by Matthew Russell Lee, Patreon Book Substack
Federal Court, Feb 9 – As banks rush to merge given rubberstamping signals from US regulators, LinkBank has done too far with Burke & Herbert. Back in 2023 Fair Finance Watch got the FDIC to impose a Community Reinvestment Act condition on LINKBANK, here.
Now with no indication of compliance, LINKBANK proposes to sell itself to also-disparate Burke & Hubert. FFW on December 22 filed challenges with the Federal Reserve Board and FDIC. FRB version:
Dear Chairman Powell, Secretary Misback: This concerns the proposal by Burke & Herbert to acquire LINKBANCORP and LINKBANK.
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 Burke & Herbert is applying to the FRS, and consider this comment on any and all Burke & Herbert applications.
FFW previously raised disparities of LINKBANK to the FDIC - resulting on a CRA condition being opposed on October 3, 2023. It is imperative that compliance be reviewed, including at the requested public evidentiary hearing. Given recent developments, there is no reason to believe that the FDIC would or will enforce even its own conditions.
Burke & Herbert in Virginia in 2024 made 83 mortgage loans to whites, and only SEVEN to African Americans. Meanwhile it denied two applications from African Americans, and only four from whites. This is disparate.
Burke & Herbert in West Virginia in 2024 made 165 mortgage loans to whites, and only TWO to African Americans. Meanwhile it denied one application from an African Americans, and only 29 from whites.
Burke & Herbert in Maryland in 2024 made 18 mortgage loans to whites, and only TWO to African Americans.
Now Burke & Herbert wants to buy LINKBANK, on which FFW had a CRA condition imposed. The FDIC wrote: CRA Protest In the course of reviewing public input on the application, the FDIC received an adverse comment from a protester that was considered a CRA protest... the FDIC decided to approve the application with the following condition.
On January 7, the FRS wrote back: "The Federal Reserve Bank of Richmond received your correspondence on December 23, 2025, regarding a future application by Burke & Herbert Financial Services Corporation (“B&H”) to acquire LINKBANCORP (“LINK”). The Federal Reserve has not yet received an application by B&H to acquire LINK. Accordingly, no immediate action will be taken on the correspondence dated December 23, 2025. If a filing is received in the next three months, your comment may be considered as part of the application record for the filing."
MAY be considered?
Jump cut to February 9, when the Fed asked the applicant questions, including about branch closing (will they be withheld, unlike on Fifth Third - Comerica) and this:
"In Confidential Exhibit G to the Interagency Bank Merger Act Application, Applicant discussed steps taken by LINKBANK to implement the Fair Lending and CRA Action Plan (“Plan”) implemented in response to a condition imposed by the FDIC in September 2023. Discuss whether the combined organization will adopt any of the practices implemented by LINKBANK under the Plan and, if so, which. Include in your discussion any plans for staff hired by LINKBANK in connection with the Plan or staff responsible for implementing the Plan."
Watch this site.
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