrial order, requests to charge, proposed voir dire, and in limine motions are due by October 6, 2023. Oppositions to motions in limine and objections to requests to charge and voir dire are due by October 13, 2023. The Final Pretrial Conference is rescheduled to December 6, 2023 at 3:30PM in Courtroom 15C at the 500 Pearl Street Courthouse. The Jury Trial is rescheduled to December 11, 2023 at 9:00AM in Courtroom 15C at the 500 Pearl Street Courthouse"

September 11, 2023

Here's a strange headline from the Fed's website: "

September 05, 2023

Federal Reserve Board announces approval of application by R. Dean Phillips Bank Trust Dated 11-19-2004, and its subsidiary, HNB Bancorp, Inc.

2004??

September 4, 2023

What has the Fed done about JPM Chase's enabling of Jeffrey Epstein? Nothing. Even the NYSDFS acted on Deutsche Banks... In Epstein Case JPM Chase Says Congress Did Not Envision USVI Suit as Oct 23 Trial Looms In Epstein Case JPM Chase Says Congress Did Not Envision USVI Suit as Oct 23 Trial Looms

By Matthew Russell Lee, Patreon Maxwell book

SDNY COURTHOUSE, Aug 31 – J.P. Morgan Chase and Deutsche Bank were sued for their enabling of Jeffrey Epstein, in lawsuits filed on Thanksgiving 2022 in the U.S. District Court for the Southern District of New York, where Inner City Press found them in the docket. Then the US Virgin Islands joined in against Chase

On August 31, Judge Rakoff heard oral argument from USVI and JPMorgan Chase, Inner City Press was there, thread:

USVI's lawyer: We seek to enjoin JPMorgan --

Judge Rakoff: From banking Jeffrey Epstein? He's...

USVI: From violating the law. Absent Jeffrey Epstein's death, Chase would still be violating the TVPA.

Judge Rakoff: Maybe this would not be a jury trial... Only in my nightmares do I see this as a bench trial.

JPM Chase lawyer: This was not the intent of Congress. All have are some snippets of floor statements

Judge Rakoff: If the trial goes forward, it'll start Oct 23. I'll rule on these motions by the end of September, if not before. Adjourned

More on Substack here

August 28, 2023

It's on: "Banc of California, Inc., Santa Ana, California; to acquire PacWest Bancorp, and thereby indirectly acquire Pacific Western Bank, both of Beverly Hills, California. 3 San Francisco 09/29/2023" - so how will the Fed treat this application? On greased skids? And mightn't JPM Chase need to apply? It's another litmus test...

August 21, 2023

Farmington Bank Belatedly Shut By Fed as SBF Jailed FOIA Appeal for Crypto Creeps Sequel

by Matthew Russell Lee, Patreon Book Substack

SDNY COURTHOUSE, Aug 17 – Alongside the larger flame-out of Silicon Valley Bank, Signature Bank too failed.

The Federal Reserve in belated response to Inner City Press' FOIA request says it has no record of reviewing Signature and crypto, nor any "record reflecting any review by the FRS of Silvergate’s (and Provident Bancorp Inc., Metropolitan Commercial Bank, Signature Bank, Customers Bancorp Inc.) of the banks’ connections with crypto-currency firms."

Federal Reserve letter to Inner City Press here

The Fed did, however, belatedly give Inner City Press the Farmington State Bank application it approved, with 100% ownership by Bahamas based Jean Chalopin. It's now on Inner City Press' DocumentCloud here.

Now on August 17, after FTX's Sam Bankman-Fried has been remanded to prison pending trial (Inner City Press "Crypto Creeps" book here), the Federal Reserve has belatedly taken action on Farmington, the horse decidedly out of (and in the case of SBF back in) the barn: "The Federal Reserve Board on Thursday announced an enforcement action against Farmington State Bank, of Farmington, Washington, and its holding company, FBH Corporation. In 2022, Farmington improperly changed its business plan without notifying the bank's supervisors and obtaining prior approval for those changes. Farmington has previously announced that it will voluntarily sell its loans and deposits to the Bank of Eastern Oregon."

On April 8, Inner City Press filed a FOIA appeal with the Fed: "This is an appeal of the FRB's denial and delayed and untransparent processing of and determinations on Inner City Press' December 22, 2022 FOIA request... After more than three months, all the FRB provided was the public portion of Farmington State Bank's application - this while FRB Governor Barr just told Congress that the Fed wants to be transparent, including to outside reviews. Most cynically, the Denial claims that "confidential information is not responsive" - basing that on its interpretation of a first request for clarification, a misinterpretation that all Inner City Press was request was previously public information - information which even then the Fed did not provide for eleven weeks. We wanted and want the records reflecting the FRS' review of Farmington State Bank's application, and the records about the Fed's review of crypto and the names firms: Silvergate with its FTX connections, record reflecting any review by the FRS of Silvergate's (and Provident Bancorp Inc., Metropolitan Commercial Bank, Signature Bank, Customers Bancorp Inc).

Does the Fed as Governor Barr said want to be transparent or not?

We'll have more on this.

August 14, 2023

"The Federal Reserve Board on Tuesday provided additional information on its program to supervise novel activities in the banks it oversees. Novel activities include complex, technology-driven partnerships with non-banks to provide banking services to customers; and activities that involve crypto-assets and distributed ledger or "blockchain" technology" - let's see what comes out of the SBF trial, now that he's detained....

August 7, 2023

Link Bank Bid To Buy Partners Bancorp On the Ocean Rebound has Belated Fed CRA Questions

By Matthew Russell Lee, Patreon Maxwell Book

SOUTH BRONX, Aug 1 – Pennsylvania, Delaware and Virginia are portrayed as diverse and ever progressive places. But their banks, not so much.

Consider for example the proposed merger on the rebound between New York-based Link Bank and Partners Bancorp, which recently broke off its proposed deal with OceanFirst.

Inner City Press and Fair Finance Watch have long exposed redlining - and in this vein, on May 6 they filed a Community Reinvestment Act challenge with the Federal Reserve.

On August 1, the Fed belated asked: "ased on staff’s review of Applicant’s letter to Mr. William T. Wisser, dated July 24, 2023, the following additional information is requested. Supporting documentation should be provided, as appropriate.

1. Describe in detail how LinkBank will adjust its fair lending program to accommodate the expanded market area acquired from VPB, particularly the Washington-Arlington-Alexandria VA-MD MMSA. 2. Clarify whether, and to what extent, LinkBank intends to integrate the consumer compliance and fair lending programs of TBOD and VPB into the resultant institution’s consumer compliance and fair lending programs.

3. Provide a list of organizations and community groups, if any, with which LinkBank has engaged since 2021 to help reach African American borrowers in Pennsylvania. In your response, provide detailed information about any partnerships that LinkBank has engaged in with these organizations and community groups since 2021. 4. Provide a list of organizations and community groups, if any, with which VPB has engaged since 2021 to help reach African American borrowers in the Washington-ArlingtonAlexandria VA-MD MMSA. In your response, provide detailed information about any partnerships that VPB has engaged in with these organizations and community groups since 2021.

5. Discuss in detail LinkBank’s and VPB’s efforts to reach African American borrowers in any area, including any specialized products and marketing campaigns targeting such borrowers, since 2021.6. Provide further information on LinkBank’s recent CRA activities since 2021, following the latest CRA performance evaluation of The Gratz Bank on March 22, 2021 (which preceded the acquisition of LinkBank by The Gratz Bank and the resulting institution’s name change to “LinkBank”). In particular, provide further information regarding LinkBank’s activities to improve its geographical distribution of loans throughout its assessment areas since the March 22, 2021, performance evaluation of The Gratz Bank. 7. Provide further information on VPB’s CRA activities since its October 2, 2017, performance evaluation."

Fair Finance Watch has been reviewing LinkBank including its 2021 HMDA data not taken into account in any CRA exam and finds it troubling.

July 31, 2023

From the Fed last week: "The Federal Reserve Board on Monday announced a consent order and a $268.5 million fine with UBS Group AG, of Zurich, Switzerland, for misconduct by Credit Suisse, which UBS subsequently acquired in June 2023. The misconduct involved Credit Suisse's unsafe and unsound counterparty credit risk management practices with its former counterparty, Archegos Capital Management LP" - but what now about the Hwang subpoenas reported in this week's Inner City Press Bank Beat report?

July 24, 2023

Bowman watch, safe harbor bid edition: Fed Governor Michelle Bowman says the Board "should improve its approach to processing applications in cases where a member of the public has made an adverse comment, particularly when the recent supervisory record addresses the concerns raised and is consistent with approval." Vantage Bank Texas President and CEO Jeff Sinnott agrees with Bowman - not surprising. But what about Quontic, which the Reserve Bank approved, before the enforcement action?

July 17, 2023

Kids gloves, from Link Bank to BofA to... "The Federal Reserve Board on Tuesday announced the termination of the enforcement action listed below: Capital One Financial Corporation, McLean, Virginia Cease and Desist Order dated August 4, 2020"

July 10, 2023

Earlier this year Inner City Press / Fair Finance Watch wrote to the Federal Reserve with complaints about Quontic Banks. In a new low, after the Board in DC denied any extension of the comment period, it was the Federal Reserve Bank of Philadelphia which wrote back and rubber-stamp approved on a delegated basis - no HMDA data, no Board. Now this: "Quontic Bank Acquisition Corp., Astoria, New York, and Quontic Bank Holdings Corp., Astoria, New York Written Agreement dated July 5, 2023." A corrective action notice...

July 3, 2023

Stress test shorts: The decline in Truist's and U.S. Bancorp's stressed CET1 ratio looks rather poorly compared to the median (-230 and -180 basis points, respectively, Figure 3), and USB saw its ratio drop to the second lowest in the group, surpassed only by Citizens Financial Group (CFG) with a stressed CET1 ratio of 6.4%.

June 26, 2023

Since Kugler has pledged to recuse herself from participating in any matter involving a former employer or client for four years — beyond what’s required under the Biden administration’s ethics pledge — and to refrain from signing on to a financial services firm within four years of leaving government - why can't and don't the other Fed governors?

June 19, 2023

Look who has requested access to Reserve Bank master accounts and financial services

COMMERCIUM FINANCIAL CHEYENNE WY 5/23/2022 Pending Tier 3 Kansas City Not Federally Insured CUSTODIA BANK, INC CHEYENNE WY 10/29/2020 Rejected 1/27/2023 Tier 3 Kansas City Not Federally Insured KRAKEN FINANCIAL CHEYENNE WY 10/6/2020 Pending Tier 3 Kansas City Not Federally Insured MORNING STAR FCU LAME DEER MT 1/26/2023 Approved 4/28/2023 Tier 1 Minneapolis NCUA NORTH STAR COMMUNITY CU MADDOCK ND 1/6/2023 Approved 5/10/2023 Tier 1 Minneapolis NCUA GS&L MUNICIPAL BANK GOUVERNEUR NY 10/27/2022 Approved 2/28/2023 Tier 1 New York FDIC FNALITY LONDON 10/17/2022 Pending TBD New York Not Federally Insured

June 12, 2023

Gov Jefferson: "the staffs of the U.S. federal banking agencies are diligently working on a Basel III endgame proposal that should be issued for public comment soon. At the same time, the Federal Reserve staff is considering ways to enhance the ability of stress tests to capture a wider range of risks and identify vulnerabilities at the largest banking organizations."

June 5, 2023

Bowman Watch II: "This local perspective is one of the great advantages of the Federal Reserve System's regional structure, and of the Fed Listens initiative, which complements the Board's efforts to understand national economic conditions. In 2019, the Board launched Fed Listens with a year of listening sessions with the public focused on monetary policy"

May 29, 2029

Waller watch: "There is a little over a month between the June and July FOMC meetings, and during that time we will learn more about how credit conditions are evolving. Over four months will have passed between the Silicon Valley Bank failure and the July meeting. By then we will have a much clearer idea about credit conditions. If banking conditions do not appear to have tightened excessively, then hiking in July could well be the appropriate policy."

May 22, 2023

Bowman watch: "I see one of my many functions and roles as a Member of the Board of Governors as providing that open door and opportunity for direct engagement with a policymaker for our regional and smaller banks, as well. Your Texas ABA executive, Chris Furlow, who is a long time friend and colleague, can put you directly in touch with me should you desire to do so. "

May 15, 2023

Governor Michelle W. Bowman gave a speech about bank failures - and nary a word about the exclusion of the public from any review of those being handed the failed banks, like JPM Chase...

May 8, 2023

PacWest on the Ropes with Comerica to Follow Fed Collins on the Board as FRB Says All Good

by Matthew Russell Lee, Patreon Book Substack

FEDERAL COURTHOUSE, May 4 – After the failures of Silicon Valley Bank and Signature Bank in New York, next was First Republic Bank.

On on May 3, PacWest Bank's shares tumbled, also those of Western Alliance, Zions and Comerica -- which has former Federal Reserve big wig Michael E. Collins cashing in on its board.

Meanwhile the Federal Reserve Board in Washington assures that all's well - as it denies FOIA requests about its regulation, notably lax on fair lending and the Community Reinvestment Act.

At 3 am Eastern time on May 1, the First Republic (and $13 billion) was given to JPMorgan Chase, which is already over the "maximum" 10% of US deposits threshold - and whose CEO Jamie Dimon has been ordered deposed about his knowledge of, and link to, the pedophile conspiracy of Jeffrey Epstein. It's come to this.

The JPM Chase complaint is on Patreon, here.

On March 20, 2023 U.S. District Court for the Southern District of New York Judge Jed S. Rakoff in a bottom line order dismissed some but not all claims, in the Epstein-related cases against JPMC and Deutsche Bank.

Inner City Press,, which reports daily on the SDNY (and the Community Reinvestment Act evasions of Chase and other banks like KeyCorp) put the order on its DocumentCloud here.

April 30, 2023 piece on JPM Chasing First Republic amid WHCA glitz and the E. Jean Carroll v. Trump trial, on Substack here

There was no public input into the sell-off, including into how many of First Republic's 84 branches for example in New York City will be closed.

Back on April 18, after a telephone conference without transcription, Judge Rakoff ordered: "Jamie Dimon should be set aside two days for his deposition. On the first day, plaintiffs will have the opportunity to depose Mr. Dimon for a combined total of five hours. Mr. Staley will have the opportunity to depose Mr. Dimon for two hours. If, at the end of the first day, any party believes that it needs more time to depose Mr. Dimon, it must convene a joint call to Chambers by no later than 5:00 PM to explain why. The Court will then rule as to whether Mr. Dimons deposition should continue for a second day and, if so, for how long."

Will that call be open to the press and public?

More on Substack here.

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May 1, 2023

FRB Downplays Its Failure on SVB As Claims No Review of Signature Crypto But FOIA Scam

by Matthew Russell Lee, Patreon Book Substack

SDNY COURTHOUSE, April 28 – Alongside the larger flame-out of Silicon Valley Bank, Signature Bank too failed, FOIA story below.

On SVB, the Federal Reserve on April 28 issues a report downplaying it failure(s) and notably not mentioning the lack of any public comment or Community Reinvestment Act / CBA review as SVB was handed over to First Citizens, and Signature to NYCB.

Federal Reserve letter to Inner City Press here

Inner City Press submitted to the Federal Reserve a Freedom of Information Act request including about Signature Bank: "This is a FOIA request for all record regarding FTX... Also, for Silvergate with its FTX connections, record reflecting any review by the FRS of Silvergate's (and Provident Bancorp Inc., Metropolitan Commercial Bank, Signature Bank, Customers Bancorp Inc.) of the banks' connections with crypto-currency firms... This is a request for expedited treatment."

The Federal Reserve acknowledged receipt and said it was granting expedited process. Then -- nothing.

Now, as the Fed belatedly backs up Signature Bank after Silicon Valley Bank, the Fed tries to paper its delay: "Months after the Federal Reserve said it granted Inner City Press expedited processing of its FOIA request on the Fed's work / errors on crypto, and two months after Inner City Press answered a request for clarification, past 4 pm on Friday March 10, 2023, this: "Good afternoon Mr. Lee The second part of your request seems to concern other entities (Silvergate, Provident Bancorp Inc., Metropolitan Commercial Bank, Signature Bank, Customers Bancorp Inc.). Please confirm the scope of this part of your request, did you intend to seek applications related information for these entities?"

Inner City Press again immediately responded and clarified, about FTX. Now the response above. Watch this site."

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April 24, 2023

Today's Federal Reserve doesn't believe that the collapse of banks and crypto are matters of urgent public concern - they've written to Inner City Press: "In support of your request for expedited treatment, you state that “‘in light of the indictment of FTX / Alameda’s Sam Bankman-Fried and Caroline Ellison (cooperating), and an upcoming January 3, 2023 hearing’ - case proceeds.” However, you have not set forth facts demonstrating an urgent need to inform the public about an actual or alleged activity of the Federal Government. Thus, I have determined that your request does not comply with the criteria for expedited processing." Really.

April 17, 2023

On April 14, the Fed announced "The Federal Reserve Board on Friday announced its approval for UBS Group AG, of Zürich, Switzerland, to acquire the U.S. subsidiaries of Credit Suisse Group AG, of Zürich, Switzerland. The application was submitted in connection with UBS Group AG's acquisition of Credit Suisse Group AG. In connection with the proposal, UBS has committed to provide the Board with an implementation plan for combining the U.S. business and operations of UBS and Credit Suisse, which will be updated quarterly. The implementation plan will address UBS's obligations to comply with more stringent enhanced prudential standards, including liquidity standards." No such announcement with regard to SVB - First Citizens, or Signature - NYCB. So oversea forced mergers are "reviewed," but those in the US are not?

April 10, 2023

Fed-Speaks: "The Federal Reserve Board on Thursday announced that it has fined Wells Fargo & Co., of San Francisco, California, $67.8 million for the firm's unsafe or unsound practices relating to historical inadequate oversight of sanctions compliance risks at its subsidiary bank, Wells Fargo Bank, N.A." Historical?

April 3, 2023

FRB Claims No Review of Signature Crypto But Here Is Farmington Application FRBSF OKed

by Matthew Russell Lee, Patreon Book Substack

SDNY COURTHOUSE, April 1 – Alongside the larger flame-out of Silicon Valley Bank, Signature Bank too failed.

Now the Federal Reserve in belated response to Inner City Press' FOIA request says it has no record of reviewing Signature and crypto, nor any "record reflecting any review by the FRS of Silvergate’s (and Provident Bancorp Inc., Metropolitan Commercial Bank, Signature Bank, Customers Bancorp Inc.) of the banks’ connections with crypto-currency firms."

Federal Reserve letter to Inner City Press here

March 27, 2023

Credit Suisse USB Merger amid Bank Meltdown Preapproved by Fed as Collins on Comerica

by Matthew Russell Lee, Patreon Book Substack

SDNY COURTHOUSE, March 19 – Alongside the larger flame-out of Silicon Valley Bank, Signature Bank too failed. Now on March 19 in Switzerland, the forced and subsidized marriage of USB and Credit Suisse. Both have US subsidiaries but from the Fed, this pre-approval:

"The following statement was released by Secretary of the Treasury Janet L. Yellen and Federal Reserve Board Chair Jerome H. Powell: 'We welcome the announcements by the Swiss authorities today to support financial stability. The capital and liquidity positions of the U.S. banking system are strong, and the U.S. financial system is resilient. We have been in close contact with our international counterparts to support their implementation.'"

Preapproval, like the entry of Goldman Sachs and Morgan Stanley into the banking system, with no comment period.

On Signature Bank's board of directors is not only Barney Frank (who after leaving Congress undermine his own Dodd Frank Act) but also former New York State Superintendent of Banks Derrick D. Cephas.

Among those being reviewed by Moody, as simply the first example, former Federal Reserve Bank of Philadelphia and Cleveland bigwig Michael E. Collins is on the board of Comerica, the bank that abandoned Detroit for Dallas. The Administration is saying that people will be held accountable - but who?

Next up: PacWest and Western Alliance, Intrust, UMB and Zions. Watch this site.

March 20, 2023

Amid Bank Meltdown Former Fed Collins on Comerica Board Like Signature Frank & Cephas

by Matthew Russell Lee, Patreon Book Substack

SDNY COURTHOUSE, March 14 – Alongside the larger flame-out of Silicon Valley Bank, over the weekend Signature Bank too failed. On Signature Bank's board of directors is not only Barney Frank (who after leaving Congress undermine his own Dodd Frank Act) but also former New York State Superintendent of Banks Derrick D. Cephas.

March 13, 2023

Months after the Federal Reserve said it granted Inner City Press expedited processing of its FOIA request on the Fed's work / errors on crypto, and two months after Inner City Press answered a request for clarification, past 4 pm on Friday March 10, 2023, this: "Good afternoon Mr. Lee Staff is still unclear about the scope of your request. Referring to the initial clarification email below, the second part of your request still needs clarification. “The second part of your request seems to concern other entities (Silvergate, Provident Bancorp Inc., Metropolitan Commercial Bank, Signature Bank, Customers Bancorp Inc.). Please confirm the scope of this part of your request, did you intend to seek applications related information for these entities? Clarifications are needed in order to conduct a search of Board records and process this portion of your request.” I realize from your January 10 email response that you are seeking application submissions, Additional Information “AI”, and approval information. However, it is unclear what application(s) you seek this information concerning. Did you intend to seek applications for FTX to acquire or merge with Silvergate, FTX to acquire or merge with Provident Bancorp, Inc., or FTX to acquire or merge with Metropolitan Commercial Bank? It is unclear the connection you intended for these institutions (other than media mentions) and as such conducting a search of Board records cannot be completed. Did you intend to seek records that reference all of these institutions together? Did you intend to seek applications records about each institution? If this was your intent, we need a target institution ABC Bank and Provident, Signature Bank and XYZ Bank, for example. From these examples alone, the interpretations are many. It would be helpful if you could include the date the application was approved or announced in the H.2. Doing so would allow us to search and review records more quickly, should they exist. I realize that you responded in a timely manner to our last communication about this request, but your comments were not specific clarifications with respect to the named institutions in part 2 of your request that would enable staff to conduct a reasonable search. If you have additional context, please provide it as soon as possible. After which, staff may be able to make reasonable interpretations regarding the information you seek."

Inner City Press again immediately responded and clarified, about FTX. Watch this site.

March 6, 2023

BMO Harris BNP Got Fed OK Despite Peters Case With Climate Dismissed Now French Suit

By Matthew Russell Lee, Patreon Story

FED COURT / S Bronx, Feb 27 – Whether or not the U.S. Community Reinvestment Act will actually be enforced under the Administration and its regulators remains an open question, or one answered in the negative, at least by the Federal Reserve. Consider: Inner City Press immediately reported that BMO Harris' application to buy Bank of the West and its more than 500 branches from BNP would be a litmus test.

Fair Finance Watch noted, from Day 1, that in 2020 BMO Harris denied many more mortgage applications from African Americans than it approved: 509 denied versus only 223 loans made to African Americans, nationwide. BMO's numbers for whites were the reverse: 9270 loans made, versus less then six thousand denials. As noted, there are also climate and secrecy issues. Fair Finance Watch and other raised branch closings.

On October 14, the banks' counsel sent Fair Finance Watch what purported to be a copy of its submission to the Fed under the Ex Parte Rules -- but the entire thing was withheld, under this cover message: "Attached is the public portion of the BMO response to the Federal Reserve Bank of Chicago’s request for additional information received on October 3, 2022. Please feel free to reach out to me with any questions. Best, Ro Ro Spaziani Wachtell, Lipton, Rosen & Katz." No substance was attached, just a request for confidential treatment This was outrageous. The Fed itself should make these types of exhibits public.

February 27, 2023

The Federal Reserve's FOIA responses have hit a new low; this appeal has been filed:

This is a FOIA appeal of the FRB's total denial of Inner City Press' FOIA request regarding MVB Bank's February 7 additional information response, in which MVB answered each and every question with referring to a withheld, "Confidential" Exhibit. The letter was and is subject to the Fed's ex parte rules - withholding the entire response, including after an immediate FOIA request, makes the Fed's ex parte rules meaningless. One of the withheld answers is about pro forma organizational chart, another concerns crypto, a matter of public import on which the Fed's record, after the SF Reserve Bank's Farmington State Bank / FTX - Alameda approval, is ever more questionable.

In signing in to the Fed's FOIA site to obtain this FOIA denial, I noticed that the Fed lists Inner City Press' earlier FOIA request about Farmington and other Fed crypto approvals (2023-178) as "On Hold - Need Info/Clarification." But on January 10, 2023 I immediately answered the request for clarification / narrowing. What is happening with the Fed's FOIA compliance? What is happening with the crypto FOIA request, on which the Fed purported to grant expedited treatment? These should be dealt with, on or in parallel with this appeal.

Thank you for your prompt attention,
Matthew R. Lee
Inner City Press / Fair Finance Watch

February 20, 2023

With Lael Brainard leaving, even before the CRA reg is out, who's next? With Governor Bowman beating the drum for even faster and more automatic merger approvals, the next Governors better be one that stands up to that...

February 13, 2023

Lakeland Bank DOJ Deal Left Disparities in NY So Protest Now Fed Questions to Provident Here

By Matthew Russell Lee, Patreon Maxwell book

SOUTH BRONX NY, Feb 10 – When the US Department of Justice sued and immediately settled with Lakeland Bank for fair lending violations, it announced a proposed merger with Provident Bank.

As if to sweep it under the carpet.

We refer to the application filed by Provident Financial Services, Inc. (“Provident”), Jersey City, New Jersey, for prior approval of the Board of Governors of the Federal Reserve System (the “Board”), pursuant to Section 3(a)(3) and 3(a)(5) of the Bank Holding Company Act of 1956, as amended, and Section 225.15 of Regulation Y, to acquire Lakeland Bancorp, Inc. (“Lakeland”), Oak Ridge, New Jersey, and thereby indirectly acquire Lakeland Bank, Newfoundland, New Jersey (“Transaction”). Based on our review of the current record, the following additional information is requested. Please provide responses to all the following items, including those in the Confidential Annex. Supporting documentation should be provided, as appropriate. Convenience & Needs/Community Reinvestment Act (“Act”) 1. Provident’s response to Question 1 of the November 30 Request for Additional Information (“November 30 AI Request”) indicates that “[t]he combined company will deliver an expanded set of products and services to its customers and communities.” Describe those products and services to be offered by the combined organization that Provident deems most beneficial to customers in low- or moderate-income (“LMI”) geographies or income levels. 2. Indicate whether any consumer products or community development programs and services of either bank are expected to be discontinued as a result of the proposed transaction, and whether any products, programs or services that are not currently offered will be made available in the combined organization’s markets. 3. The application states “Provident and Lakeland will determine through the integration planning process how the Combined Bank will continue the successful processes, policies, procedures and technology platforms of Provident and Lakeland to maintain a strong, comprehensive and sustainable CRA program.” Provide an update on these efforts. Mark J. Menting, Esq. February 8, 2023 2 NONCONFIDENTIAL // EXTERNAL Compliance Program 4. In the response to Question 6(a) of the November 30 AI Request, Provident stated that it anticipated that its existing compliance risk management program would “either be the successor policies and procedures for the combined organization, or that they may serve as a solid foundation for revised policies and procedures going forward.” If available, provide an update on the expected compliance risk management program at the combined organization. 5. Describe in greater detail Provident Bank’s current fair lending program and risk management controls with respect to fair lending and discuss the rationale behind the decision for the combined organization to adopt the overall framework and structure of Lakeland Bank’s fair lending compliance program. To the extent not previously addressed, include in your discussion any areas of Lakeland Bank’s existing fair lending program the combined organization intends to enhance, as well as all efforts to ensure that the policies and procedures adopted by the combined organization will be adequate for the combined organization to provide equal access to credit to majority-minority communities in its assessment area (“AA”). Branching 6. For Provident Bank, Lakeland Bank, and the combined organization, provide the number and percentage of total branches that are or will be located in LMI and/or majorityminority census tracts. 7. To the extent not previously addressed, describe the process by which Provident Bank currently determines whether and where to open or close a branch. Include in your discussion any fair lending considerations the bank takes into account in making such determinations. Indicate whether the existing policies and procedures of Provident Bank or Lakeland Bank will be implemented at the combined organization. Staffing 8. Discuss whether any existing staff of Provident Bank or Lakeland Bank are under consideration to be the combined organization’s Chief Compliance Officer or Fair Banking Officer. If so, identify those individuals and provide an update regarding the timing and content of the selection process, if available. 9. Confirm, if such is the case, that Lakeland Bank’s current Community Development Officer will continue in that role at the combined organization. If not, indicate who will assume that position at the combined organization, if known. Mark J. Menting, Esq. February 8, 2023 3 NONCONFIDENTIAL // EXTERNAL 10. Provide an update to the organizational chart provided in response to question 6(b) of the November 30 AI Request reflecting all compliance-related positions at the combined organization. For those positions where an individual has been identified to fill the role, indicate that individual’s name in the organizational chart. Department of Justice (“DOJ”) Consent Order 11. Under Section C of the Consent Order, Lakeland Bank is required to take certain steps with respect to fair lending training. Indicate whether the combined organization intends to continue to adhere to those training requirements following the proposed acquisition. If so, indicate whether they will apply to all employees of the combined organization or only those employees retained from Lakeland Bank. 12. Provide an update on the timing of the opening of the full-service branch in Newark, New Jersey, as described in Paragraph 19 of the Consent Order. In addition, provide an update on the plans of Lakeland Bank or the combined organization to open a second branch, if available.

Tellingly, the banks' response on CRA to not only the lending disparities but even the rare DOJ discrimination settlements has been to attack the comments.

February 6, 2023

While the Fed pretends to be serious, now on Custodia, after allowing FTX in through Farmington State Bank, now they delegate to a (privately-owned) Reserve Bank the approval for a bank with a crypto card and other problems: "We refer to the Notice of Change in Bank Control (the “Notice”) submitted to the Federal Reserve Bank of Philadelphia (“Reserve Bank”) and the Board of Governors of the Federal Reserve System (“Board”), pursuant to the Change in Bank Control Act of 1978, as amended, by (1) the Estate of Steven B. Schnall, Sherri Silver Schnall as Preliminary Executor, both of New York, New York, to retain voting shares of Quontic Bank Acquisition Corp. (“QBAC”), and Quontic Bank Holdings Corp. (“QBHC”), and thereby indirectly retain voting shares of Quontic Bank, all of New York, New York; and (2) the Schnall Disclaimer Trust A, Sherri Silver Schnall, individually, and as co-trustee, both of New York, New York, with Amie Hoffman, as co-trustee, New Hope, Pennsylvania; and the Sherri S. Schnall Family Irrevocable Trust, Amie Hoffman as trustee, both of New Hope, Pennsylvania; to acquire voting shares of QBAC, and QBHC, and thereby indirectly acquire voting shares of Quontic Bank. Accordingly, all notificants in the Notice to become a group acting in concert. This Reserve Bank, acting under authority delegated by the Board at section 265.11(c)(5)(iv) of its Rules Regarding Delegation of Authority, has determined not to disapprove the Notice." We'll have more on this.

January 30, 2023

Fed Denies Custodia Bank After FTX Wreck As FOIAed on Moonstone Bank by Inner City Press

By Matthew Russell Lee, Patreon

SDNY COURTHOUSE, Jan 27 – Amid the prosecution of Samuel Bankman-Fried on wire fraud, money laundering and campaign finance violation charges, the role of the Federal Reserve is coming to the fore. Now it seeks to step back from its brink by denying the application of Custodia, with order still withheld. See below.

Inner City Press was unsurprised to learn of Fed laxity as Alameda invested in Farmington State Bank, renamed Moonstone Bank.

The Federal Reserve acknowledged receipt: "Your request has been assigned number FOIA-2023-00178. Please reference this number in all future correspondence. Request description: This is a FOIA request for all record regarding the FRS' approval for the application / request for membership in the Federal Reserve System by Farmington State Bank [also] any review by the FRS of Silvergate's (and Provident Bancorp Inc., Metropolitan Commercial Bank, Signature Bank, Customers Bancorp Inc.) of the banks' connections with crypto-currency firms."

On January 27, still withholding documents, the Fed "announced its denial of the application by Custodia Bank, Inc., Cheyenne, Wyoming, to become a member of the Federal Reserve System. The Board has concluded that the firm's application as submitted is inconsistent with the required factors under the law. Custodia is a special purpose depository institution, chartered by the state of Wyoming, which does not have federal deposit insurance. The firm proposed to engage in novel and untested crypto activities that include issuing a crypto asset on open, public and/or decentralized networks. The firm's novel business model and proposed focus on crypto-assets presented significant safety and soundness risks. The Board has previously made clear that such crypto activities are highly likely to be inconsistent with safe and sound banking practices. The Board also found that Custodia's risk management framework was insufficient to address concerns regarding the heightened risks associated with its proposed crypto activities, including its ability to mitigate money laundering and terrorism financing risks. In light of these and other concerns, the firm's application as submitted was inconsistent with the factors the Board is required to evaluate by law. The Board's order will be released following a review for confidential information."

And when will that be? And when the FOIA response on the promised expedited timeline?

January 23, 2023

Fed speak - but no live questions: "What: Federal Reserve Bank of Dallas President & CEO Lorie Logan will speak about U.S. economic outlook and monetary policy at the McCombs School of Business at The University of Texas at Austin. Logan took office last August, and with this speech she will introduce the monetary policy objectives that will guide her tenure. When: Wednesday, Jan. 18, 2023 4-4:05 p.m., Texas McCombs Dean Lillian Mills, welcome and introduction. 4:05-4:30 p.m., Dallas Fed President & CEO Lorie Logan. 4:30-4:45 p.m., Q&A moderated by Julia Coronado, Texas McCombs clinical associate professor of finance; time will not allow for live questions"

January 16, 2023

NY Fed Dissolved TRO to Fire Unvaccinated Staff Now Fed Accuses Lawyer of Contacts

By Matthew Russell Lee, Patreon Maxwell Book
BBC - Guardian UK - Honduras -