By Matthew Russell Lee, Patreon Story
BBC - Guardian UK - Honduras - ESPN
FEDERAL COURT / S Bronx, May 26 – Whether or not the U.S. Community Reinvestment Act will be again enforced until the new Administration and its regulators is an open question. And the proposed merger of two redlining banks, M&T and People's United, will be a litmus test, see below.
And now another one: Citizens Bank's proposal to buy 80 more branches, from HSBC. If the Federal Reserve, or at least Governor Lael Brainard, had a problem with PNC - BBVA, why now Citizens - HSBC? Inner City Press (and Fair Finance Watch, on the HMDA) will have more to say about this. Watch this site.
While M&T - People's United still pends in the Federal Reserve, with a promised expedited FOIA response still not forthcoming, the Fed in mid May approved PNC - BBVA, with a rare abstention by Governor Lael Brainard, albeit on antitrust and not CRA or fair lending grounds. But now on May 25, Governor Brainard didn't even abstain on Huntington - TCF, despite HHI Index going over 3000 in multiple markets. Limiting antitrust concern to those with $250 billion is unwise, and arbitrary. The minimal branch divestitures are just window dressing. We'll have more on this.
On March 27, Fair Finance Watch and Inner City Press on the FOIA filed a challenge with the Federal Reserve to the banks' application, below. We await full response to the FOIA.
On April 12, the Federal Reserve asked M&T 32 questions, including:
"Provide People’s United’s record and experience with customer complaints and the types of actions taken by the company to resolve these complaints. Explain the complaint handling process, including identification, evaluation, monitoring, and resolution. Identify the number of complaints received during each of the last two years and how the complaints were resolved. Discuss the policies and procedures People’s United has in place to protect customers and resolve complaints. Please also provide plans for an integrated complaints process and any early measures to monitor consumer complaints following consummation of the proposed transaction.
9. Indicate any legal proceedings/investigations related to consumer protection concerns that either M&T or People’s United may be involved in. Full letter here.
Inner City Press / Fair Finance Watch filed this challenge: "This is a timely first comment opposing and requesting an extension of the FRB's public comment period on the Applications by M&T Bank Corporation to acquire People's United Financial.
The applicant M&T in New York State in 2019 made 8,613 home loans to whites and only 629 to African Americans. M&T in New York State in 2019 made 3.4 loans to whites for each denial to whites. It made only 1.4 loans to African Americans for every denial to African Americans.
This is totally unacceptable.
The applicant M&T in Connecticut in 2019 made 251 home loans to whites and only 27 to African Americans. M&T in Connecticut in 2019 made 2 loans to whites for each denial to whites. It made only 1.28 loans to African Americans for every denial to African Americans. This is unacceptable.
The applicant M&T in Pennsylvania in 2019 made 3565 home loans to whites and only 106 to African Americans.
M&T in Pennsylvania in 2019 made 2.52 loans to whites for each denial to whites. It made only 1.15 loans to African Americans for every denial to African Americans.
This is totally unacceptable.
Meanwhile, People's says it will close some 140 branches.
FFW and Inner City Press have been deeply concerned about the rush by the FRS' penchant to rubberstamp mergers by redliners, particularly during the pandemic. We note the Fed's recent website statement that a comment period has been extended to allow participation amid the Coronavirus crisis. This should be done, by the Fed's logic, on this and other applications. We timely request public hearings.
The hearings, and your review, should also address M&T's discrimation, see, e.g., (EEOC v. Manufacturers and Traders Trust Co., d/b/a M&T Bank., Civil Action No. 1:16-cv-03180-ELH) in U.S. District Court for the District of Maryland, Northern Division. See also, this.
The comment period should be extended; evidentiary hearings should be held; and on the current record, the application should not be approved.
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