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by Matthew Russell Lee, Patreon Book Substack

SDNY / SOUTH BRONX, Nov 24 –  JPMorgan Chase's apparent enabling of sex trafficking by Jeffrey Epstein and Ghislaine Maxwell, as well as its "debanking," have been formally raised by Fair Finance Watch on November 24 to the US Office of the Comptroller of the Currency, opposing JPMC's applications including to open eight branches while closing in low and moderate income communities. 

   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 is a test:

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:  

   In 2024, the most recent year for which HMDA data is available and data for which has not been reviewed in any Community Reinvestment Act performance evaluation, JPM Chase NA nationwide made 52,013 mortgage loans to whites, while denying 7437 applications from whites. Meanwhile it made only 6222 loans to African Americans, with fully 1565 denials.     Beyond these disparities, JPM Chase's lending to African Americans is even down from 2022, when it made 7505 loans to African Americans. JPM Chase is in decline.  

  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, initially timely on these (and also on all of the pending and 2025 applications)  

Branch Establishment    2025-BranchNew-343696    JPMorgan Chase Bank, NA    1111 Polaris Parkway    Columbus    OH    Delaware    2025-11-24 

Branch Establishment    2025-BranchNew-343697    JPMorgan Chase Bank, NA 2025-11-24 

Branch Establishment    2025-BranchNew-343700    JPMorgan Chase Bank, NA   2025-11-24 

Branch Establishment    2025-BranchNew-343701    JPMorgan Chase Bank, NA   2025-11-25 

Branch Establishment    2025-BranchNew-343724    JPMorgan Chase Bank, NA   2025-11-26 

Branch Establishment    2025-BranchNew-343813    JPMorgan Chase Bank, NA  2025-11-28 

Branch Establishment    2025-BranchNew-343834    JPMorgan Chase Bank, NA    2025-12-01 

Branch Establishment    2025-BranchNew-343835    JPMorgan Chase Bank, NA    2025-12-02 

Branch Establishment    2025-BranchNew-343841    JPMorgan Chase Bank, NA    2025-12-01 

Branch Establishment    2025-BranchNew-343891    JPMorgan Chase Bank, NA    2025-12-05 

Branch Establishment    2025-BranchNew-343892    JPMorgan Chase Bank, NA 2025-12-08 

Branch Establishment    2025-BranchNew-343893    JPMorgan Chase Bank, NA  2025-12-08 

Branch Establishment    2025-BranchNew-343904    JPMorgan Chase Bank, NA   2025-12-08 

Branch Establishment    2025-BranchNew-343926    JPMorgan Chase Bank, NA   2025-12-12 

Branch Establishment    2025-BranchNew-343931    JPMorgan Chase Bank, NA 2025-12-15     

Meanwhile, JPM Chase NA is moving to CLOSE branches in low and moderate income areas. As only one example - and hereby raised, along with the request(s) for public hearings, FFW opposes this proposed closing by JPM Chase in a moderate income census tract, over 80% "minority" -- 

South Holland    370 EAST 162ND STREET         SOUTH HOLLAND    IL    60473    Cook    141494A    

FFW notes in the FDIC's pending proposal RIN 3064-AG10, which is mirrored by other OCC proposal to move away from even having applications, and shortening review times, while purportedly taken issues like the debanking herein raised seriously: "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,  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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