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By Matthew Russell Lee, Patreon Maxwell Book
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SDNY / SOUTH BRONX, August 6 – Seemingly oblivious to US regulators stated desire to tighten up their merger review rules, specifically on fair lending, Toronto Dominion on February 28 announced a $13.4 billion proposal to buy First Horizon.

 Fair Finance Watch has been concerned by TD Bank's lending disparities for some time. Nationwide in 2020, TD Bank denied almost as many applications from African Americans (833) as it made in mortgage loans to African Americans (853). It was far more generous with white borrowers: 23,469 loans made, with only 9009 denials. 

 Fair Finance Watch immediately online noted that in New York State in 2020, TD Bank was even worse. It denied more mortgage applications from African Americans (255) that it made loans to African Americans in NYC (198). Again, TD Bank was far more generous with white borrowers in NYS: 3,558 loans made, with only 1714 denials. 

 Fair Finance Watch said: but just as the Federal Reserve begrudgingly is holding a public hearing on US Bancorp - MUFG / Union Bank, on March 8, there is even more reason to hold multiple hearings on a large and disparate Canadian bank buying Horizon.

Now even more so, as the arrogance of Toronto Dominion is on full display: "1. Toronto-Dominion Bank's $1.3 billion move for Cowen underscores that the Canadian lender wants more of the US investment-banking pie. Riaz Ahmed, TD Securities' group head for wholesale banking said one pressing question when determining an acquisition was finding a target with "complementary skills."   "It's difficult to time things exactly to where the markets are. When you have a long view of the business, then really what you're looking for is — can you find a party that has complementary skills, and then you worry less about the timing," Ahmed said. We'll have more on this.

From the regulators: "The Federal Reserve Board (Board) and the Office of the Comptroller of the Currency (OCC) today announced a joint public meeting on the proposal by The Toronto-Dominion Bank, Toronto, Ontario, Canada, to acquire First Horizon Corporation, Memphis, Tennessee. The purpose of the public meeting is to collect information from a wide range of stakeholders as the agencies evaluate the proposed applications. By law, the agencies are required to evaluate: the convenience and needs of the communities to be served by the combined organization; the insured depository institutions’ performance under the Community Reinvestment Act; competition in the relevant markets; the effects of the proposal on the stability of the U.S. banking or financial system; the financial and managerial resources and future prospects of the companies and banks involved in the proposal; and the effectiveness of the companies and banks in combatting money laundering activities. The public meeting will be held virtually on August 18, 2022, at 9:00 a.m. EDT. Members of the public seeking to present oral comments must register by 12:00 p.m. EDT on July 28, 2022 through the online registration web page, which will be updated with registration details by June 8, 2022."

 But as of July 27, the Fed's link is to an OCC website which does not provide information about registering for the public meeting, only commenting. Fair Finance Watch timely used the box to register, and asked for confirmation. So far, this:

"Your comment was submitted successfully! Comment Tracking Number: l63-3wqi-yw6q  Your comment has been sent for review. This process is dependent on agency public submission policies/procedures and processing times. Once the agency has posted your comment, you may view it on Regulations.gov using your Comment Tracking Number.  Agency: COMPTROLLER OF THE CURRENCY (OCC) Document Type: Other Title: Merger Application - TD Bank NA - First Horizon Bank (2022-LB-Combination-326132) Document ID: OCC-2022-0010-0001  Comment: This is a timely registration to testify at the Federal Reserve's and OCC's public hearing on the TD - First Horizon proposal. The link on the Fed's web page led here, which there this no clear place to register. But this is a timely request, please immediately confirm receipt."

  Why can the Fed not do its own work? Why can the OCC not be clear? Or are these conscious choices? Watch this site.

Inner City Press will be inquiring under the Freedom of Information Act. Watch this site.  

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