| FDIC Has Violated
Community Reinvestment Act
As Now No Public Notice of
New Branches
by
Matthew Russell Lee, Patreon Book
Substack SOUTH
BRONX / SDNY COURT,
March 6 รข The
Community Reinvestment Act
directs bank regulators to
consider banks' records of
lending in poor neighborhoods
when they apply to expand with
mergers or, right in the
statute, branches ("deposit
facilities"). But in August
2025 the Federal Deposit
Insurance Corporation quietly
moved to eliminate public
notice of, and public comment
on, banks' branch
applications. While Inner City
Press filed Freedom of
Information Act requests; Fair
Finance Watch commented to the
FDIC, on the proposed change -
and on sample current branch
applications pending. The
American Banker of September
10 ran FFW's op-ed, here But
contemptuous of the law, now
on March 6, 2026 the FDIC's
online list of application to
which the CRA applies - which
it does, to branch
applications - lists no branch
applications at all.
This is entirely lawless. It
does however list mergers,
which the FDIC seems poised to
rubber stamp, ever faster.
Watch this site. Filed in
August, 2025: On behalf of
Fair Finance Watch and in my
personal capacity this is a
timely comment opposing -
including as illegal - the
FDIC's proposals in RIN
3064-AG10. The
Community Reinvestment Act
specifies that "the
appropriate Federal financial
supervisory agency shall (1)
assess the institution's
record of meeting the credit
needs of its entire community,
including low- and
moderate-income neighborhoods,
consistent with the safe and
sound operation of such
institution; and (2) take such
record into account in its
evaluation of an application
for a deposit facility by such
institution."
That is, the only enforcement
mechanism of CRA is its
consideration on applications
for deposit facilities:
branches. But now
the FDIC blithely proposes to
eliminate public notice and
public comment on branch
applications. This is
blatantly against the CRA.
Ironically, the FDIC's
reasoning is that few comments
are filed. So, that must
change. And is: consider,
among currently pending branch
applications, these: the
pending application by
Somerset Trust Company to
expand with a deposit facility
at 3894 State Route 981 MOUNT
PLEASANT, PA. The application
is listed as filed on August
20 with a comment period
running through September 11:
(and for a deposit facility at
11361 Route 30 IRWIN, PA. The
application is listed as filed
on August 20 with a comment
period running only through
September 4 FFW has reviewed
the 2024 HMDA data - not in
any CRA evaluation - of
Somerset Trust Company. In
Pennsylvania in 2024 it made
754 mortgage loans to whites
and only ONE to an African
American. * * * the pending
application by Harmony Bank to
expand with a deposit facility
at "Suite 400 MIDLOTHIAN, TX"
- no street address is given
[!]
FFW has reviewed the 2024 HMDA
data - not in any CRA
evaluation - of Harmony Bank.
In Texas in 2024 it made 27
mortgage loans to whites and
NONE to African
Americans. * * * Gulf Coast
Bank and Trust Company for a
branch at 25910 Canal Road
ORANGE BEACH, AL. The
application is listed as
somehow received on September
1 with a comment period
running through September 19.
FFW has reviewed the 2024 HMDA
data - not in any CRA
evaluation - of Gulf Coast
Bank and Trust Company. In
Louisiana in 2024 it made 726
mortgage loans to whites and
denied only 107 applications,
1 to 7. For African Americans,
220 loans and fully 54
denials: approximately 1 to 4.
Worse in Alabama in 2024 Gulf
Coast Bank and Trust Company
made loans only to whites,
none to African
Americans. * * * the pending
application by TexasBank
to expand with a deposit
facility at 300 West Seventh
Street, FORT WORTH, TX. The
application is listed as filed
on August 21 with a comment
period running only through
September 15. FFW has reviewed
the 2024 HMDA data - not in
any CRA evaluation - of
TexasBank. In Texas in 2024 it
made 1158 mortgage loans to
whites and only FIVE to
African Americans.
There are
more. And there
will be more - comments. Watch this site.
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