| Link Bank
Bid To Buy Partners Bancorp On the Ocean
Rebound has Belated Fed CRA Questions
By Matthew
Russell Lee, Patreon Maxwell
Book
SOUTH BRONX, Aug
1 – 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.
On August 1, the
Fed belated asked: "ased on
staff’s review of Applicant’s
letter to Mr. William T.
Wisser, dated July 24,
2023, the following additional
information is requested.
Supporting documentation
should be provided, as
appropriate.
1. Describe in
detail how LinkBank will
adjust its fair lending
program to accommodate
the expanded market area
acquired from VPB,
particularly the
Washington-Arlington-Alexandria
VA-MD MMSA. 2. Clarify
whether, and to what extent,
LinkBank intends to integrate
the consumer compliance
and fair lending programs of
TBOD and VPB into the
resultant institution’s
consumer compliance and fair
lending programs.
3. Provide a list
of organizations and community
groups, if any, with which
LinkBank has engaged
since 2021 to help reach
African American borrowers in
Pennsylvania. In your
response, provide detailed
information about any
partnerships that LinkBank has
engaged in with these
organizations and community
groups since 2021. 4. Provide
a list of organizations and
community groups, if any, with
which VPB has engaged
since 2021 to help reach
African American borrowers in
the
Washington-ArlingtonAlexandria
VA-MD MMSA. In your response,
provide detailed information
about any partnerships
that VPB has engaged in with
these organizations and
community groups since
2021.
5. Discuss in
detail LinkBank’s and VPB’s
efforts to reach African
American borrowers in
any area, including any
specialized products and
marketing campaigns targeting
such borrowers, since
2021.6. Provide further
information on LinkBank’s
recent CRA activities since
2021, following the
latest CRA performance
evaluation of The Gratz Bank
on March 22, 2021 (which
preceded the acquisition of
LinkBank by The Gratz Bank and
the resulting institution’s
name change to
“LinkBank”). In particular,
provide further information
regarding LinkBank’s
activities to improve its
geographical distribution of
loans throughout its
assessment areas since
the March 22, 2021,
performance evaluation of The
Gratz Bank. 7. Provide further
information on VPB’s CRA
activities since its October
2, 2017, performance
evaluation."
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 reconsidering. This
should not be countenanced -
rather than conditional
approval, denial is called
for.
If the regulators
at the Fed and FDIC mean what
they claim, this application
should be denied. Watch this
site.
***
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