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By Matthew Russell Lee, Patreon Story
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FEDERAL COURT / S Bronx, July 8 – Whether or not the U.S. Community Reinvestment Act will be again enforced until the new Administration and its regulators remains an open question.

  This has become even more true in 2023, with regulators under fire for misregulation of the failing banks, and of handing them over to mega banks like JPM  Chase. Hence Janet Yellen has promised "openness" to mergers of midsized (and presumably small) banks. Let the rubber stamping begin!

This perhaps explains the industry press hand-wringing about the failure of some mergers subject to CRA protest, largely by Fair Finance Watch. In May 2023, there's MVB bank, here.

Sometimes a CRA protest presage / precedes a downgrade.

Back in August 2022: "Matthew Lee, Esq. Fair Finance Watch P.O. Box 20047 New York City, New York 10017 Re: MapleMark Bank’s Application to Acquire Oakwood Bank Dear Mr. Lee, We are writing to inform you that MapleMark Bank, Dallas, Texas, withdrew its application to acquire and merge with Oakwood Bank, Dallas, Texas. Please note that we will perform any necessary follow-up of the concerns you raised as part of our consumer compliance and Community Reinvestment Act examination programs. We appreciate your concerns and value community input into the application process." Yeah.

   Fair Finance Watch with Inner City Press on the FOIA  filed comments with the Federal Deposit Insurance Company to a proposed merger involving a bank subject to a rare CRA condition: Oakwood Bank in Dallas, and MapleMark Bank:

"March 21, 2022  Dear Regional Director Elmquist, Ass't Regional Director Finnegan and others at the FDIC:   This is a request for all information in the possession of the FDIC about, and a timely comment on, the Applications of Oakwood Bank to merge with MapleBank Bank, both of Dallas, Texas.  

The FDIC publicly imposed a CRA / fair lending condition on Oakwood for its underperformance in Dallas, see, e.g., FDIC required Oakwood Bank to "develop plans to equitably lend to low- and moderate-income borrowers in predominately minority parts of Southern Dallas... [and] action plans to improve small business lending in census tracts in majority-minority, and low- to moderate-income areas. Those action plans have to be adopted by the banks' board of directors and submitted to the FDIC, which is also requiring regular updates on the banks' progress." 

 There is a long history here. See, e.g., American Banker, "Oakwood's CRA Problems Continue."  

 Inner City Press has submitted a FOIA request to the FDIC for All records reflecting and regarding the fair lending / Community Reinvestment Act condition publicly imposed by the FDIC on Oakwood Bank in Dallas, Texas, including all non exempt portions of reports purporting to show performance  

This is a matter of public interest, as it MapleMark's engagement with fintech(s), see, e.g., MapleMark Bank is utilizing German fintech in a partnership  Jun 9, 2021 — A Dallas-based bank funded by local family offices is partnering with a German fintech.. Very Truly Yours,     Matthew Lee, Esq.   Executive Director  Inner City Press/Fair Finance Watch

  Since then, both banks have received rare Needs to Improve CRA ratings...

 Inner City Press (and Fair Finance Watch, on the HMDA) will have more to say about this. Watch this site.

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