By Matthew Russell Lee, Patreon Maxwell Book
BBC - Honduras - CIA Trial Book - NY Mag
S Bronx / SDNY, August 24 – While the Administration says it is modernizing the Community Reinvestment Act, Ford is rushing to use the old rule to evade CRA, ostensibly in the name of electric vehicles.
On August 23-4 Fair Finance Watch, with Inner City Press on the FOIA, filed comments opposing it with the FDIC and Utah regulator:
Re: Timely opposition to the application by the proposed Ford Credit Bank
Dear Kathy Moe Regional Director, Janet Kincaid Deputy Director, others at FDIC & Utah DFI:
This is a timely first comment opposing and requesting an extension of the FDIC's public comment period on the Applications by the proposed Ford Credit Bank. This proposal, if approved, would make a mockery of the Community Reinvestment Act, particularly as it is being modernized by the new regulation on which the comment period closed on August 5.
The FDIC should hold public hearings, and on the current record deny the application. Contrary to the current and even more to the impending CRA regulation claims that despite its high volume of auto lending -- with its own compliance problems -- it should be viewed as a limited purpose institution. Fair Finance Watch opposes this. Consider, for example, the size of Ford Credit's retail lending, here: "Ford Credit delivered record quarterly earnings before taxes of $1.6 billion."
Compare: 87 Fed. Reg. 33928, VIII. Retail Lending Test Product Categories and Major Product Lines Public hearings are needed, and a re-opened comment period after the new CRA regulation is finalized.
Consider also, beyond previous issues at Ford's lending operations of discrimination against African Americans and Latinos, these recent TCPA cases: Coleman v. Ford Motor Credit Company LLC (8:21-cv-00647) District Court, M.D. Florida; and Diaz v. Ford Motor Credit Company, LLC (3:20-cv-06027) District Court, N.D. California The FDIC is administering a loophole that even many in the industry, because consumer and CRA advocates, oppose.
For the record, this is a timely comment on: " Ford Credit Bank (Proposed) 15 West South Temple SALT LAKE CITY, UT Deposit Insurance (New Bank) 07/22/2022 08/24/2022 San Francisco The comment period should be extended; evidentiary hearings should be held; and on the current record, the application should not be approved.
Very Truly Yours, Matthew Lee, Esq. Executive Director Inner City Press/Fair Finance Watch
cc: Utah Dept of Financial Institutions
We'll have more on this.
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