| Merger Application to FDIC
by Misnamed Bank of Hope Is Challenged by Fair
Finance Watch
by
Matthew Russell Lee, Patreon Book
Substack
FEDERAL
COURT,
May 14 – How automatic
do banks now think merger
approvals are? How automatic
does the FDIC make them? There
is a new test case, before the
FDIC, to which Fair Finance
Watch has filed:
a timely first comment opposing and
requesting an extension of the FDIC's public
comment period on the Application by Bank of
Hope to acquire SMBC Manubank.
The application is on the FDIC's website where
a public comment period running through March
27 . These comment, and supplements to come,
are timely.
Fair Finance Watch, which
commented to the FDIC that its proposal to
eliminate public notice of branch applications
violates the CRA, noting the FDIC's rationale
that it receives few public comments, hereby
timely informs the FDIC that it is troubled by
Bank of Hope's lending record and is
requesting public hearings and denial of this
application.
ty, and even its non-Asian lending is
skewed. In 2024 Bank of Hope
in New York made 12 mortgage loans to whites -
but NONE to African Americans. Meanwhile it
mad 315 loans to Asians.
Nationwide in 2024 Bank of Hope
made 33 mortgage loans to whites, none to
African Americans, and 533 loans to
Asians. More than half
of Bank of Hope's loans to Asians nationwide
were in New York, versus one third of its
loans to whites - and nowhere did it lend to
African Americans. Can this comply with CRA
and the fair lending laws?
Bank of Hope has branches in New York /
NJ, including Manhattan 2.32 miles 16 W.
32nd St., 1st floor. New York, NY 10001
212-279-2790 Get Directions Woodside 7.02
miles 50-15 Roosevelt Ave., Woodside, NY 11377
718-335-2000 Get Directions ATM (Open from 8am
- 8pm) Today 9:00 am - 5:00 pm Palisades Park
9.02 miles 303 Broad Ave., Palisades Park, NJ
07650 201-582-1100 Get Directions ATM (24/7)
Today 9:00 am - 5:00 pm Fort Lee 9.44 miles
172 Main St., 1st floor, Fort Lee, NJ 07024
201-242-7462 Get Directions ATM (24/7) Today
9:00 am - 5:00 pm Englewood Cliffs 11.61 miles
474 Sylvan Ave., Englewood Cliffs, NJ 07632
201-500-9943 Get Directions ATM (24/7) Today
9:00 am - 5:00 pm Flushing-Union 12.04 miles
138-02 Northern Blvd., Flushing, NY 11354
718-886-6611 Get Directions ATM (24/7) Today
9:00 am - 5:00 pm Flushing-Crocheron 14.19
miles 162-05 Crocheron Ave., Flushing, NY
11358 718-888-0020 Get Directions ATM (Open
from 6am - 6pm) Today 9:00 am - 5:00 pm
Bayside 16.17 miles 209-07 Northern Blvd.,
Bayside, NY 11361 718-428-1606 Get Directions
ATM (24/7) Today 9:00 am - 5:00 pm Great Neck
19.13 miles 485 Great Neck Rd. STE 16 Great
Neck, NY 11021
516-466-4160 Here is a
just-settled ADA complaint, see for the record
MARQUISE BAILEY, Plaintiff, vs. BANK OF HOPE;
and DOES 1 to 10...
FFW notes in the FDIC's 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
The Community Reinvestment Act specifies
that "the appropriate Federal financial
supervisory agency shall (1) assess the
institution's record of meeting the credit
needs of its entire community, including low-
and moderate-income neighborhoods, consistent
with the safe and sound operation of such
institution; and (2) take such record into
account in its evaluation of an application
for a deposit facility by such
institution." That is,
the only enforcement mechanism of CRA is its
consideration on applications for deposit
facilities: branches, and proposed mergers
like this one.
But now the FDIC has moved 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. We
note that the FDIC seems to have changed its
website so the public cannot click and ask for
a copy of a pending application. Another move
away from transparency and
accountability. The comment period
should be extended; evidentiary hearings
should be held; and on the current record, the
application should not be
approved.
Very Truly
Yours, /s/
Matthew Lee, Esq. Executive Director
Inner City Press/Fair Finance Watch
There will be more coming.
***
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