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by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX/Federal Court, Dec 22  – A proposed acquisition by Ohio-based Park National Bank of First Citizens of Tennessee after Park National's redlining settlement, and deteriorating record since, have given risen to a challenge under the Community Reinvestment Act.

  On November 15 Fair Finance Watch, reviewing Home Mortgage Disclosure Act data of Park National for 2024, filed a CRA challenge to the merger with the Office of the Comptroller of the Currency, below.

After five weeks of no transparency - no questions asked, nothing - on December 22 the public hearing request was denied and the same day, a cursory approval without any explanation, much less rebuttal, by Debra M. Burke, Director
Chartering, Organization, and Structure. Ultimately, this is Comptroller Gould's race to the bottom - he bragged about approving Erebor, then five weeks later extended OCC's time to respond to a timely FOIA request. Public cut out.

  Beyond the lending disparities preliminarily identified below, Park National is one of the few banks with a redlining settlement. See, United States v. Park National Bank (S.D. Ohio), 2:23-cv-00822-EAS-CM    It also has troubling consumer complaints against it. On the current record, the application to buy First Citizens must be denied.  

  In North Carolina in 2024, The Park National Bank denied four mortgage applications from African Americans while making fewer, only two loans - while it made fully 71 loans to whites and denied only 11 applications. This is disparate.

In South Carolina in 2024, The Park National Bank made 166 mortgage loans to whites, with only 49 denials, while making only 14 loans to African Americans with fully 10 denials. This is disparate.  

Even in its home state of Ohio in 2024 The Park National Bank made 2648 mortgage loans to whites, with only 721 denials, while making only 218 loans to African Americans with fully 55 denials. This is disparate.

And see, e.g., American Banker, Sept 10, 2025, "The FDIC is taking the 'community' out of CRA enforcement," by Matthew R. Lee, here.

 And now the OCC is following suit in cutting out the public. The above-quoted reasoning is that few comments are filed. So, that is now changing.

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