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By Matthew Russell Lee, Patreon
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UN GATE / SDNY COURT, Sept 1 – Acting U.S. Comptroller of the Currency Brian Brooks, as Coinbase’s chief legal officer,  was paid $1.4 million in salary -- separate from the stock options -- in the year and a half he spent with company, which had weighed seeking a charter through the OCC before making other moves to access the banking system."

  Now Brooks says, "I'm increasingly thinking of this agency as an activities regulator, not an entity regulator." But since the Community Reinvestment Act is enforced with regard to entities, this is an even more egregious attach on CRA than Otting engaged in. Combined with Brooks open contempt for rulings of the U.S. District Court for the Southern District of New York, it shows why he should be removed as Comptroller.

 Now "[a] proposal by the regulator of the nation’s largest banks would allow predatory lenders to do an end-run around state interest rate caps, exposing people to high-cost loans with minimal consumer protections, according to a comment letter being submitted today to the Office of the Comptroller of the Currency (OCC) by 13 national consumer and civil rights groups. Most of these groups also joined a shorter comment letter being submitted today by more than 100 community based organizations across the country.      The Center for Responsible Lending, National Consumer Law Center (on behalf of its low income clients), Americans for Financial Reform Education Fund, Consumer Action, Consumer Federation of America, the Leadership Conference on Civil and Human Rights, NAACP, National Association of Consumer Advocates, National Association for Latino Community Asset Builders, National Coalition for Asian Pacific American Community Development (National CAPACD), Public Citizen, UnidosUS, and U.S. PIRG strongly oppose the OCC’s “true lender” rule.      The proposed rule would facilitate fraudulent predatory “rent-a-bank” schemes where a non-bank lender launders a loan through a bank (which is not subject to state rate caps)  in order to charge interest rates beyond what state law allows.       The OCC’s proposal provides that a bank “makes” the loan and thus is the lender -- so that state interest rate laws do not apply -- so long as the bank’s name is on the loan agreement or the bank funds the loan. This rule would prohibit courts from looking behind the fine print form to the truth about which party is running the loan program and is the “true lender.” The head of the agency has said that he intends for this rule to shelter rent-a-bank arrangements from litigation. Just days before the speech, the District of Columbia (D.C.) attorney general sued a high-rate rent-a-bank lender, Elevate, for violating state rate caps; and California just launched an investigation into LoanMart, another rent-a-bank lender. Currently, 45 states and D.C.  have interest rate caps on at least some installment loans to protect residents from high-cost predatory lending.      The groups urged the OCC to abandon its proposal in its comment letter to the OCC.

 But some groups are even being blocked, or Brooks-ed, from commenting through Regulation.gov. Watch this site.

 On his conflicts of interest, Inner City Press asked - and then requested under FOIA - what are the "other tech firms" as to which Brooks is acknowledging a conflict.

   The OCC wrote to Inner City Press, faux apologizing for withholding information it has requested about Otting until after he had left the agency. Inner City Press immediately wrote back requesting a copy of Brooks' ethics letter and list of companies as to which even he acknowledges a conflict of interest.

  On June 18, that simple request was denied and so a FOIA request was filed, see below.

  And now more than a month later on July 22 the OCC has provide to Inner City Press under FOIA a copy of the ethics memo that Brooks is recused on: Amazon (minus AWS), Avant, Aventas, Merrill Lynch, CoinBase, EarnUp, Spring Labs, TextIQ - and Citibank N.A. residential mortgage business." We'll have more on this.

  From Inner City Press' FOIA request: "This is a request under FOIA on behalf of Inner City Press and in my personal capacity for all records concerning conflicts of interest or the appearance of conflict of interest by Acting Comptroller Brian Brooks, including but not limited to the Ethics letter Inner City Press requested from the OCC, below, and Coinbase, Avant, OneWest and any other firm.  Inner City Press in responding to a request by OCC to "close out" a FOIA request still not completed asked "I do have an OCC public information / transparency question - for the Acting Comptroller's ethics filing - can it be sent to me at Matthew.Lee@innercitypress.com? To identify it: "Brooks has submitted a letter through the agency's ethics office outlining companies he'll steer clear of because of potential conflicts of interest, including Amazon.com Inc., Bank of America Corp.'s Merrill Lynch unit, Coinbase and a number of other tech firms he's worked with." What are those companies? Thanks, -Matthew Lee, Inner City Press"  Days later and minutes ago Inner City Press received this: Good Morning Mr. Lee....  I don't know the answer to the question you asked.  You should file a FOIA request for the records you seek regarding the Acting Comptroller. " This is that request, on which expedited treatment should be granted - such disclosures are among the very purposes of FOIA."  Watch this site.

   Amid all this, Fair Finance Watch and Inner City Press / Community on the Move have launched a new project. And so far, Brooks' national banks have been among the worst. Watch this site.

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