by Matthew Russell Lee, Patreon Book Substack
SDNY/SOUTH BRONX, Oct 24 – As US bank regulators loosen rules - including the FDIC moving to eliminate public comment altogether on branch expansion applications - now more big banks are moving to get bigger.
On October 6, amid the pending PNC - FirstBank, Pinnacle - Synovus proposals, and Fifth Third - Comerica Bank proposals, in the Midwest First Merchants Bank has applied only to the FDIC to by First Savings Bank.
On October 9, it was opposed, to the FDIC:
Dear Regional Director Bottone and others at the FDIC: This is a timely first comment opposing and requesting an extension of the FDIC's public comment period on the Application by First Merchants Bank to acquire First Savings Bank. The application is on the FDIC's website where a public comment period running through November 6, 2025 . These comment, and supplements to come, are timely.
Fair Finance Watch, which has commented to the FDIC that its proposal to eliminate public notice of branch applications violates the CRA, noting the FDIC's rationale that it receives few public comments, hereby timely informs the FDIC that is troubled by First Merchant's lending record and is requesting public hearings and denial of this application.
In 2024 in Illinois, from which First Merchants is ostensibly regulation, First Merchants made only 11 loans to African Americans while denying more than double, 24 applications from African Americans. By contrast in Illinois in 2024 First Merchants Bank made 60 loans to whites while denying only 20 - a three to one ratio. First Merchants is six times more likely to deny the applications of African Americans than those of whites. This application must be denied, and referral made.
In 2024 in Indiana, in which First Merchants seeks to expand, First Merchants made only 106 loans to African Americans while denying 55 applications from African Americans. By contrast in Indiana in 2024 First Merchants Bank made fully 2478 loans to whites while denying only 745.
In 2024 in Ohio, First Merchants made only 16 loans to African Americans while denying 13 applications from African Americans. By contrast in Ohio in 2024 First Merchants Bank made fully 217 loans to whites while denying only 39.
In 2024 in Michigan, First Merchants made only 122 loans to African Americans while denying 41 applications from African Americans. By contrast in Michigan in 2024 First Merchants Bank made fully 1327 loans to whites while denying only 192. This application must be denied, and referral made.
There are many consumer complaints against First Merchants Bank; here for the record...
On October 24, First Merchant's CEO Mark K. Hardwick responded to FFW, including that "Disparities in other Assessment Areas were self-identified through FMB’s internal Fair Lending monitoring program."
Fair Finance Watch immediately filed a second timely comment asking that these areas be named, and noting that "In the state of Indiana in 2024, First Savings Bank made fully 275 mortgage loans to whites, with 73 denials to whites, but only THREE loans to African Americans. This is extremely disparate, making full disclosure by FMB all the more imperative."
Inner City Press, which has opposed the FDIC's moves to close itself to public scrutiny - American Banker op-ed here - has now submitted FOIA requests on all this. The FDIC said it will eliminate public notices because it does not receive enough public comments. That is changing, starting now. Watch this site.
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