| Link Bank In
Bid To Buy Partners Bancorp On the Ocean
Rebound Misrepresented to FDIC
By Matthew
Russell Lee, Patreon
SOUTH BRONX, July
22 – Pennsylvania,
Delaware and Virginia are
portrayed as diverse and ever
progressive places. But their
banks, not so much.
Consider
for example the proposed
merger on the rebound between
New York-based Link Bank and
Partners Bancorp, which
recently broke off its
proposed deal with OceanFirst.
Inner City Press
and Fair Finance Watch have
long exposed redlining - and
in this vein, on May 6 they
filed a Community Reinvestment
Act challenge with the Federal
Reserve:
This is a
timely first comment on the
Applications of LINKBANCORP,
Inc. Camphill, Pennsylvania;
to acquire Partners Bancorp,
Salisbury, Maryland, and
thereby indirectly acquire The
Bank of Delmarva, Seaford,
Delaware, and Virginia
Partners Bank, Fredericksburg,
VA "and more."
Since Partners
Bancorp's attempt to sell
itself to Ocean Bancorp died
amid reports of regulator
concern, documents in that
regard should be provided (and
made part of the record on
this application), too.
Fair Finance
Watch has been reviewing
LinkBank including its 2021
HMDA data not taken into
account in any CRA exam and
finds it troubling.
In
Pennsylvania in 2021, Link
Bank made 49 HMDA-reported
loans to whites - and only TWO
to African Americans, worse
that its peers. When one
expands the review to include
loans beyond Pennsylvania,
Link Bank's loans in 2021 to
whites increase to 53, but to
African Americans remains the
same insufficient
TWO.
Virginia
Partners Bank is only slightly
better. In 2021 it made 48
HMDA reported loans and only
THREE to African Americans.
While insufficient, that is
still more than Link Bank's
TWO. A terrible bank would be
acquiring a bad bank, and
making it even worse.
After
Inner City Press' comments
were filed, LINKBANK's outside
counsel Luse Gorman PC by
Agata S. Troy and Benjamin
Azoff rather than addressing
the disparities argued that
they have no merit, including
lying to the Federal Reserve
that the FDIC considered them
substantive, then urging the
FDIC to reconsider.
On July 12, the
FRBP asked Link questions,
including "5. Discuss whether
a compliance committee or any
fair lending or CRA-related
committees have been
established by Applicant or
LinkBank. If so, provide the
minutes. If not, provide
any minutes of the board of
either Applicant or LinkBank
since the March 22,
2021, Consumer Affairs Report
of Examination discussing
consumer compliance,
fair lending, and/or CRA
matters. 6. Provide LinkBank’s
most recent consumer
compliance risk assessment."
On July 19, Link
admitted it has misspoken to
the FDIC and tried to amend
it: "Dear Ms. Goñi: On behalf
of LINKBANK, Camp Hill,
Pennsylvania, a Pennsylvania
chartered commercial bank, we
would like to revise
LINKBANK’s responses to
comments received ... as
follows: Subsidiaries and
Affiliates 1. Describe
ownership details for the two
subsidiaries partially owned
by the Virginia Partners Bank
(Johnson Mortgage Company) and
the Bank of Delmarva (FBW LLC)
and what will happen to these
subsidiaries and all the other
subsidiaries of each bank as
part of the merger
transactions. LINKBANK would
like to retract the following
statement made in LINKBANK’s
response to comment 1, “The
parties expect to dissolve all
of the subsidiaries of TBOD
and VPB at or following
consummation of the closing of
the Transaction with the
exception of Johnson Mortgage
and 410 William Street,
LLC.” LINKBANK will
acquire all of the current
subsidiaries of TBOD and VPB
in the Bank Mergers and none
of these subsidiaries will be
dissolved at or prior to the
consummation of the
transaction. Prior to
dissolving any subsidiaries
post-closing, LINKBANK will
conduct an analysis pursuant
to 12 U.S.C. 1828(c)(1)(A) and
contact FDIC staff to confirm
whether any notice or
application is necessary."
If the regulators
at the Fed and FDIC mean what
they claim, this application
should be denied. Watch this
site.
***
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