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by Matthew Russell Lee, Patreon Book Substack

FEDERAL COURTHOUSE, Oct 15 – As PNC Bank has grown it has become more disparate in its lending. After its CEO Bill Demchak announced a $4.1 billion proposal to buy FirstBank and bragged, "We just effectively bought Colorado," Fair Finance Watch prepared an early filing to the regulators demanding scrutiny and hearings.  And it filed a FOIA request about Erebor's charter application.

This takes place as the regulators, led by the FDIC, are seeking to eliminate public notice and limit public comment. See, e.g., American Banker, Sept 10, 2025, "The FDIC is taking the 'community' out of CRA enforcement," by Matthew R. Lee, here

 On September 30, after the FRB granted expedited processing under FOIA, the OCC denied an identical request for expedited processing, trying to ensure no records during the public comment period.

Compare OCC denial of expedited processing here to FRB grant of identical request here

Inner City Press appealed on September 30.

The OCC denied it, saying the public does not need any information about a bank application before the OCC closes the comment period- and approves it. Like on Erebor:

On October 1 the OCC reflexively denied expedition on a FOIA request for one of the many new (fangled) bank charters it is eager to give out, writing to Inner City Press that

"You requested the exhibits (mis) labeled 'Confidential' in the application for the proposed Erebor Bank. The applicants have withheld almost all exhibits and information about their proposal, including even the names of the directors, organizers, executives and principal shareholders. This is a FOIA request, then, for all of the exhibits. This is also a request for all record reflecting communication by or within the OCC with or about Erebor and its unidentified proposed directors, organizers, executives and principal shareholders.

We have reviewed you request for expedited processing under the criteria set out in 5 U.S.C. 552(a)(6)(E) and Treasury disclosure regulations at 31 C.F.R. 1.5(e). Although your request for expedited processing is denied, we have initiated a search in our program offices. The OCC must respond to FOIA requests in the order that they are received, however, we will try to respond as expeditiously as possible. Based on the information you have provided, I have determined that your request for expedited processing should be denied." UNreal.

Then on October 15 the Comptroller bragged, "

"The OCC granted preliminary conditional approval to Erebor Bank after thorough review of its application. In granting this charter, the OCC applied the same rigorous review and standards applied to all charter applications.

“Erebor is the first de novo bank to receive a preliminary conditional approval since I arrived at the OCC. I am committed to a dynamic and diverse federal banking system, and our decision today is a first but important step in living up to that commitment,” said Comptroller of the Currency Jonathan V. Gould.

But he's rubberstamping and protecting legacy banks too, and not only "Community Banks." Watch this site.

 From the filings:

This is an early first comment on, the proposal and applications by PNC to acquire FirstBank. PNC's CEO Bill Demchak on September 9 said publicly, "We just effectively bought Colorado." Not so fast.  

 Fair Finance Watch has long been concerned about PNC.  Fair Finance Watch has reviewed the just-released 2024 Home Mortgage Disclosure Act data of PNC, not reviewed in any Community Reinvestment Act performance evaluation. 

 In state after state, PNC for African Americans has (many) more denials than originations, while the opposite is true for white borrows. The pattern is striking:    

  In Colorado, which PNC CEO's says the bank has now "effectively bought," PNC in 2024 denied 12 applications from African Americans while making only 17 loans - while it made fully 422 loans to whites and denied only 244 applications.

    In Arizona, where PNC lists 60 branches and now proposes to further expand, PNC in 2024 denied 15 applications from African Americans while making only 22 loans - while it made fully 796 loans to whites and denied only 466 applications. This is disparate.  

 There are many more - including regarding the debanking the OCC said will now be considered in connection with merger and other applications - to be addressed at the requested hearings.

Watch this site.

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