by Matthew Russell Lee, Patreon Book Substack
SOUTH BRONX/SDNY, Nov 7 – Amid the FDIC's bid to eliminate public notice of and public comment on branch applications, Prosperity Bank has applied to buy San Antonio-based Southwest Bank for $269 million.
Fair Finance Watch, which has commented to the FDIC that its proposal to eliminate public notice of branch applications due to lack of comments violates the CRA, has now commented to the Federal Reserve:
This is a timely first comment on the application by Prosperity Bancshares, Inc., to merge with Southwest Bancshares, Inc., and indirectly acquire Texas Partners Bank. Notice was only put on the FRB's website today.
Fair Finance Watch has reviewed the just-released 2024 Home Mortgage Disclosure Act data of Prosperity Bank, not reviewed in any Community Reinvestment Act performance evaluation. In the state of Texas in 2024, Prosperity Bank denied 109 applications from African Americans while making fewer than half that, 40 loans - while it made fully 1502 loans to whites and denied only 904 applications. This is disparate.
In Oklahoma in 2024, Prosperity Bank denied three applications from African Americans while making only four loans - while it made fully 84 loans to whites and denied only 22 applications. Though lesser volume, this too is disparate.
Also for now consider: "Does anyone else find Prosperity Bank terrible? Should I go shopping for another bank. I don't know if this is the place to vent about this, but it seems that Prosperity Bank is constantly triggering fraud alerts and then it's extremely long waits on customer service calls to get them restored, and twice I have had all my cards canceled" and "I was with them since they were Legacy Texas and then Viewpoint and once Prosperity took over service completely tanked." Would that happen to Southwest?
FFW notes in the FDIC's pending proposal RIN 3064-AG10: "the FDIC has received a limited number of public comments in response to subpart C applications.... Therefore, the FDIC is proposing to eliminate the public notice and related public comment period from subpart C and to make conforming changes to subpart A of 12 CFR part 303 of the FDIC Rules."
See, e.g., Sept 10, 2025: https://www.americanbanker.com/opinion/the-fdic-is-undercutting-a-key-element-of-the-cra
But now the Federal regulator(s) blithely propose(s) to eliminate public notice and public comment on banks' proposals to expand. The above-quoted reasoning is that few comments are filed. So, that is now changing.
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