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FEDERAL COURT / S Bronx, Oct 28 – Whether or not the U.S. Community Reinvestment Act will be again enforced until the new Administration and its regulators is an open question. And not only the proposed acquisition of Investors Bank by Citizens Bank NA but also Stock Yards - Commonwealth will be litmus tests. FRB's Oct 27, 2021 letter here.

On October 2, after filing with the FDIC, Inner City Press filed with the Federal Reserve:

"This is a timely first comment opposing and requesting an extension of the FRB's public comment period on the Applications by Stock Yards Bancorp to acquire Commonwealth Bancshares, Inc., and thereby indirectly acquire Commonwealth Bank and Trust Company, both of Louisville, Kentucky     

 The applicant Stock Yard Bank is getting worse.  In Kentucky in 2020 it made 1431 home loans to whites and only 39 to African Americans (while denying 18application from African Americans, and only 188 from whites - down from 250 in 2019).    Commonwealth Bank & Trust in Kentucky in 2020 made more loans that its putative acquirer, but was also disparate: it made 3358 home loans to whites and 156 to African Americans (while denying 63 application from African Americans, and 459 from whites).  There is no public benefit to this proposal.    

FFW and Inner City Press have been deeply concerned about the rush by the FRB's penchant to rubberstamp mergers by redliners, particularly during the pandemic - including starting comment periods even before applications are filed and/or publicly available. We have just filed a FOIA request."

Now in late October, Inner City Press is publishing these questions to Stock Yard asked by the Federal Reserve on October 27, full letter here: "October 27, 2021 Mr. Nathan Berger Frost Brown Todd, LLC 400 West Market Street, 32nd Floor Louisville, Kentucky 40202-3363 Dear Mr. Berger:

This letter refers to application submitted by Stock Yards Bancorp, Inc. (“Stock Yards” or  “Applicant”), the parent of state nonmember bank, Stock Yards Bank & Trust Company (“Stock  Yards Bank”), to acquire Commonwealth Bancshares, Inc. (“Commonwealth”), a bank holding  company, and its state nonmember bank subsidiary, Commonwealth Bank & Trust Company (“Commonwealth Bank”), all of Louisville, Kentucky, pursuant to section 3 of the Bank Holding Company Act of 1956, as amended. Please provide a complete, detailed response to each of the  following items. Supporting documentation, as appropriate, should be provided.  1. Please confirm whether the merger will result in new products or services at the  resulting bank that are not currently offered by Stock Yard Bank or Commonwealth  Bank. If so, please provide: a. A description of the new products and services that Stock Yards Bank expects  to offer following the merger.  b. A description of how Stock Yards Bank plans to adjust its consumer compliance  program to support these new products and services. c. A description of how Stock Yards Bank plans to adjust its Community  Reinvestment Act program to support these new products and services.

2. Describe any changes to the consumer compliance program at Stock Yards Bank as a  result of the merger, including staffing. Discuss the skills and experience of the Stock  Yards Bank consumer compliance management team and provide an organizational  chart reflecting the consumer compliance function at the pro forma organization.

3. Applicant’s response to Question 19(d) indicates that the merger will result in an  expansion of Stock Yards Bank’s assessment areas and products and services. Discuss  whether the Applicant expects that staff responsible for managing the CRA program  will change following the merger. Mr. Nathan Berger October 27, 2021 Page 2 4. Applicant’s response to Question 20(c) of the Y-3 application shows that the Applicant  plans on closing or consolidating six branches following the merger. a. Indicate whether each branch listed in the response to Question 20(c) is in a  majority-minority census tract. b. Discuss how Stock Yards Bank plans to mitigate the impact of any branches to  be closed in LMI and/or majority-minority communities. 5

. Please provide a list of organizations and community groups, if any, with which Stock  Yards Bank engaged since 2019 to help reach African American borrowers in Kentucky. In your response, please provide detailed information about the partnerships  that Stock Yards Bank engaged in with these organizations and community groups since 2019.

6. Please provide information about Stock Yards Bank’s efforts to reach African  American borrowers in Kentucky, including specialized products and marketing  campaigns, since 2019.

7. Please provide a list of organizations and community groups, if any, with which Commonwealth Bank engaged since 2019 to help reach African American borrowers  in Kentucky. In your response, please provide detailed information about the  partnerships that Commonwealth Bank engaged in with these organizations and  community groups since 2019."

Meanwhile, Investors Bank is one of the most disparate banks in New York State, where in 2020 it made only three mortgage loans to African Americans, while denying fully seven applications from African Americans. By contrast, it made 164 loans to whites while denying only 76 applications from whites.

  Inner City Press raised the 2019 disparities to the FDIC - and on July 30 was contacted by the FDIC that it imposed rare conditions on Investors. Letter here. This has now been raised on Citizens' applications   

Citizens cannot, as of now, be allowed to acquire this hot mess.  As noted:  The applicant Citizens in 2020 in New York State based on its disparate marketing made 7183 mortgage loans to whites, with 3116 denials to whites -- while making only 323 loans to African Americans, with more than that in denials: 336.  

  Here's some of Investors' 2020 HMDA data:  Investors Bank in 2020 in New York State based on its disparate marketing made 164 mortgage loans to whites, with 76 denials to whites -- while making only THREE loans to African Americans, with SEVEN denials. This is far out of keeping with the demographics, and other lenders, in NYS - this is outrageous.

This is a pattern. Investors Bank in 2020 in New Jersey based on its disparate marketing made 1580 mortgage loans to whites, with 281 denials to whites -- while making only 64 loans to African Americans, with 28 denials. This is far out of keeping with the demographics, and other lenders, in New Jersey. The comment period should be extended; evidentiary hearings should be held; and on the current record, the application should not be approved."

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