| Citizens
Bank Thumbs Nose At CRA On Investors Bank
FDIC Conditions Litmus Test Failing
By Matthew
Russell Lee, Patreon Story Order
BBC
- Guardian
UK - Honduras
- ESPN
FEDERAL COURT / S
Bronx, Oct 22 – 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 the proposed
acquisition of Investors Bank
by Citizens Bank will be a
litmus test, one that both
Citizens and the regulators
are failing.
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 was raised on Citizens'
applications: "be aware that
based on Fair Finance Watch's
comments to the FDIC about
Investors, it recently imposed
a condition on Investors.
Investors has yet to
meaningfully implement the
required improvements; this
application should not be
approved, much less at this
time. The
FDIC wrote:
"Matthew
Lee, Esquire Executive
Director Inner City Press/Fair
Finance Watch Dear Mr.
Lee: We are writing to inform
you that the FDIC approved
Investors Bank’s application
to acquire eight branches from
Berkshire Bank. As part of the
application review process, we
investigated the issues you
raised in your e-mail dated
January 19, 2019... The Bank
will develop and Board approve
an Action Plan within 60 days
of the effective date of
this Order to ensure that its
home mortgage lending
adequately addresses the
credit needs of all segments
of its market areas. The
Action Plan should
include, at a minimum, the
following: a. The Bank will
regularly monitor application
and origination activity of
home mortgage loans in
majority-minority census
tracts and from Blacks
throughout the Bank’s
assessment areas. b. The
Bank will ensure marketing and
outreach efforts are inclusive
of all communities,
including minority communities
within all the Bank’s
assessment areas. The
marketing and outreach efforts
should focus on home mortgage
product awareness.
Marketing activities should
use materials and media that
reflect the racial and
ethnic composition of
the targeted communities. The
Bank should also have
specific advertising and
outreach goals, and the
results of these efforts
should be documented,
monitored, and evaluated for
effectiveness. 5. Upon
Board approval of this Order,
the Bank will provide a copy
of the signed Order to
the FDIC's New York Regional
Office within 30 days.
6. Upon Board approval of such
Action Plan, the Bank will
provide a copy of the
Plan to the FDIC’s New
York Regional Office. 7. The
Bank will provide the FDIC’s
New York Regional Office with
quarterly updates
detailing its progress in
meeting the goals listed in
the Action Plan."
But in
response to this, Citizens
only said dismissively that
the record of the acquiree
doesn't matter. So they could
buy OneCoin? It is major law
firm making this argument. It
is an embarrassment. And the
Federal Reserve's question
letter of October 22 (on
Patreon here) does not address
it, and Citizens' law firm
late provide its "answer" and
two responses to the Fed.
This application
should be denied.
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.
Watch this site.
***
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