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CRA Protest to Gaming MVB Bank Bid On Hemp Lender West Town Bank Yields Questions

By Matthew Russell Lee, Patreon MVB File
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SOUTH BRONX NY, Nov 17 – Amid the focus on big mergers like Bank of Montreal Harris - BNP Paribas and the stalled Flagstar / NYCB, there are other also dubious smaller merger proposals.

Fair Finance Watch is on the lookout, with Inner City Press on the FOIA, and filed this:

Dear Chair Powell, Secretary Misback and others in the FRS:    This is a request for a full copy of, and a timely first comment on, the Applications of MVB Financial Corp., Fairmont, West Virginia; to acquire Integrated Financial Holdings, Inc., Raleigh, North Carolina, and thereby indirectly acquire West Town Bank & Trust, North Riverside, Illinois, and acquire voting shares of West Town Payments, LLC, Raleigh, North Carolina, "and more." 

Fair Finance Watch has been reviewing West Town Bank including its 2021 HMDA data not taken into account in any CRA exam and finds it troubling. FFW in looking into MVB Bank find its offers of banking for gaming, but for CRA questions, not even an email address, only a snail mail address. This is not a best practice, far from it. 

   In terms of HMDA data, in 2021, West Town Bank made 319 mortgage loans to whites with seven denials. Meanwhile to African Americans it made only TWENTY FIVE loans, while denying five applications. A referral should be made to the DOJ for fair lending violations.     MVB, proposing to buy West Town Bank including its hemp lending, is engaged in gaming lending, fintechs - but has not put its CRA file online or even available by emailing."

  First after the filing, MVB provided Fair Finance Watch with what it calls its 271-page CRA file (for some reason, only "as of April 2022") which we've put on DocumentCloud here to make it public as all CRA files should be.

Now on November 17, Fed questions including

"This correspondence relates to the application filed by MVB Financial Corp. (“MVB”), Fairmont, West Virginia, to acquire Integrated Financial Holdings, Inc. (“IFHI”), Raleigh, North Carolina, and thereby indirectly acquire West Town Bank & Trust (“West Town Bank”), North Riverside, Illinois, pursuant to sections 3(a)(3) and 3(a)(5) of the Bank Holding Company (“BHC”) Act, and to indirectly acquire voting shares of West Town Payments, LLC, Raleigh, North Carolina, pursuant to sections 4(c)(8) and 4(j) of the BHC Act. Based on Federal Reserve staff’s review of the current record, the following additional information is requested. Please provide responses to the following items, including those in the Confidential Annex. Supporting documentation should be provided as appropriate: 1. Provide a revised page 1 of the FR Y-3 Application to Become a Bank Holding Company and/or Acquire an Additional Bank or Bank Holding Company (“FR Y-3”) form to state that MVB’s application is submitted pursuant to both sections 3(a)(3) and 3(a)(5) of the BHC Act. 2. In response to Question 20 of the FR Y-3, MVB represents, “No existing branches will be closed or consolidated as a result of the Proposed Transaction.” However, Exhibit A of the Agreement and Plan of Merger of West Town Bank with and into MVB Bank does not include West Town Bank’s North Riverside, Illinois branch in the list of surviving bank branch locations. Confirm, if such is the case, that MVB does not intend to close any existing branches of either West Town Bank or MVB Bank, Inc. (“MVB Bank”), Fairmont, West Virginia, in connection with the proposed transaction. 3. MVB represents that the following IFHI’s wholly-owned nonbank subsidiaries are anticipated to be sold or dissolved prior to consummation of the proposed transaction: (1) SBA Loan Documentation Services, LLC, (2) West Town Insurance Agency, Inc., (3) Glenwood Structured Finance, LLC, and (4) Patriarch, LLC. For each subsidiary: a. Provide a status update on the dissolution or sale of the subsidiary; b. For any subsidiary that has not yet been dissolved or sold, provide an estimated date by which the dissolution or sale is expected to be completed; and c. Confirm, if such is the case, that the subsidiary would not be acquired or operated by MVB following consummation of the proposed transaction. 

  4. Confirm MVB intends to maintain an ownership interest in VeriLeaf, Inc. and Dogwood State Bank, following consummation of the proposed transaction. 5. The FR Y-3 and Agreement and Plan of Merger and Reorganization dated as of August  12, 2022, between IFHI and MVB indicate that IFHI provides services to marijuana- related businesses (“MRBs”). Indicate whether MVB anticipates continuing to provide  services to MRB customers following consummation of the proposed transaction. If not, describe how and when the combined organization would terminate that business line. If yes, describe the nature and scope of IFHI’s current activities with MRB customers and the combined organization’s anticipated activities with MRB customers. The response should summarize product or services offerings and the size and scope of the business line. In addition, the response should describe the criteria or system for identifying and classifying MRB customers and the combined organization’s definition of MRB customer, if any. 6. Discuss the due diligence process MVB undertook relating to IFHI’s servicing of MRB customers. In addition, summarize any due diligence findings relating to that business line, including whether the due diligence identified any risks, weaknesses, or concerns at IFHI and how the combined organization intends to address them following consummation of the proposed transaction. 7. If applicable, provide an overview of the laws, regulations, orders, or other requirements or guidance that impact IFHI’s and the combined organization’s provision of services to MRB customers. The response should: a. Discuss how the combined organization would manage and mitigate risks associated with servicing MRB customers and ensure compliance with any statutes, regulations, or guidance in each jurisdiction in which the combined organization would service MRB customers. b. Indicate how the combined organization would monitor potential changes to applicable laws concerning providing services to MRB customers in the future. c. Discuss existing policies and procedures as well as any contemplated changes at the combined organization to ensure compliance with applicable law and the 2014 Financial Crime Enforcement Network guidance titled “BSA Expectations Regarding Marijuana-Related Businesses.”  8. Discuss MVB and/or MVB Bank’s record of compliance with the West Virginia Community Reinvestment Act, W. Va. Code §§ 31A-8B-1 to 5, including the date of MVB and/or MVB Bank’s most recent evaluation and rating, as applicable. 9. In the FR Y-3, MVB states that the proposed transaction would create benefits for clients of West Town Bank by enabling them to take advantage of a larger branch and ATM network. Describe in greater detail how the clients of West Town Bank, whose only branch is located in Illinois, would benefit from access to the MVB Bank’s branch and ATM network, which is located in West Virginia and Virginia. 10. Provide a copy of the most recent version of the CRA Strategic Plan that is expected to become effective in January 2023.  NONCONFIDENTIAL // EXTERNAL  11. On page 21 of the FR Y-3, MVB states that MVB Bank is in the process of reviewing the products and services of West Town Bank. Indicate when that review is expected to be completed. If already completed, explain whether any products and services offered by either MVB Bank or West Town Bank would be discontinued after consummation of the proposed transaction. Additionally, discuss whether there would be any changes to the terms or provision of the products and services currently provided, including fees. 12. Confirm whether the consumer compliance program of the merged bank would be MVB Bank’s current program. Describe any modifications to the consumer compliance risk management program that are planned as a result of the proposed transaction. 13. Discuss any enhancements that would be made to MVB Bank’s consumer compliance risk management system to accommodate the proposed additional and expanded activities described in the strategic business plan in Confidential Exhibit E." Full letter on Patreon here.

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