| Burke & Hebert
Challenged on Bid for LINKBANK
FRB 3 AI Letters Rubberstamp
by
Matthew Russell Lee, Patreon Book
Substack Federal
Court,
April 10 â As banks rush to
merge given rubberstamping
signals from US regulators,
LinkBank has done too far with
Burke &
Herbert. Back in
2023 Fair Finance Watch got
the FDIC to impose a Community
Reinvestment Act condition on
LINKBANK, here. Now with no
indication of compliance,
LINKBANK proposes to sell
itself to also-disparate Burke
& Hubert. FFW
on December 22 filed
challenges with the Federal
Reserve Board and FDIC. FRB
version: Dear
Chairman Powell, Secretary
Misback: This
concerns the proposal by Burke
& Herbert to acquire
LINKBANCORP and
LINKBANK. This is
opposition at the earliest
possible time. In light of a
recent proposal in which only
the OCC is considering a
multi-billion merger, we are
submitting this to the FRB as
soon as possible. Please
immediate inform FFW if Burke
& Herbert is applying to
the FRS, and consider this
comment on any and all Burke
& Herbert
applications. FFW
previously raised disparities
of LINKBANK to the FDIC -
resulting on a CRA condition
being opposed on October 3,
2023. It is imperative
that compliance be reviewed,
including at the requested
public evidentiary hearing.
Given recent developments,
there is no reason to believe
that the FDIC would or will
enforce even its own
conditions.
Burke &
Herbert in Virginia in 2024
made 83 mortgage loans to
whites, and only SEVEN to
African Americans. Meanwhile
it denied two applications
from African Americans, and
only four from
whites. This is
disparate.
Burke & Herbert in West
Virginia in 2024 made 165
mortgage loans to whites, and
only TWO to African Americans.
Meanwhile it denied one
application from an African
Americans, and only 29 from
whites.
Burke & Herbert in
Maryland in 2024 made 18
mortgage loans to whites, and
only TWO to African
Americans. Now Burke
& Herbert wants to buy
LINKBANK, on which FFW had a
CRA condition imposed. The
FDIC wrote: CRA Protest
In the course of reviewing
public input on the
application, the FDIC received
an adverse comment from a
protester that was considered
a CRA protest... the FDIC
decided to approve the
application with the following
condition. On January 7, the
FRS wrote back: "The Federal
Reserve Bank of Richmond
received your correspondence
on December 23, 2025,
regarding a future application
by Burke & Herbert
Financial Services Corporation
(âB&Hâ) to acquire
LINKBANCORP (âLINKâ). The
Federal Reserve has not yet
received an application by
B&H to acquire LINK.
Accordingly, no immediate
action will be taken on the
correspondence dated December
23, 2025. If a filing is
received in the next three
months, your comment may be
considered as part of the
application record for the
filing." MAY be
considered? On February 25
the Fed asked 10 more
questions, including on fair
lending, letter on Patreon here On March 3, the
Fed asked 7 multi-part
questions, including
"Following the proposed
transaction, CRE levels would
continue to exceed the
threshold for enhanced
monitoring noted in SR 07-1.
Accordingly, discuss whether
and, if so, how the oversight
of the loan portfolio,
including concentration risk
management practices and
management's responsiveness to
changing market conditions,
would be enhanced. 5. Discuss
the number of LINKBANK
employees that B&H Bank
would retain following the
proposed transaction (aside
from Messrs. Andrew Samual,
Carl Lundblad, and Brent
Smith)" - full letter on
Patreon here On April 10 the
Fed rubberstamped the
application: "The commenter
also noted that, in connection
with its approval of an
acquisition by LINKBANK in
2023, the FDIC placed a
condition on the bank
requiring the bank to take
certain specific actions
related to mortgage lending
and related activities in
certain areas, particularly
with respect to African
American consumers and LMI
communities." No follow up.
Even when banks are bad enough
to have conditions imposed,
there is no follow up. But we
will follow up. Watch this
site. Watch this
site.
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