by Matthew Russell Lee, Patreon Book Substack
SOUTH BRONX/SDNY, Sept 26 – Amid the FDIC's bid to eliminate public notice of and public comment on branch applications, TowneBank has applied to the FDIC to acquire a bank in North Carolina, Dogwood Bank, for $476 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 FDIC:
This is a timely first comment opposing and requesting an extension of the FDIC's public comment period on the Application by TowneBank to acquire Dogwood State Bank. The application is on the FDIC's website where a public comment period running through November 30, 2025 (11/30) is listed (screenshot submitted to the FDIC via form and available on request). These comment, and supplements to come, are timely.
Fair Finance Watch, which has commented to the FDIC that its proposal to eliminate public notice of branch applications violates the CRA, has compared TowneBank's lending record in North Carolina in 2023 to 2024. It has gotten worse and more disparate. In 2023 in North Carolina, TowneBank made 80 loans to African Americans while denying 10 applications from African Americans. In 2024 it made fewer loans to African Americans - 77 - while denying more: 13. Now it wants to expand there. At the earliest possible time, FFW is opposing this. We will be submitting more comments before the stated November 30 expiration of the comment period.
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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