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OCC Moves for Banks to Bypass CRA with Streamlined Strategic Plan while Ignores Epstein

by Matthew Russell Lee, Patreon Book Substack

SDNY / SOUTH BRONX, Dec 17 – The OCC is even handed: it is giving away the store to banks both large and smaller. On the large(st), see below the OCC denying Fair Finance Watch's requests about JPMorgan Chase's apparent enabling of sex trafficking by Jeffrey Epstein and Ghislaine Maxwell, as well as its "debanking," opposing JPMC's applications including to open eight branches while closing in low and moderate income communities. 

 On so-called Community Banks - larger than any previously definition of community banks - the OCC on December 17 moved to allow them "streamlined" Community Reinvestment Act strategic plans. The OCC says it can waive data, and the filing of notices. They are giving away the store.

   As the US bank regulators including the OCC under Comptroller Jonathan V. Gould move to limit public notice and participation in review of banks' applications for approvals, and purport to take seriously debanking and even banks' enabling of sex trafficking, this was a test.

On and December 2, the test was failed. The OCC wrote: " Dear Mr. Lee: The OCC has decided not to extend the public comment period. Your request for a public hearing did not appropriately describe the nature of issues or facts to be presented in such a hearing. Therefore, your request for a public hearing was denied."

 But the OCC loudly claims to take debanking seriously, and tells at least one Senator it is taking the Epstein files and JPM Chase seriously. Not so much - no hearing. How can there be details, for example, while the files are not yet unsealed in the SDNY?

To Comptroller Gould and To Whom it May Concern at the OCC: 

    On behalf of Fair Finance Watch and in my personal capacity there are timely comments opposing JPMorgan Chase NA's branch applications list below, all of which have comment periods running through today November 24 or later. These comments are timely.   

   FFW has reviewed the Home Mortgage Disclosure Act data of JPMorgan Chase NA and finds that it is deteriorating. For now, here are JPMC's nationwide numbers..

  Also for the record on these and all other JPM Chase applications before the OCC, now and until at least the end of the year: JPM Chase has been exposed as having enabled sex traffickers Jeffrey Epstein and Ghislaine Maxwell, including a current Congressional inquiry into Suspicious Activity Reports it should have filed by didn't.    

Also, on the issue of debanking which the OCC (and Comptroller) have said they take so seriously, for the record on these and all other JPM Chase applications, consider:  "Strike CEO Jack Mallers said JPMorgan Chase closed his bank accounts without a proper explanation last month, prompting concerns of debanking of crypto CEOs. "Last month, J.P. Morgan Chase threw me out of the bank," Mallers wrote on social media platform X on Sunday. "It was bizarre. My dad has been a private client there for 30+ years." When Mallers inquired why his accounts were closed, he said JPMorgan’s only response was: "We aren’t allowed to tell you.'"

    This is a debanking complaint to the OCC, on pending applications - please immediately confirm receipt, and take action. Public hearings are hereby timely requested

Meanwhile, JPM Chase NA is moving to CLOSE branches in low and moderate income areas.

See,  American Banker, BankThink: "The FDIC is taking the 'community' out of CRA enforcement," by Matthew R. Lee, here.

   Again, the only enforcement mechanism of CRA is its consideration on applications for deposit facilities: branches.  A hearing is requested, timely opposition made.

Thank you for your attention, /s/ Matthew Lee, Esq. Executive Director Fair Finance Watch

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