| As Colony
Bankcorp Tries First Reliance
in South Carolina Fair Finance
Watch Writes FDIC
by
Matthew Russell Lee, Patreon Book
Substack SOUTH
BRONX/SDNY,
July 11 รข Colony Bankcorp of
Georgia (and Alabama and
Florida) proposes to expand
into South Carolina by buying
First Reliance Bank. Fair
Finance Watch, after the FDIC
thumbed its nose at the
Community Reinvestment Act by
eliminating public notice of
branch application, has
commented to the FDIC on the
2025 HMDA data of Colony
Bank - and on the scam: Dear Regional
Director Servaes, Deputy
Brown, Assistant Mohammed and
others at the FDIC: This is a
timely comment opposing and
requesting an extension of the
FDIC's public comment period
on the proposal by Colony Bank
to buy and merge with First
Reliance Bank. Fair
Finance Watch, which has
commented to the FDIC that its
lawless decision to eliminate
public notice of branch
applications violates the CRA,
noting the FDIC's rationale
that it receives few public
comments, hereby timely
informs the FDIC of this,
using the 2025 HMDA data put
in the CFPB website less than
a month ago: In 2025 in
Georgia, Colony Bank made 604
loans to whites, with only 31
denial, and only 124 loans to
African Americans with fully
12 denials. This is disparate.
In 2025 in
Alabama, Colony Bank made 18
loans to whites, and only ONE
loan to an African Americans.
This is disparate. In 2025 in
Florida, Colony Bank made 82
loans to whites, and only TWO
loans to African Americans.
This too is disparate. Colony Bank's
2025 data was published less
than one week ago. No other
organization has yet analyzed
these numbers. Fair Finance
Watch is submitting them to
the FDIC now, because the
Federal Deposit Insurance
Corporation has an obligation
to evaluate whether an
institution seeking to expand
into a new state has met the
credit needs of its existing
communities. These numbers
show it has not. Public
hearings should be held.
FFW notes
again in the FDIC's 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
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, and
proposed mergers like this
one. But now the
Federal regulator(s) blithely
have eliminated 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. Your
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