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by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX / SDNY COURT, Oct 31 –    The Community Reinvestment Act directs bank regulators to consider banks' records of lending in poor neighborhoods when they apply to expand with mergers or, right in the statute, branches ("deposit facilities").  

But now the Federal Deposit Insurance Corporation and OCC are quietly moving to eliminate public notice of, and public comment on, banks' branch applications. While Inner City Press has Freedom of Information Act requests pending, Fair Finance Watch on August 30 commented to the FDIC, on the proposed change - and on sample current branch applications pending. On October 6, FFW commented on the OCC's proposal, still hidden on Regulations dog gov.

On August 21, in part to forestall the Federal Reserve using the same twisted logic of "few comments so let's eliminate public notice," Fair Finance Watch filed a branch comment with the Federal Reserve Bank of St. Louis on the pending application by Arkansas-based First Security Bank to open a branch at 4001 Rodney Parham Road in Little Rock, noting that First Security Bank in Arkansas in 2024 it made 1030 mortgage loans to whites and denied only 120 applications, 1 to 9. For African Americans, only 17 loans and fully 10 denials: approximately 1 to 1.7.

  On September 11 First Security Bank vaguely responded, pointing to a 2023 CRA Performance Evaluation 1) that did not consider the 2024 HMDA data. 2) that PE states, inter alia, Distribution on loans in non-MSA Arkansas is "Poor" (id. at 10); on the Investment Test in Jonesboro, Hot Springs and Fort Smith is "Below" (id. at 13); in the same Jonesboro and Hot Springs communities, accessibility of delivery systems are "Below." Community Development Services in Jonesboro, also "Below."    Fair Finance Watch reiterated its request for hearings, and denial.

On September 24 the Fed informed First Security Bank that the application is being transferred to the Board in DC and the time extended - but only into October.

On October 6, the Fed asked more questions including:

In your response to the commenter on September 11, 2025 (“Response”), you state that FSB has implemented a system to deliver marketing and outreach to assessment areas with majority-minority census tracts, and that this system  includes creating focus groups to increase advertising strategies toward majority- minority census tracts and minority individuals, conducting consumer sentiment  surveys in African American populations, and developing a strategic media plan. The Response also states that this program includes financial education components designed to increase homeownership, quarterly workshops held at establishments located within majority-minority census tracts in Little Rock, Arkansas, and monthly broadcasts on the number one radio show reaching African Americans in Little Rock, Arkansas. Further, the Response states that FSB has also established programs to address unbanked and underbanked consumers, provide financial education, and increase rates in homeownership. a. Please indicate whether any of the above systems and programs were implemented after the CRA Performance Evaluation of FSB in January 2023. b. If any new CRA-related activities, services or programs have been implemented since the last CRA Performance Evaluation, describe such activities, services or programs.

But when the Fed approved it on October 31 it was pure boilerplate, with even the issues above covered up. Meanwhile, FOIA delays past the end of comment periods, raised by FFW to the Fed in the EGRPRA hearing on October 31 continue...

Watch this site.

See also, Inner City Press' op-ed in the American Banker here

There will be more.   

   This proposal to eliminate public notice and comment on branch applications must be withdrawn - or sued.

Watch this site.

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