By Matthew Russell Lee, Patreon
FEDERAL COURT / S Bronx, March 29 – Whether or not the U.S. Community Reinvestment Act will be again enforced under this Administration and its regulators including under the incoming divided Congress is an open question.
On November 25, 2022 Fair Finance Watch with Inner City Press on the FOIA filed comments with the Federal Deposit Insurance Corporation against the applications by Prosperity Bank in Texas. In April 2023, the FDIC imposed conditions on one - and in March 2024, on the other, Lone Star.
November 25, 2022
Federal Deposit Insurance Corporation Attn: Chairman Martin J. Gruenberg Dallas Kristie K. Elmquist, Regional Director Julie V. Banfield, Deputy Regional Director Chris Finnegan
Re: Comment on Applications by Prosperity Bank, El Campo, Texas to acquire Lone Star Bank of West Texas and FirstCapital Bank of Texas, N.A.
Dear Chairman Gruenberg, Regional Director Elmquist, Ass't Regional Director Finnegan and others at the FDIC: This is a request for all information in the possession of the FDIC about, and a timely comment on, the Applications of Prosperity Bank, El Campo, Texas to acquire Lone Star Bank of West Texas and FirstCapital Bank of Texas, N.A. which appear on the FDIC website under "Applications In Process Subject to the CRA Report" with an initial comment periods running through December 16. This comment is timely.
The applicant Prosperity Bank in 2021 in Texas based on its disparate marketing made 5453 mortgage loans to whites -- while making only 188 loans to African Americans. Meanwhile it denied fully 94 applications from African Americans, versus only 1186 from whites. This is far out of keeping with the demographics, and others lenders, in Texas in particularly in Prosperity Bank's CRA assessment areas - this is outrageous.
The applicant Prosperity Bank in 2021 in Oklahoma based on its disparate marketing made 320 mortgage loans to whites -- while making only 38 loans to African Americans. This is far out of keeping with the demographics, and others lenders, in Oklahoma in particularly in Prosperity Bank's CRA assessment areas - this is outrageous. Very Truly Yours, Matthew Lee, Esq. Executive Director Inner City Press/Fair Finance Watch
On April 6, 2024 sent April 10, the FDIC imposed this condition: "After a careful review of the concerns, the FDIC decided to approve the application with the following condition. This condition will help ensure the home mortgage lending needs of African American populations in Prosperity Bank’s assessment areas are met. Enhance the bank’s Fair Lending Action Plan (Plan) adopted by the Board of Directors of Prosperity Bank and submit changes to the FDIC for approval within 60 days of the application approval date. The Plan updates and revisions, as applicable, should provide strategies to improve the volume of home mortgage applications from, and originations to African American applicants within each of the designated assessment areas established in Texas. The Plan should also provide strategies to improve the volume of home mortgage applications from, and originations in majority-minority census tracts and majority-Hispanic tracts within designated assessment areas in Texas. The enhancements should be developed in the context of available demographic data, as well as safe and sound lending considerations, and provide for periodic review of the Bank's efforts, using measurable criteria, to assess actions and progress. The Bank will continue to provide quarterly updates to the FDIC's Dallas Regional Office detailing the Bank's progress under the Plan."
The condition was re-imposed in March 2024 when the FDIC approved the Lone Star Bank application. Watch this site.
Watch this site.
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