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by Matthew Russell Lee, Patreon Book Substack

SOUTH BRONX/SDNY, Jan 23 – Associated Banc-Corp, with a track record of disparate lending and consumer complaints, now proposes to expand into Nebraska and Iowa by taking over American National Bank.

  Fair Finance Watch, while the Federal Reserve refuses to act to ensure public access to Home Mortgage Disclosure Act data,  notes the 2024 HMDA data of Associated National Bank, starting in Wisconsin: it denied more mortgage applications from African Americans, 90, than it made loans to African Americans, 86. Meanwhile it made fully 4243 loans to whites, while denying only 1430 loans.  On December 1 we said we would have more on these troubling disparities, including under the Community Reinvestment Act - and now we do.

On December 8 Fair Finance Watch filed with the Fed - acknowledged on the application on January 7, below - with no portion of the application provided as of Jan 9 at 4:20 pm

This concerns the proposal by Associated Banc-Corp to acquire and merge with American National    

  This is opposition at the earliest possible time. In light of a recent proposal in which only the OCC is considering a multi-billion merger, we are submitting this to the FRB as soon as possible. Please immediate inform FFW if Associated is applying to the FRS, and consider this comment on any and all Associated applications.  

[On January 7, the Fed wrote back: "Dear Matthew: The Federal Reserve Bank of Chicago has received your correspondence dated December 8, 2025. As of 4:20 pm on January 9, no application, none of it. And still none as of January 23.

     Associated Bank NA in Minnesota in 2024 made 414 mortgage loans to whites, and only 18 to African Americans. Meanwhile it denied TWENTY applications from African Americans, and only 163 from whites.   

   Associated Bank NA in Illinois in 2024 made 690 mortgage loans to whites, and only 136 to African Americans. Meanwhile it denied 105 applications from African Americans, and only 367 from whites.   

   Now Associated wants to take its branch closing ways to new states despite, for example,     Associated has closed many branches - here in the past year and a half, nothing but closings, etc.

On January 23, FFW submitted this:

Fair Finance Watch commented in opposition at the earliest possible time, on December 8, 2025. At that time, along with analysis of HMDA data and consumer complaints, FFW identified five more branch closings by Associated, for which they applied to the OCC in October and November, 2025.  

     The FRB of Chicago wrote to FFW on January 7, acknowledging the comment submitted a full month earlier and saying that no application had been received. Two days later on January 9, the FRBC sent FFW's comment to counsel for Associated, with a copy to FFW.       Since then, nothing. No copy of an Additional Information letter, no response by Associated. The comment period is running.       

FFW now puts into the record before the FRB that Associated on January 16, 2026 applied to close yet four more branches, in Wisconsin and Illinois:    

Associated Bank, NA  200 North Adams Street  Green Bay  WI  Brown    

Madison Galaxie Branch    828 East Washington Avenue         Madison    WI    53703    Dane    172576A

     10910 MAIN STREET         RICHMOND    IL    60071    McHenry    118578A

Bank Mut - Rice Lake Office    2850 Pioneer Avenue         Rice Lake    WI    54868    Barron

Alton Branch    104 HOMER ADAMS         ALTON    IL    62202    Madison

Given that even before the proposed acquisition Associated is closing so many branches, it is imperative that Associated be asked - during the comment period, and for a public exhibit - its branch closing plans going forward. Even other FR Banks do this (see, e.g., FRB of Cleveland on Fifth Third, on which FFW commented, resulting in a list of 80 closures being made public, albeit after the comment period was allowed to close).       We are writing now to avoid this - the question should be asked now, any AI letter that has gone out should be provided under the ex parte rules, or the lack of questions be explained.

Watch this site.

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