| TD Bank Bid to
Close 51 Branches Opposed by
Fair Finance Watch OCC Says 12
Are LMI
by
Matthew Russell Lee, Patreon Book
Substack
SOUTH
BRONX/SDNY, Dec 1 –
Amid the FDIC's bid to
eliminate public notice of and
public comment on branch
applications, TD Bank -
Toronto Dominion - is moving
to close 51 more branches, on
top of 36 earlier closed.
On
November 10 Fair Finance Watch
filed the below opposition to
the Office of the Comptroller
of the Currency.
On December 1,
the OCC wrote back: "Mr.
Lee: I
am responding to your email
below. Please see the
attached public comment
acknowledgment letter. The OCC
notes that twelve (12) out of
the fifty-two (52) branches
mentioned below: 20th & K
(343727); Myrtle Beach Main
(343728); North Conway
(343729); Lowell-Central
Street (343731); Willimansett
(343732); Silver Spring City
Place (343742); Little River
Turnpike (343743); Marion
(343746); Lincoln Plaza
(343748); Four Seasons
(343749); Miami Gardens
Northeast Branch (343754); and
Pittsfield (343785) are
located in LMI areas, and that
you have requested a hearing.
With respect to these branch
closings, Licensing has
forwarded your comment to the
OCC’s Community Affairs
Department for review."
Now what?
Filed with
OCC on November 10:
Fair Finance
Watch has long been concerned
about TD Bank. Fair
Finance Watch has reviewed the
just-released 2024 Home
Mortgage Disclosure Act data
of TD Bank NA not reviewed in
any Community Reinvestment Act
performance evaluation.
Nationwide, TD Bank in 2024
denied 3837 applications from
African Americans while making
fewer, only 3169 loans - while
it made fully 44,281 loans to
whites and denied only 20,376
applications. This is
disparate, and it is systemic.
In state after state, TD Bank
for African Americans has
(many) more denials than
originations, while the
opposite is true for white
borrows. The pattern is
striking, starting with New
York:
In New York, TD Bank in 2024
denied 483 applications from
African Americans while making
fewer, only 297 loans - while
it made fully 2915 loans to
whites and denied only 1599
applications. This is
disparate.
Again, the only enforcement
mechanism of CRA is its
consideration on applications
for deposit facilities:
branches. Here TD Bank is
closing yet 51 more
branches. A hearing is
requested, timely opposition
made. For identification: TD
Bank is closing more branches
throughout this year and next.
The bank is closing more
branches at the end of 2025
and into 2026 after closing 38
branches earlier in 2025....
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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