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FEDERAL COURT / S Bronx, Nov 20 – 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 Home BancShares / Centennial Bank - Happy Bancshares will be litmus tests.

On November 20 Inner City Press filed with the Federal Reserve:

"This is a request for a full copy of, and a timely first comment on, the Applications of South State Corporation to merge with Home BancShares, Inc. to merge with Happy Bancshares, Inc., and thus indirectly acquire Happy State Bank. Fair Finance Watch has been tracking Home BancShares' Centennial Bank, including but not only because it has a branch in New York.

The applicant's Centennial in 2020 in Alabama based on its disparate marketing made 46 mortgage loans to whites, with 19 denials to whites -- while making only NO loans to African Americans. This is far out of keeping with the demographics, and other lenders, in Alabama - this is outrageous. This application should be denied, and a referral made to the Justice Department, as the Fed did far too late on Cadence Bank, whose lesser disparities Inner City Press similarly raised to the Fed.

This is a pattern. Centennial Bank in 2020 in Arkansas based on its disparate marketing made 1943 mortgage loans to whites, with 282 denials to whites -- while making only 113 loans to African Americans, with 37 denials. This is out of keeping with the demographics, and other lenders, in Arkansas, in the state Home BancShares' Centennial Bank presumably performs best.   South State Bank NA in 2020 in New York based on its disparate marketing made a mortgage loan to a white application, and none to African Americans. 

Centenntial Bank in 2020 in Florida based on its disparate marketing made 1591 mortgage loans to whites, with 256 denials to whites -- while making only 52 loans to African Americans, with 16 denials. This is out of keeping with the demographics, and other lenders, in Florida. What could Home BancShares' Centennial be expected to do in Texas?   

FFW and Inner City Press have been deeply concerned about the rush by the Federal Reserve's to rubber-stamp mergers by redliners. This has been killing the Community Reinvestment Act and we timely request public hearings. We have already submitted a FOIA request for all withheld portions of the applications / portions for which confidential treatment has been requested, and for communications. The comment period should be extended; evidentiary hearings should be held; and on the current record, the application should not be approved.

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."   

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