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

By Matthew Russell Lee, Patreon MVB File
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SOUTH BRONX NY, March 23 – 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.

On March 23, 2023 - with no reference to SVB or Signature, Fed questions including

"MVB has agreed to sell its Chartwell Compliance subsidiary to the consulting firm, Ankura. a. Update the pro forma organizational chart provided in Confidential Exhibit A of the Additional Information Response, dated February 7, 2023, to reflect the sale of this subsidiary. b. Discuss whether MVB will retain any personnel associated with its Chartwell Compliance subsidiary following consummation of its sale to Ankura. c. Describe any anticipated changes to MVB’s compliance function, as a result of the proposed sale of Chartwell Compliance. d. Provide the date the transaction is expected to close. 2. Provide an update on the status of IFHI’s sale of and the dissolution of West Town Insurance Agency, Inc. Confirm whether any other IFHI subsidiaries have been or are expected to be sold or disposed of prior to consummation of the proposed transaction. If yes, identify each such subsidiary and provide the status of the sale or disposition. 3. In addition to data conversion, discuss proposed integration steps to incorporate West Town Bank & Trust with and into MVB Bank, Inc. (“MVB Bank”), Fairmont, West Virginia. INTERNAL FR/OFFICIAL USE // SECURE EXTERNAL 4. 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. The additional information submitted on November 30, 2022, stated that that review was still ongoing and was expected to be completed in early 2023. Assuming that analysis is now 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.

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