| TowneBank Challenged
Application to FDIC to Buy Dogwood
Has Names of Exhibits Redacted
by
Matthew Russell Lee, Patreon Book
Substack
SOUTH
BRONX/SDNY, Oct 15 –
Amid the FDIC's bid to
eliminate public notice of and
public comment on branch
applications, TowneBank has
applied to the FDIC to acquire
a bank in North Carolina,
Dogwood Bank, for $476
million.
Fair
Finance Watch, which has
commented to the FDIC that its
proposal to eliminate public
notice of branch applications
due to lack of comments
violates the CRA, has now
commented to the FDIC:
This is a timely
first comment opposing and
requesting an extension of the
FDIC's public comment period
on the Application by
TowneBank to acquire Dogwood
State Bank. The application is
on the FDIC's website where a
public comment period running
through November 30, 2025
(11/30) is listed (screenshot
submitted to the FDIC via form
and available on request).
These comment, and supplements
to come, are
timely.
Update: On
October 15, the FDIC finally
provided Inner City Press some
of the application - absurdly,
with even the names of
"Confidential" Exhibits
blacked out. Inner City Press
has immediately challenged it
under FOIA, noting the
connection with the comment
period (which must be
extended). Watch this site.
Fair
Finance Watch, which has
commented to the FDIC that its
proposal to eliminate public
notice of branch applications
violates the CRA, has compared
TowneBank's lending record in
North Carolina in 2023 to
2024. It has gotten worse and
more disparate. In
2023 in North Carolina,
TowneBank made 80 loans to
African Americans while
denying 10 applications from
African Americans. In 2024 it
made fewer loans to African
Americans - 77 - while denying
more: 13. Now it wants to
expand there. At the earliest
possible time, FFW is opposing
this. We will be submitting
more comments before the
stated November 30 expiration
of the comment period.
FFW notes
in the FDIC's pending proposal
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
But now the
Federal regulator(s) blithely
propose(s) 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.
***
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