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Community Reinvestment Act For Coronavirus Must Have Comment Period Extended Fair Finance Watch Says

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

They ask that in light of Coronavirus / COVID-19 the comment period on the assault on CRA be extended for months. Confirmation of receipt by of the comment and request has been received. Here it is: March 11, 2020  Re: Docket ID OCC-2018-0008 - 3d opposition to OCC/FDIC plan to weaken CRA - demand that comment period be extended for months in light of Coronavirus COVID-19 & OCC inaction

To whom it may concern at the OCC and FDIC:    On behalf of Fair Finance Watch, and Inner City Press, and in my personal capacity, this is a third timely comment opposing the proposal by Comptroller Joseph Otting and the FDIC to weaken the CRA.    To be clear: the comment period must now be extended for months in light of Coronavirus / COVID-19. This is based on the Administration's own statements on the topic, and what we can only interpret at the OCC's furthering weakening by it, with no response to our timely comments on Northfield Bank - Victory State Bank, no documents response to our FOIA request about this CRA proposal and the Comptroller's schedule, and the OCC's failure to inquire into even branch closings int he CBNA - Steuben Trust proposal we comments on. This is not the time to be slipping through an undermining of CRA.  

 Note, simply as examples, that Federal courts have shut down (see, e.g., the Eastern District of Washington), whole law firms have, and the containment of New Rochelle, NY just above The Bronx. The comment period must be extended. 

Enforcing the CRA including through commenting to the Federal Reserve and FDIC, and OCC under previous Comptrollers, the results have been new bank branches in the South Bronx, and lending and consumer protection commitments well beyond.   Now under Otting the OCC is ignoring, rebuffing and sometimes simply rejecting such public comments. This as Otting says he is personally unaware of discrimination. So, during and in connection with this comment period on his attempt to more systematically defang the CRA, Fair Finance Watch has commented on a proposed acquisition by a national bank which settled race discrimination charges, Evans Bank: "Evans had redlined Buffalo’s predominantly African-American East Side neighborhoods, intentionally excluding these neighborhoods from its lending area.  Evans Bank also allegedly developed mortgage products that it made unavailable to these neighborhoods, notwithstanding the creditworthiness of the applicants; and refused to solicit customers, market mortgages or provide banking facilities in those neighborhoods.  The lawsuit alleged that by redlining the East Side neighborhoods, which are home to more than 85,000 people, Evans excluded an area that is home to the vast majority of Buffalo’s African-American population from the marketing and sales of its mortgage products and services."   

 This is a national bank. Its Fairport Savings application should be denied. And for the record, the CFPB's elimination of the HMDA informaiton that has been available on the FFIEC's and even its own website for 2017 data is part of the destruction of CRA and HMDA of which the OCC is a part.   Also for the record, "Nasca says there may be consolidation of some back office staff." Public hearings should be held. But Otting routinely denies such requests.     Aain, since Otting became Comptroller, we have seen timely comments ignored, and been denied access to bank merger applications by a retaliatory imposition of FOIA fees. The Federal Reserve and other federal agencies, like the OCC pre-Otting, grant Inner City Press FOIA fee waivers. Under Otting, the OCC does not. On Chinatown FSB, the OCC refused to consider a timely comment. The OCC unilaterally determined not to accept public comments on a major bank's charter conversion application, which it rubber stamped. This has been rogue-like behavior.    As a proud member of NCRC we join in its comments.  The central point of CRA is ensuring that banks meet local needs. For agencies to ascertain that, they must listen carefully to the public.   But Otting has shown that he does not, or does so only selectively. The proposal must be rejected. We will have further comments. Matthew R Lee Fair Finance Watch (and Inner City Press) New York.

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