Challenge to BancFirst Led to Referral to Federal Reserve Board Now 2d Rubber Stamp

Challenge to BancFirst Led to Referral to Federal Reserve Board Now 2d Rubber Stamp by Matthew Russell Lee, Patreon Book Substack SOUTH BRONX/Federal Court, Sept 22 – A proposed acquisition by BancFirst of American Bank of Oklahoma after the latter's redlining settlement, and deteriorating record since, gave rise to one then two challenges under the Community Reinvestment Act.   First, Fair Finance Watch, reviewing Home Mortgage Disclosure Act data of both banks from 2019 to 2024, filed a CRA challenge to the merger with the Federal Reserve Board: "American Bank of Oklahoma settled redlining charges with DOJ for its lending to 2021, while pushing to have reference to the Tulsa Race Riot removed from the complaint it settled. But since 2021, American Bank of Oklahoma's lending has hardly gotten better, including in 2024 a year for which data has not been considered in any CRA exam. And BancFirst is scarcely better. Public evidentiary hearings are needed and hereby requested. In 2024 American Bank of Oklahoma made 9 loans to African Americans in Oklahoma, and 225 loans to whites. For whites it made 20.45 loans for every denied, versus only 4.5 originations for even denial to whites. In 2023 American Bank of Oklahoma though still low made more loans to African Americans (15) while fewer to whites (223) then in 2024.  American Bank of Oklahoma is getting worse over time. (Back in 2019 in Oklahoma it made 14 loans to African American). The proposed acquirer BancFirst is problematic. In Oklahoma in 2024 BancFirst made 69 loans to African Americans, and 2413 loans to whites. For whites it made 7.18 loans for every denied, versus only 2.55 originations for even denial to whites. On July 9, 2025 the FRBKC wrote, "Application filed by BancFirst Corporation to acquire American Bank of Oklahoma - Dear Mr. Shadid: We are writing to advise you that effective July 9, 2025, processing of the above referenced filing is being transferred from the “Delegated Action” processing procedure to “Board Action” in order to permit additional time to review the public comment received. As a result, the processing schedule will be extended; however, the filing will be acted on within the timeframe allowed by regulation." Letter on DocumentCloud here. Jump cut to September 22, 2026: The Federal Reserve has approved BancFirst Corporation's acquisition of Spirit BankCorp and SpiritBank — the second major Oklahoma bank acquisition the Board has waved through for BancFirst in less than twelve months, following its October 2025 approval of BancFirst's acquisition of American Bank of Oklahoma, itself fresh off a federal redlining settlement. The new order is worth reading closely not for what it concludes, but for how little work the conclusion actually required.  The Board describes a genuine factual dispute, then declines to resolve it. Fair Finance Watch's comment, based on HMDA data, showed BancFirst made fewer home loans to African American individuals in Oklahoma in 2025 than in 2024, even as lending to white individuals rose. BancFirst's response doesn't dispute the underlying trend directly — it disputes the count, arguing the commenter's figures exclude HMDA's "Two or More Minority Races" and "Joint" categories, which would inflate the apparent number of loans to Black borrowers by folding in mixed-race and joint applications. The commenter, per the order's own footnote, "urged the Board to consider single-race HMDA data, in addition to BANF's calculations." The Board's response to this direct, stated disagreement about methodology: nothing. The order recites both positions and moves straight to "consistent with approval," never stating which count it actually credits, or why.  The CRA exam underneath this approval is nearly four years stale. BancFirst's most recent CRA Performance Evaluation is dated July 15, 2024 — but the underlying lending data it reviews runs only through December 31, 2022, per the exam's own methodology footnote. The commenter's actual complaint concerns 2024 and 2025 lending patterns. The exam approving this transaction never looked at either year.  Buried under the exam's overall "Satisfactory" rating are two "Low Satisfactory" scores — the second-lowest possible — on both the Lending Test and the Investment Test, the two categories that most directly measure whether a bank is actually extending credit fairly. Only the Service Test pulled "High Satisfactory," enough to average the composite up to passing.  The public hearing request was denied using boilerplate that contradicts the order's own text. The Board's stated reason: the commenter's request "does not identify disputed issues of fact that are material to the Board's decision." Three pages earlier, the same order describes exactly that — a disputed factual question about how many loans BancFirst actually made to African American borrowers, which methodology should govern the count, and which party's numbers are correct. A hearing exists precisely to test disputes like this one; the order identifies the dispute and then declares none exists.  A separate complaint — that BancFirst's own responses were improperly marked confidential — got the same non-engagement, answered with a citation to the Board's general confidentiality rules rather than any actual ruling on whether these specific redactions were proper.  And BancFirst has disclosed, without specifics, that it "is likely to close one SpiritBank branch at a later time," citing generic factors — "economic prudence," "market impact" — with no indication of which branch, or whether it serves a low- or moderate-income community. The Board accepted this as sufficient.  Two Oklahoma acquisitions, one redlining settlement, and now an unresolved HMDA dispute the Board's own order can't be bothered to settle — approved anyway. Watch this site. *** Your support means a lot. 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