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

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

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

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

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

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

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

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

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

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

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

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

  Watch this site.

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