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by Matthew Russell Lee, Patreon Book Substack

BRONX / FEDERAL COURT, Feb 19 –   General Motors is an opportunity. It previously applied to try to get into banking through the Utah Industrial Loan Company loophole, but was opposed and withdrew. 

  Now, for obvious reasons, it has reapplied - under the old CRA rules, which have been repealed and superseded, no less. On February 7 Fair Finance Watch filed opposition with the FDIC and Utah regulator:

This is a timely first comment by Fair Finance Watch  opposing and requesting an extension of the FDIC's public comment period on the Applications by General Motors for deposit insurance.

 This re-submitted proposal, if approved, would make a mockery of the Community Reinvestment Act. The FDIC should hold public hearings, and on the current record deny the application.   

GM does business and its bank would, well beyond Utah. But it seeks to limit its CRA to… Utah.   Tellingly, the application states that "GM Financial has developed this Community Reinvestment Act (“CRA”) plan based on the Federal Deposit Insurance Corporation (“FDIC”) CRA regulations that were effective on March 31, 2024, rather than the new framework that was finalized on October 24, 2023 (the “2023 CRA Framework”).

The questions to be considered at the public hearing are not only the regulatory evasion of ILCs - more unacceptable after the financial meltdown - but also CRA assessment areas, covering of affiliates, etc. 

On February 18, this: "William J. Donnelly, Senior Vice President  GM Financial  801 Cherry Street, Suite 3500  Fort Worth, TX 76102  Dear Mr. Donnelly:  This letter is in reference to a Community Reinvestment Act (CRA) protest filed by Mr. Matthew  R. Lee of Fair Finance Watch, concerning your application for an Industrial Loan Charter and  deposit insurance, filed on January 31, 2025.  We reviewed the enclosed correspondence and  consider it to constitute a protest for purposes of this application, in accordance with the  provisions of 12 C.F.R. Section 303.  The protest concerns the proposed institution’s CRA  compliance and how the convenience and needs factor will be addressed in the application  process.  You may provide a written response on the protest to me until March 5, 2025."

  Inner City Press also opposes the redactions to the application, including to the "Financial Model"   Watch this site.

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