by Matthew Russell Lee, Patreon Book Substack
SOUTH BRONX/SDNY, Dec 1 – Amid the FDIC's bid to eliminate public notice of and public comment on branch applications, TD Bank - Toronto Dominion - is moving to close 51 more branches, on top of 36 earlier closed.
On November 10 Fair Finance Watch filed the below opposition to the Office of the Comptroller of the Currency.
On December 1, the OCC wrote back: "Mr. Lee: I am responding to your email below. Please see the attached public comment acknowledgment letter. The OCC notes that twelve (12) out of the fifty-two (52) branches mentioned below: 20th & K (343727); Myrtle Beach Main (343728); North Conway (343729); Lowell-Central Street (343731); Willimansett (343732); Silver Spring City Place (343742); Little River Turnpike (343743); Marion (343746); Lincoln Plaza (343748); Four Seasons (343749); Miami Gardens Northeast Branch (343754); and Pittsfield (343785) are located in LMI areas, and that you have requested a hearing. With respect to these branch closings, Licensing has forwarded your comment to the OCC’s Community Affairs Department for review." Now what?
Filed with OCC on November 10:
Fair Finance Watch has long been concerned about TD Bank. Fair Finance Watch has reviewed the just-released 2024 Home Mortgage Disclosure Act data of TD Bank NA not reviewed in any Community Reinvestment Act performance evaluation.
Nationwide, TD Bank in 2024 denied 3837 applications from African Americans while making fewer, only 3169 loans - while it made fully 44,281 loans to whites and denied only 20,376 applications. This is disparate, and it is systemic.
In state after state, TD Bank for African Americans has (many) more denials than originations, while the opposite is true for white borrows. The pattern is striking, starting with New York: In New York, TD Bank in 2024 denied 483 applications from African Americans while making fewer, only 297 loans - while it made fully 2915 loans to whites and denied only 1599 applications. This is disparate.
Again, the only enforcement mechanism of CRA is its consideration on applications for deposit facilities: branches. Here TD Bank is closing yet 51 more branches. A hearing is requested, timely opposition made. For identification: TD Bank is closing more branches throughout this year and next. The bank is closing more branches at the end of 2025 and into 2026 after closing 38 branches earlier in 2025....
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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