By Matthew Russell Lee, Patreon Maxwell Book
SOUTH BRONX, Aug 1 – Pennsylvania, Delaware and Virginia are portrayed as diverse and ever progressive places. But their banks, not so much.
Consider for example the proposed merger on the rebound between New York-based Link Bank and Partners Bancorp, which recently broke off its proposed deal with OceanFirst.
Inner City Press and Fair Finance Watch have long exposed redlining - and in this vein, on May 6 they filed a Community Reinvestment Act challenge with the Federal Reserve.
On August 1, the Fed belated asked: "ased on staff’s review of Applicant’s letter to Mr. William T. Wisser, dated July 24, 2023, the following additional information is requested. Supporting documentation should be provided, as appropriate.
1. Describe in detail how LinkBank will adjust its fair lending program to accommodate the expanded market area acquired from VPB, particularly the Washington-Arlington-Alexandria VA-MD MMSA. 2. Clarify whether, and to what extent, LinkBank intends to integrate the consumer compliance and fair lending programs of TBOD and VPB into the resultant institution’s consumer compliance and fair lending programs.
3. Provide a list of organizations and community groups, if any, with which LinkBank has engaged since 2021 to help reach African American borrowers in Pennsylvania. In your response, provide detailed information about any partnerships that LinkBank has engaged in with these organizations and community groups since 2021. 4. Provide a list of organizations and community groups, if any, with which VPB has engaged since 2021 to help reach African American borrowers in the Washington-ArlingtonAlexandria VA-MD MMSA. In your response, provide detailed information about any partnerships that VPB has engaged in with these organizations and community groups since 2021.
5. Discuss in detail LinkBank’s and VPB’s efforts to reach African American borrowers in any area, including any specialized products and marketing campaigns targeting such borrowers, since 2021.6. Provide further information on LinkBank’s recent CRA activities since 2021, following the latest CRA performance evaluation of The Gratz Bank on March 22, 2021 (which preceded the acquisition of LinkBank by The Gratz Bank and the resulting institution’s name change to “LinkBank”). In particular, provide further information regarding LinkBank’s activities to improve its geographical distribution of loans throughout its assessment areas since the March 22, 2021, performance evaluation of The Gratz Bank. 7. Provide further information on VPB’s CRA activities since its October 2, 2017, performance evaluation."
Fair Finance Watch has been reviewing LinkBank including its 2021 HMDA data not taken into account in any CRA exam and finds it troubling.
In Pennsylvania in 2021, Link Bank made 49 HMDA-reported loans to whites - and only TWO to African Americans, worse that its peers. When one expands the review to include loans beyond Pennsylvania, Link Bank's loans in 2021 to whites increase to 53, but to African Americans remains the same insufficient TWO.
Virginia Partners Bank is only slightly better. In 2021 it made 48 HMDA reported loans and only THREE to African Americans. While insufficient, that is still more than Link Bank's TWO. A terrible bank would be acquiring a bad bank, and making it even worse.
After Inner City Press' comments were filed, LINKBANK's outside counsel Luse Gorman PC by Agata S. Troy and Benjamin Azoff rather than addressing the disparities argued that they have no merit, including lying to the Federal Reserve that the FDIC considered them substantive, then urging the FDIC to reconsidering. This should not be countenanced - rather than conditional approval, denial is called for.
If the regulators at the Fed and FDIC mean what they claim, this application should be denied. Watch this site.
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