by Matthew Russell Lee, Patreon Book Substack
SOUTH BRONX/SDNY, Feb 12 – Associated Banc-Corp, with a track record of disparate lending and consumer complaints, now proposes to expand into Nebraska and Iowa by taking over American National Bank.
Fair Finance Watch, while the Federal Reserve refuses to act to ensure public access to Home Mortgage Disclosure Act data, notes the 2024 HMDA data of Associated National Bank, starting in Wisconsin: it denied more mortgage applications from African Americans, 90, than it made loans to African Americans, 86. Meanwhile it made fully 4243 loans to whites, while denying only 1430 loans. On December 1 we said we would have more on these troubling disparities, including under the Community Reinvestment Act - and now we do.
On December 8 Fair Finance Watch filed with the Fed - acknowledged on the application on January 7, below - with no portion of the application provided as of Jan 9 at 4:20 pm
This concerns the proposal by Associated Banc-Corp to acquire and merge with American National
This is opposition at the earliest possible time. In light of a recent proposal in which only the OCC is considering a multi-billion merger, we are submitting this to the FRB as soon as possible. Please immediate inform FFW if Associated is applying to the FRS, and consider this comment on any and all Associated applications.
[On January 7, the Fed wrote back: "Dear Matthew: The Federal Reserve Bank of Chicago has received your correspondence dated December 8, 2025. As of 4:20 pm on January 9, no application, none of it. And still none as of January 23.
Associated Bank NA in Minnesota in 2024 made 414 mortgage loans to whites, and only 18 to African Americans. Meanwhile it denied TWENTY applications from African Americans, and only 163 from whites.
Associated Bank NA in Illinois in 2024 made 690 mortgage loans to whites, and only 136 to African Americans. Meanwhile it denied 105 applications from African Americans, and only 367 from whites.
Now Associated wants to take its branch closing ways to new states despite, for example, Associated has closed many branches - here in the past year and a half, nothing but closings, etc.
On January 23, FFW submitted this:
Fair Finance Watch commented in opposition at the earliest possible time, on December 8, 2025. At that time, along with analysis of HMDA data and consumer complaints, FFW identified five more branch closings by Associated, for which they applied to the OCC in October and November, 2025.
The FRB of Chicago wrote to FFW on January 7, acknowledging the comment submitted a full month earlier and saying that no application had been received. Two days later on January 9, the FRBC sent FFW's comment to counsel for Associated, with a copy to FFW. Since then, nothing. No copy of an Additional Information letter, no response by Associated. The comment period is running.
FFW now puts into the record before the FRB that Associated on January 16, 2026 applied to close yet four more branches, in Wisconsin and Illinois:
Associated Bank, NA 200 North Adams Street Green Bay WI Brown
Madison Galaxie Branch 828 East Washington Avenue Madison WI 53703 Dane 172576A
10910 MAIN STREET RICHMOND IL 60071 McHenry 118578A
Bank Mut - Rice Lake Office 2850 Pioneer Avenue Rice Lake WI 54868 Barron
Alton Branch 104 HOMER ADAMS ALTON IL 62202 Madison
Given that even before the proposed acquisition Associated is closing so many branches, it is imperative that Associated be asked - during the comment period, and for a public exhibit - its branch closing plans going forward. Even other FR Banks do this (see, e.g., FRB of Cleveland on Fifth Third, on which FFW commented, resulting in a list of 80 closures being made public, albeit after the comment period was allowed to close). We are writing now to avoid this - the question should be asked now, any AI letter that has gone out should be provided under the ex parte rules, or the lack of questions be explained.
On February 12, while dodging, Associated was asked and answered: "Target Bank was rated “Needs to Improve” for the Investment Test at its most recent CRA evaluation. Discuss how the combined bank would ensure satisfactory ratings for all CRA performance tests. As discussed in the Application, Associated Bank will: (1) expand its CRA assessment areas to include American National Bank’s existing assessment areas; (2) have its CRA and compliance personnel meet with their counterparts at American National Bank to better understand the details of American National Bank’s CRA investment activities, as well as the community needs in these assessment areas." Really?
Watch this site.
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