| Ford Credit
Bank Proposal Challenged by Fair Finance
Watch Citing Evasion of New CRA
By Matthew
Russell Lee, Patreon Maxwell
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S Bronx / SDNY,
August 24 – While the
Administration says it is
modernizing the Community
Reinvestment Act, Ford is
rushing to use the old rule to
evade CRA, ostensibly in the
name of electric vehicles.
On August 23-4
Fair Finance Watch, with Inner
City Press on the FOIA, filed
comments opposing it with the
FDIC and Utah regulator:
Re: Timely
opposition to the application
by the proposed Ford Credit
Bank
Dear Kathy Moe
Regional Director, Janet
Kincaid Deputy Director,
others at FDIC & Utah DFI:
This is a timely
first comment opposing and
requesting an extension of the
FDIC's public comment period
on the Applications by the
proposed Ford Credit Bank.
This proposal, if approved,
would make a mockery of the
Community Reinvestment Act,
particularly as it is being
modernized by the new
regulation on which the
comment period closed on
August 5.
The FDIC should
hold public hearings, and on
the current record deny the
application.
Contrary to the current and
even more to the impending CRA
regulation claims that despite
its high volume of auto
lending -- with its own
compliance problems -- it
should be viewed as a limited
purpose institution.
Fair Finance Watch opposes
this. Consider,
for example, the size of Ford
Credit's retail lending, here:
"Ford Credit delivered record
quarterly earnings before
taxes of $1.6 billion."
Compare: 87
Fed. Reg. 33928, VIII. Retail
Lending Test Product
Categories and Major Product
Lines Public
hearings are needed, and a
re-opened comment period after
the new CRA regulation is
finalized.
Consider
also, beyond previous issues
at Ford's lending operations
of discrimination against
African Americans and Latinos,
these recent TCPA cases:
Coleman v. Ford Motor Credit
Company LLC (8:21-cv-00647)
District Court, M.D. Florida;
and Diaz v. Ford Motor
Credit Company, LLC
(3:20-cv-06027) District
Court, N.D.
California
The FDIC is administering a
loophole that even many in the
industry, because consumer and
CRA advocates,
oppose.
For the
record, this is a timely
comment on: " Ford Credit Bank
(Proposed) 15 West South
Temple SALT LAKE CITY,
UT Deposit
Insurance (New
Bank)
07/22/2022
08/24/2022
San
Francisco
The comment period
should be extended;
evidentiary hearings should be
held; and on the current
record, the application should
not be approved.
Very Truly
Yours,
Matthew Lee, Esq.
Executive Director Inner
City Press/Fair Finance Watch
cc: Utah Dept of
Financial Institutions
We'll have more
on this.
***
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