Friday, July 31, 2026

As OCC Moves on CRA Fair Finance Watch Opposes MidFirst Bid on Dallas Capital Bank on Disparities

FEDERAL COURT, July 27 –   As the Office of the Comptroller of the Currency along with the FDIC takes aim at the Community Reinvestment Act, the OCC is encouraging merger applications from disparate lenders, with little transparency. On July 27 Inner City Press comments to the OCC:

Office of the Comptroller of the Currency Attn: Director for Licensing for Midside Banks Astrada et al
400 7th St., SW Washington, DC 20219 

Re: Comment Opposing Applications by MidFirst Bank to acquire Dallas Capital Bank 

Dear Director Astrada, Comptroller Gould and others at the OCC:  

This is a a timely comment opposing the Application by MidFirst Bank to acquire Dallas Capital Bank, which appears on the OCC's website with a comment period running through August 21. This comment is timely. 

     The applicant MidFirst Bank in Oklahoma in 2025 made 429 mortgage loans to whites while denying 231 applications from whites - versus only 12 loans to African Americans, with fully 13 denial to African Americans. This is disparate. Public hearings are needed.    These practices should not be allowed to expand.  

The target Dallas Capital Bank appears to report no HMDA data. In Texas in 2025, MidFirst Bank made 195 mortgage loans to whites versus only 28 loans to African Americans. This too is disparate. Public hearings are needed.  Inner City Press is requesting an extension of the public comment period, public / virtual evidentiary hearings and that, on the current record, the applications not be approved.   

  FFW and Inner City Press have been deeply concerned about the rush by the OCC's to rubber-stamp mergers by redliners, money launderers and predatory lenders. This has been killing the Community Reinvestment Act and we timely request public hearings. [Our timely comments on the evasion of CRA for fintechs by Column NA has still not been responded to]. 

We note now in July 2026 reports that the OCC and FDIC intend to go further back on CRA then the previous reg, and de facto exempt many many banks based on size - we oppose that in advance.  The comment period should be extended; evidentiary hearings should be held; and on the current record, the application should not be approved.   Please immediately send all requested information -- including a complete copy of the application, during the comment period -- and responses by e-mail

  Please also confirm receipt of this formal submission. If you have any questions, please immediately telephone the undersigned, at (718) 716-3540.   Very Truly Yours,     Matthew Lee, Esq.  Executive Director Fair Finance Watch

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