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by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX/SDNY, Nov 13 – Amid the FDIC's bid to eliminate public notice of and public comment on branch applications, Bank of America is moving to close eight more branches, including in low and moderate income areas.

  This comes at Bank of America, beyond its lending disparities and negiglence with First Brands, has been sued in the U.S. District Court for the Southern District of New York for having enabled Jeffrey Epstein. Inner City Press has covered that case and others against BofA.

  On November 12 Fair Finance Watch filed opposition to the Office of the Comptroller of the Currency:

Dear Jason Almonte, Director for Large Bank Licensing and to Whom it May Concern at the OCC:

   On behalf of Fair Finance Watch and in my personal capacity this is a timely comment opposing the recent branch closing applications by Bank of America, National Association. These comments in opposition are timely.

  Consider as simply one example B of A's proposed closing of a branch in a moderate income census tract, more than 80% "minority," in Georgia, filed on November 6 (this comment, and request for public hearings, is timely)

  For identification, from the OCC's website:
Gainesville Main    402 WASHINGTON STREET         GAINESVILLE    GA    30501    Hall    099860A

Here from the FFIEC are the demographics:

Address: 402 Washington St SE, Gainesville, Georgia, 30501
MSA-State-County-Tract: 23580-13-139-0008.00
Tract Income Level
Moderate
Underserved or Distressed Tract
No
2025 FFIEC Estimated MSA/MD/non-MSA/MD Median Family Income
$102,700
2025 Estimated Tract Median Family Income
$61,014
2020 Tract Median Family Income
$44,050
Tract Median Family Income %
59.41
Tract Population
3482
Tract Minority %
82.80
Tract Minority Population
2883
Owner-Occupied Units
450
1- to 4- Family Units
1106

  Here is Bank of America's disparate lending record in Georgia in 2024:

in 2024 denied 1525 mortgage applications from African Americans while making fewer, only 771 loans - while it made fully 1960 loans to whites and denied only 1674 applications. This is disparate.

Nationwide in 2024 Bank of America denied 11,467 mortgage applications from African Americans while making fewer, only 6855 loans - while it made fully 54,061 loans to whites and denied only 45,570 applications. This is disparate, and it is systemic.

   Fair Finance Watch is opposing Bank of America's branch closing including but not limited to these, on the OCC's website:

 FFW notes in the FDIC's pending proposal RIN 3064-AG10: "the FDIC has received a limited number of public comments in response to subpart C applications.... Therefore, the FDIC is proposing to eliminate the public notice and related public comment period from subpart C and to make conforming changes to subpart A of 12 CFR part 303 of the FDIC Rules."  

See, e.g., Sept 10, 2025: https://www.americanbanker.com/opinion/the-fdic-is-undercutting-a-key-element-of-the-cra  

 But now the Federal regulator(s) blithely propose(s) to eliminate public notice and public comment on banks' proposals to expand.  The above-quoted reasoning is that few comments are filed. So, that is now changing.

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