Green Dot Predatory Practices Covered Up by CommerceOne Redaction on AI FOIA Appeal

Green Dot Predatory Practices Covered Up by CommerceOne Redaction on AI FOIA Appeal by Matthew Russell Lee, Patreon Book Substack SOUTH BRONX/SDNY, July 17 – Green Dot Bank, the subject of extensive consumer complaints, proposes to split itself with its bank going with CommerceOne and its fintech business to (related) Smith Ventures.  Fair Finance Watch has filed opposition to the Federal Reserve.   "This is early opposition to the application of Compass Sub Northwest, Inc., Birmingham, Alabama "and others" to become a bank holding company by acquiring Green Dot Corporation, and thereby indirectly acquiring Green Dot Bank, both of Provo, Utah "and more." ... CommerceOne is a HMDA reporter - and lending only to whites, not to any African American...     There are extensive consumer complaints against the applicant(s) here; the FRB has taken the problematic position that even the CFPB complaint database is not "substantive." FFW objects, and requests a hearing. Ten days later, Sullivan & Cromwell submitted an entirely dismissive response, to which FFW immediately replied, with 2025 HMDA data and more - including S&C being slammed for misusing AI in court. And on May 7, the Fed asked CommerceOne / Compass Sub North questions, including "Describe specific actions New CommerceOne would take to strengthen and enhance Green Dot Bank’s complaints management program and to reduce the number of customer complaints the bank receives. Describe any new systems, additional staffing, and new operations New CommerceOne would implement at Green Dot Bank to strengthen and enhance its complaints management program. 6. Provide a detailed timeline New CommerceOne would expect Green Dot Bank to address each of the corrective actions of the Consent Order after the acquisition"  and saying, "Please provide a copy of the public portion of your response to the commenter, Mr. Matthew Lee." On Saturday, May 16 Sullivan & Cromwell sent Inner City Press a heavily redacted answer - information about Bill Smith removed, and any moves to address the predatory lending consent order. On Inner City Press' DocumentCloud here Inner City Press immediately emaild a FOIA request to the Board, which has yet to make a notice of appearance in the FOIA lawsuit against it. On June 25, embolded, CommerceOne redacted even more. Inner City Press immediately filed a FOIA request: This is an immediate FOIA request for CommerceOne's and its subsidiaries' June 25 responses to the June 12, 2026 Additional Information questions posed by the FRS in connection with its application to acquire Green Dot Bank.    The FRB has taken to deeming confidential certain of its Additional Information questions, which Inner City Press is challenged.    Now, emboldened, CommerceOne is redacting nearly all of tis answers, on Artificial Intelligence and consumer protection - copy attached. The FRB asked CommerceOne in Question 1 how it intends to utilize artificial intelligence and to provide a copy of its AI Policy. The public version of CommerceOne's response contains no substantive answer to this question — only a blank section following the question's text. The AI policies and practices of a bank holding company applicant seeking to acquire Green Dot Bank, a fintech-oriented institution serving millions of low- and moderate-income prepaid card customers, are matters of direct public and consumer protection interest. Inner City Press specifically requests the full unredacted text of CommerceOne's response to Question 1 and a copy of CommerceOne's AI Policy as submitted to the Board. (This is a challenge to all of the redactions). The public version of CommerceOne's response to Question 8(d) — addressing BSA/AML monitoring responsibilities at Green Dot Bank post-acquisition — is entirely deflected to Confidential Exhibit 3. Green Dot Bank is currently operating under a Cease & Desist Order issued by the Board on July 19, 2024, specifically citing deficiencies in risk management, compliance, and BSA/AML programs and controls. How CommerceOne plans to remediate those BSA/AML deficiencies at a bank it proposes to acquire is not a commercially sensitive business strategy — it is a federal regulatory compliance obligation of direct public concern. Inner City Press requests the full unredacted response to Question 8(d) and the portions of Confidential Exhibit 3 addressing BSA/AML roles, reporting lines, and monitoring programs. The public version of CommerceOne's response to Question 7(b) — seeking projections of the financial impact on Green Dot Bank's balance sheet from planned growth strategies — is redacted entirely into Confidential Exhibit 4. Likewise, Question 10 (dollar amount of financial resources allocated to Green Dot Bank's compliance management system) and Question 11 (compliance staffing levels) are entirely deflected to confidential exhibits. The financial resources being allocated to remediate a bank under a federal Consent Order, and the projected balance sheet of the combined institution, are matters the public must be able to evaluate during the comment period. Inner City Press requests the full unredacted text of CommerceOne's responses to Questions 7(b), 10, and 11, and the relevant portions of Confidential Exhibit 4 addressing the post-closing governance, remediation, and oversight framework.  As noted in the examples above, these are specious confidentiality requests, encouraged by the FRS' increasing withholding of consumer protection questions, including all questions to Enova in the ongoing Grasshopper Bank proceeding (which has given rise to a FOIA lawsuit. By that same logic we are hereby challenging the withholding of these CommerceOne responses, and ask for a ruling as quickly as possible, certainly before any action other than denial is taken on the application.   The Fed after nearly a month unredacted some, but withheld most information. So, a FOIA appeal. Watch this site. *** Your support means a lot. As little as $5 a month helps keep us going and grants you access to exclusive bonus material on our Patreon page. Click here to become a patron. Feedback: Editorial [at] innercitypress.com Mail: Box 130222, Chinatown Station, NY NY 10013 Other, earlier Inner City Press are listed here, and some are available in the ProQuest service, and now on Lexis-Nexis.  Copyright 2006-2026 Inner City Press, Inc. To request reprint or other permission, e-contact Editorial [at] innercitypress.com