California Reinvestment Coalition Recommendations on Updating the Community Reinvestment Act

Community reinvestment act 2

Fact Sheet: Community Reinvestment Act Recommendations

To truly meet community needs, CRC members believe the CRA should be improved and strengthened. In a recent survey, 100% of members said that the level of CRA activity in their community needed improvement and that there was considerable room for banks to do more.

CRC recommends that CRA be reformed so that:

1. CRA implementation encourages, not discourages, reinvestment in rural areas. California is home to numerous rural reinvestment deserts, where a lack of lending and investment prevents communities from thriving economically. And yet, many of these areas already have bank branches and are included in bank CRA assessment areas. Regulators subject bank CRA activity in these areas to a lower level of scrutiny, as banks are able to denote these areas as subject to only “limited scope” review. For example, Bakersfield, California, has numerous bank branches, and those banks have CRA obligations in the city. However, these same banks are examined for their CRA activity far more closely in other, more urban areas of the state. This creates fierce competition, for example, for housing tax credit deals in urban areas, while rural projects struggle to find financing. Instead, regulators should ensure that the banks with the largest deposits in a given MSA are subject to a full scope review in that MSA.

2. Regulators should encourage banks to develop transparent, multi-year CRA Plans that reflect significant public input and that include measurable goals, such as tying reinvestment activity to a percentage of bank deposits. Banks are supposed to help meet community credit needs. And in many bank merger applications, banks must demonstrate that the merger will provide a community benefit. The public input process is critical to this assessment.

However, community input has been diluted, and is not sufficiently sought and considered under current CRA implementation, as an example, very few mergers will even have public hearings. Mergers most often lead to diminished resources for communities as 1 + 1 rarely equals 2 in terms of reinvestment. That is why a comprehensive review of mergers is so important, complete with strong community input and mitigation of any harm the merger may cause in the form of decreased reinvestment or reduced access to banking services or branches.

Regulators should encourage CRA plans, particularly in the context of mergers that must show a clear public benefit to the community. Strong and meaningful CRA plans reflect community input about community credit needs, motivate banks by setting strong goals for lending, investment and services, and allow communities to work in partnership with banks to ensure that they are treated equitably and fairly by financial institutions. CRA plans are a best practice that have resulted in significant gains for communities in the past few years. Strong CRA plans can help demonstrate that a merger will have a public benefit.

3. Banks should be downgraded for causing, enabling, or financing harm in communities, taking into account discrimination, and equity stripping conduct and transactions that lead to displacement. The CRA calls for an assessment of how well or poorly a bank is meeting community credit needs. This analysis must include an assessment of fair housing and related factors. Regulators should conduct a comprehensive review of a bank’s community impact. Wells Fargo is but the most recent example to demonstrate that simply investing in the community is insufficient- banks must also not cause harm or break the law.

For a regulator to give a bank a passing CRA grade while the bank engages in discriminatory lending would be to endorse discrimination. Further, a high CRA rating for a discriminatory bank could result in consumers being directed to a bank with an inflated CRA rating, only for the bank to potentially overcharge the consumer or deny that person a loan. In this way, regulators would abuse the public’s trust in its ratings.

Bank regulators should consider expensive overdraft programs and excessive reliance on fee revenue generated at the expense of the most economically vulnerable consumers as a basis for downgrading a bank in a CRA service test evaluation. Similarly, banks should be downgraded for financing high cost, predatory lenders, and for contributing to gentrification and displacement. Banks should also suffer CRA rating downgrades as a result of any involvement in the REO to Rental craze, which results in first time homebuyers being outbid by cash investors, tenants being displaced by Wall Street landlords, and neighborhoods losing long term residents as well as racial and income diversity.

4. Encourages banks to open and maintain branches in LMI and rural areas. Bank branches remain a critical part of how banks serve communities, and inequitable distribution of branches must be considered as part of the CRA service test. Critically, regulators cannot allow the industry’s preference for technology to result in fewer branches and shrinking CRA assessment areas, footprints, and obligations in LMI communities. Additionally, many LMI neighborhoods and communities of color not only lack access to bank branches, but also to a wide range of banking products and services, including ATMs.  Regulators should analyze whether banks are meeting the banking needs of all communities in their assessment areas.

Regulators should also consider how banks can better reduce the number of unbanked or underbanked consumers within their assessment areas. Moreover, banks should quantify the extent to which LMI bank customers are able to keep their accounts open and in good standing over time, or if their customers are pushed out of the bank by overdraft fees or other barriers. Low cost bank accounts should be offered and accessible to LMI consumers, including through bank acceptance of municipal identification cards and other accessible forms of ID.

5. Assessment areas should include areas where banks have branches, or where a significant number of their customers and depositors live. Regulation has lagged behind market innovation. Requiring reinvestment only around retail branches makes much less sense today, when internet, credit card, and fintech banks operate nationally but reinvest only in Salt Lake City or another headquarters location.

Assessment areas should be expanded to include areas where a substantial portion of a bank’s depositors and borrowers reside. At the same time, banks should not be allowed to receive additional CRA credit for lending or investing outside of the bank’s CRA assessment area, beyond the accommodation made to banks by regulators during the last CRA Questions and Answers review. This will only lead to a dilution of investment in LMI neighborhoods that are most in need of reinvestment. The primary purpose of the CRA is to serve communities where the bank is doing business, not to encourage reinvestment where it is easiest to do. Banks should not be able to circumvent obligations to serve the communities in their assessment areas. The focus of bank CRA should remain on LMI individuals and communities.

6. CRA examinations should consider and reflect new small business lending data that the CFPB will be overseeing. Small businesses are the lifeblood of our economy, prime job creators, and bulwarks of the community. Yet small business owners benefit from fewer protections than homeowners. HMDA data has been collected for years, and used to inform CRA examinations, without problem or incident. Small business owners should also benefit from a comprehensive and unified lending data collection system.

CRC members strongly support Congress’ charge in Dodd-Frank that §1071 small business lending data be collected in order to facilitate enforcement of fair lending laws and enable communities, governmental entities, and creditors to identify business and community development needs and opportunities of women-owned, minority-owned, and small businesses. Such data collection and dissemination will surely make affordable credit more accessible to all small businesses, and will inform CRA examinations.

A recent CRC survey of our CDFI, community lender and technical assistance provider member organizations revealed that small business clients still face discrimination; are pushed by banks towards higher priced credit cards; are frequently targeted for nonbank credit products (like Merchant Cash Advances), and are in need of greater access to affordable, safe, and transparent credit.

7. Banks serve all segments of the community, including the immigrant community. Banks can and should serve the immigrant community by directly providing loans and investments to immigrants, and by supporting community lenders and other organizations that serve the immigrant community. Immigrant community members have significant unmet credit needs, whether it is a safe place to save money, a loan to buy a house, purchase a car, start a businesses, or pursue a citizenship application.

Banks should ensure that employees represent the diversity of their service areas, and make translation, interpretation and related language access services available to all potential clients. Banks should make loans and investments accessible to all community members, and invest and support community lenders and other organizations that serve the immigrant community.

8. The bank examination process can be improved so that years do not go by after an examination before the pubic rating is released. The regulators should hire additional examiners and provide enhanced training to ensure that there is consistency in the examination process across agencies and examiners. CRC believes that a primary reason behind the delay in the public release of CRA ratings is the propensity of banks to challenge and appeal initial CRA ratings by regulators. This process should be reformed to limit the circumstances in which a bank can challenge a rating, and the public should be given an opportunity to comment on the appeal when a bank invokes this otherwise opaque process. It is of critical importance that regulators set high standards of review.

To make CRA meaningful, regulators have to end the long history of CRA grade inflation so that poor CRA performance will be reflected in CRA ratings. Streamlining the process while lowering the examination bar will only lead to less investment, more harm to communities, and potentially, to greater risk in the US financial system. We saw this happen in the years leading up the financial crisis, when regulatory agencies competed against each other to attract banks to their charters, fueling a regulatory race to the bottom, and leading ultimately to the failure of several savings and loans and the end of the Office of Thrift Supervision.

Asian Inc Testimony at OneWest and CIT Group Merger Hearing in Los Angeles

The testimony of Michael Chan, president of Asian Inc, about the proposed OneWest and CIT Group merger is featured in its entirety below. If you were unable to attend the hearing, CRC live-blogged it here and you may also find our CIT Group/OneWest Merger resource page helpful as well. Pictures are available here.

Federal Reserve Hearing for CIT Group Acquisition of OneWest

Thursday, February 26,2015

Federal Reserve Bank, 950 South Grand Avenue,

Los Angeles, California 90015

Thank you for giving me this opportunity to provide my statement.  My name is Michael Chan and I am the President of ASIAN, Inc., a nonprofit tax exempt corporation that seeks to empower our disadvantaged Asian American Pacific Islander and other racial minority communities by removing obstacles to their socio-economic advancement in California.

Over our last 43 years, we have developed over 1,000 affordable housing units.  We assisted over 15,000 Low to Moderate (LMI) persons with Limited English Proficiencies secure homebuyer education, foreclosure counseling, and financial literacy training in Northern California.  We also operate 3 Minority Business Development Agency Business Centers in San Francisco, San Jose and Fresno, where we have assisted hundreds of minority businesses secure hundreds of millions of dollars in contracts and capital.  We have compiled a significant track record that illustrates our deep understanding of the broad community reinvestment issues that are being discussed here today.

Based on our humble experiences, ASIAN, Inc. is compelled to currently oppose the CIT Bank merger due to what we see are significant flaws and limitations in the CIT Bank CRA Benefits Plan which in our opinion can and should be remedied by CIT Bank.

We understand this this is a unique merger of a retail bank, OneWest Bank, based in Southern California, and an internet bank, CIT Bank, which can accept deposits from anywhere.  This poses some unique CRA challenges, particularly regarding the basic fundamental CRA tenet that deposits collected from a community need to be reasonably reinvested back into that community.

With significant deposits being made over the Internet to CIT Bank in conjunction with deposits received at OneWest Bank branches in Southern California, it is good to know that CIT Bank will recognize Internet deposits in Southern California for reasonable reinvestment in Southern California.  This is a good start.

This also says that CIT can track where Internet deposits are coming from not only in Southern California but anywhere else in and outside of California.  Given that there is a consensus within the community development leadership that where deposits are taken is where those deposits need to be reasonably reinvested.

The proof is on CIT Bank to show that their CRA Benefits Plan can address the reinvestment of deposits received outside of Southern California back into reinvestments that impact disadvantaged LMI communities from where these deposits came from.  The reinvestment needs are just as severe in Fresno, Stockton, Sacramento, Oakland, San Francisco, East Palo Alto, San Jose and other California localities as they are in Southern California.

Otherwise endorsement of the CIT CRA Benefits Plan as-is with its presumed flaws would send the wrongful message that de facto redlining via the Internet cannot be prevented.

This would be a tragic precedent for CRA rankings for internet banks.  Their CRA Plan needs to be revised to address this systemic imbalance between the location of deposits and where community reinvestments are made.  This is where the CRA regulations are maybe a step behind internet banking and need to protect the intent and integrity of the CRA Act.

We all want to avoid redlining as an unintended consequence. This is why it is so very important to require CIT Bank to develop a more transparent, realistic and comprehensive CRA Benefits Plan that will benefit all of California’s disadvantaged, culturally diverse, and Limited English proficient LMI communities that have deposits with CIT Bank.

Community Bank Advocates Give Input on EGRPRA (Economic Growth and Regulatory Paperwork Reduction Act)

EGRPRA Hearing

Kevin Stein quips that the system, like his wrist, is broken.

You can watch the community panel here.  (discussion begins at 17:40 into the video)

Yesterday, community advocates attended a meeting in Los Angeles, hosted by the three main bank regulators, the Federal Reserve, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation.  As part of the Economic Growth and Regulatory Paperwork Reduction Act of 1996, the meeting focused on identifying regulations that are outdated, unnecessary, or unduly burdensome while also balancing the regulator’s jobs to ensure the safety and soundness of the financial system.

After three panels with representatives from banks, a fourth panel consisted of community representatives.

Kevin Stein, associate director at the California Reinvestment Coalition, was one of the panelists.

A few takeaways from the meeting with community panelists include:

  1. The current rules need to be updated to reflect new bank practices.  Using CIT Bank as an example, some Internet banks are evading the requirements to reinvest in the communities where they accept deposits.  For example, while CIT Bank accepts $14 billion from around the US, it only reinvests those deposits near its Salt Lake City headquarters. See more here: Coalition Asks Bank Regulators: “Is There Community Benefit In OneWest And CIT Group Bank Merger?
  2. Dialogue is important between regulators, communities, and banks.  One good way to do this is through public community benefit and reinvestment plans.  To see an example of a recent one, look at Banc of California’s Community Benefit and Reinvestment plan.
  3. Bank regulators could provide negative credit to banks during their CRA exams for engaging in practices that are harmful to their communities- for example through financing payday lenders and other abusive lenders, or financing practices such as REO to Rental, which is hurting first-time homebuyers, displacing long-term tenants, and changing communities.  More about that here: 80 Organizations Ask Federal Gvt. to Address Investor Cash Flooding Into Neighborhoods   Another harmful practice can be seen in the example of OneWest bank foreclosing on widowed homeowners who have reverse mortgages serviced by Financial Freedom- a OneWest subsidiary. More examples of that here: HECM Non-Borrowing Spouses Renew Class Certification Attempts  and here: 103-Year-Old North Texas Woman Fights To Keep Her House  You can hear Sandy Jolley discuss Financial Freedom at the meeting here (move cursor to 1:10:18).
  4. Following their playbook BEFORE the our foreclosure crisis, banks are continuing to try and use preemption as a means to evade state consumer protection laws– for example, the California Homeowner Bill of Rights.  More on that here: Saving the Homeowner Bill of Rights 
  5. Some of the people most impacted by banks also may be the least likely to hear about bank mergers.  As an example, the California Reinvestment Coalition has begun hearing from consumers harmed by OneWest Bank and its subsidiary Financial Freedom because they have seen stories in the media about this proposed Too Big To Fail merger.  However, they are being told by the Federal Reserve that their comments “aren’t timely.”
  6. When banks leave communities, harmful financial service companies move in– like payday lenders, check cashers, and car title lenders. See CRC’s report about the high percentage of payday lenders in San Joaquin Valley as compared to banks: New Report Documents Lack of Banking and Financial Services in the San Joaquin Valley)

Interested in seeing more?  Read this press release: Community Advocates Urge Bank Regulators to Update Regulations (EGRPRA)


Regulation of Banks

How to Update the Community Reinvestment Act


Today, the three primary bank regulators are holding a meeting in Los Angeles, focused on identifying regulations that are outdated, unnecessary, or unduly burdensome. The meeting is being held as part of the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA). Bank regulators are looking to balance regulatory burden with their duty to ensure the safety and soundness of the financial system.

The invited panelists on the first three sessions at the meeting are bankers. The fourth session includes representatives from community-based organizations who will speak about updating regulations like the Community Reinvestment Act (CRA).

Community panelists are expected to speak about issues including:

  1. Updating regulations to respond to new technologies and practices;
  2. Transparency with bank CRA plans;Public benefit (or lack thereof) as a result of bank mergers;
  3. Fair housing and credit issues; and
  4. Grade inflation with CRA exams, with 96% of banks receiving a “satisfactory” or higher rating since the inception of the CRA, according to the Congressional Research Service.

Kevin Stein, associate director at the California Reinvestment Coalition, one of the community speakers, explains:

“This may be one of the few times when we agree with the bankers in the room- at least on a few points. The CRA is outdated, doesn’t reflect current bank practices, and fails to protect consumers and communities. As an example, CIT Bank accepts $14 billion in deposits from around the US (via the Internet), but gets away with only reinvesting that money into communities near its Salt Lake City headquarters. CIT’s proposed merger with OneWest Bank also raises questions about public benefit with bank mergers, regulator transparency, and serving community credit needs.

Regulators should update the CRA to address Internet deposits and their corresponding assessment areas, improve CRA exams to also account for harmful banking practices (for example by giving banks negative CRA credit), and should increase transparency into bank CRA plans and bank mergers so the public can provide meaningful input.”

Sandy Jolley, a reverse mortgage consumer advocate who has worked with senior homeowners and their families harmed by reverse mortgages, is attending the event and adds: “I’m interested to see how regulators discuss harmful products and practices (like reverse mortgages) in the context of measuring whether or not banks are meeting community credit needs.”

Sasha Werblin, economic equity director with the Greenlining Institute, also a panelist, explains: “Regulators must develop better methods for involving the public in analyzing how banks serve consumers. One immediate way to do this is for regulators to hold public hearings before every significant bank merger. Hearings would ensure that regulators and the public have a dialogue about how banks operate for the public benefit, community credit needs, and banking practices that help — and hurt — consumers.

Edmundo Hidalgo, president and CEO of Chicanos Por La Causa, a panelist on the consumer panel, comments on the impact when banks leave communities: “As banks have left, our communities have been flooded with high-cost “alternatives” that are far more expensive and risky for consumers. Regulators should start by focusing on the extent to which banks are culpable for the expansion of fringe lenders like payday lenders, whether through their abandoning low-income communities, or in some cases, providing cheap financing to companies who extend high-cost, dangerous credit products like car title or payday loans.”

Additional Context:

In September, the three bank regulators (FDIC, OCC, Federal Reserve) asked for public comment on proposed changes to the Interagnecy Questions and Answers Regarding Community Reinvestment. The California Reinvestment Coalition provided suggested improvements, CRC’s full letter can be viewed here.

A July 2014 report from the Congressional Research Service cites some of the long-standing concerns community advocates have had with the CRA, including grade inflation because regulators look to a bank’s peers instead of looking at a community’s needs when judging a bank’s CRA record. Report: The Effectiveness of the Community Reinvestment Act

Advocates Announce 5 Days of Questions about CIT Group and OneWest Bank Merger

OneWest Bank Merger

The California Reinvestment Coalition announced a new campaign today to increase the public’s awareness of a proposed bank merger combining CIT Group with OneWest Bank.  The merger, if approved, would create a nearly $70 billion, Systemically Important Financial Institution (SIFI), AKA a Too Big To Fail bank, in Southern California.

A SIFI is a financial institution that is so large, over $50 billion in assets, that its failure could trigger another financial crisis. In this newest proposed bank merger, banking regulators are being asked to approve the union of two banks with troubled histories, OneWest Bank and CIT Group, to form the country’s newest Too Big To Fail bank.

CIT Group, headquartered in New Jersey, is proposing to buy OneWest Bank, headquartered in Pasadena, California. The two banks both have a checkered past. CIT Group took $2.3 billion in TARP funds just a few months before it declared bankruptcy, which meant CIT Group never repaid the $2.3 billion it received from the US Government.OneWest was formed from the ashes of one of the largest bank failures in history, Indymac Bank. Indymac was seized by the FDIC after depositers made a run on the bank in 2009. The FDIC later sold IndyMac at a discount to a group of investors: IMB Holdings Inc. These investors now stand to double their money, and community groups want to know if the regulators are going to ensure there is public benefit and not just investor gain as a result of the merger.

The first of several deadlines for public input to regulators was last Friday, and the California Reinvestment Coalition (CRC) and 25 community organizations sent letters to the New York Federal Reserve Bank, opposing the merger and asking regulators to hold hearings in Los Angeles. CRC’s detailed letter to the Federal Reserve Bank of New York includes a preliminary analysis of the merger and a long list of concerns and unanswered questions about the proposed merger.

Kevin Stein, associate director of CRC, explains: “A recent tape recording of bank regulators coddling the banks they’re supposed to regulate has reduced the public’s confidence that regulators are watching the store. This merger of two banks who required massive government bailouts adds to those concerns because it is an example of investors profiting while communities are left holding the bag. We are urging the bank regulators to conduct their due diligence on this merger which will create a $70 billion institution, and hold hearings in Los Angeles. If there’s not a clear community and public benefit, and instead only a continuing subsidy of the largest institutions and investors, the merger shouldn’t happen.”

As part of the public awareness campaign, the California Reinvestment Coalition will shine a light on five troubling themes about the merger (a new theme each day) as part of a broad public awareness campaign.

On Day One, CRC members are asking regulators: “What (if any) are the public benefits in allowing the creation of another Too Big To Fail Bank?”

CRC is urging regulators to answer the following questions about the public benefit (or lack thereof) of the merger.

• In a merger of this kind, regulators are required to assess the benefits of the merger against the risks created by it. Given the troubled history of the two banks, including the damage caused to communities through the tens of thousands of foreclosures by OneWest bank, and the unpaid $2.3 billion given to CIT Group through TARP, are regulators going to ensure that the newly merged bank has a community benefit and reinvestment plan in place that is commensurate to its new size? How will regulators weigh the risks to the financial system by the creation of a new SIFI bank, especially since taxpayers and communities have already paid for previous risks created by these two institutions?

• Will regulators ask the leadership at the banks why it has set CRA goals in community development and investments that it appears the banks may have already met? Isn’t that bar too low for a bank this large?

• Only fifteen percent of OneWest bank branches are in low and moderate-income census tracts. Based on this measure and others, CRC members believe OneWest Bank is already failing to meet the needs of low and moderate income Californians. How would this new bank merger change that? Should low and moderate income Californians expect to see any benefit from this merger? Why should low income communities accept OneWest’s promise to serve them through mobile banking instead of brick and mortar branches when other communities get both?

• The majority of “small business” loans currently made by OneWest bank are to businesses with over $1 million in revenue. Small businesses create local jobs, strengthen local communities, and are an asset building tool for families. As part of the merger, will the regulators ensure that the bank has a plan to increase its focus on small business lending to smaller businesses (those with less than $1 million in revenue annually)?

• Why have the banks not established clear goals for contracting with Minority, Women, and Disadvantaged Business Enterprises vendors? Does the leadership value contracting with these businesses? If so, why aren’t there any clear benchmarks in the bank’s CRA plan?

Tomorrow’s questions for regulators will focus on the loss-share agreements the FDIC gave to the purchasers of IndyMac bank, the fact that the banks are now asking the FDIC to transfer the agreements to CIT Group, and how much money the FDIC has paid out under these loss-share agreements.

For a copy of CRC’s letter to the Federal Reserve Bank of New York, click here: CRC letter to FRBNY

How Much Money Has the FDIC Paid to OneWest Bank Investors Under Loss Share Agreements?

CIT Group Merger with OneWest Bank

Will CIT Group and OneWest deal creating another TBTF bank be approved?

Have you followed the recent news (Community Group to Oppose CIT-OneWest Deal) about a proposed merger of CIT Group and OneWest Bank?

Do those names sound familiar to you?

When IndyMac Bank failed, the FDIC sold it to a group of investors, including John Paulson, an investor who made billions of dollars betting that the housing market would collapse.  As part of the purchase, the FDIC offered a “loss-share” agreement to the new owners of IndyMac.  You can read more about loss-share agreements on the FDIC website.

The investors who bought IndyMac bank renamed it OneWest bank.

CIT Group, headquartered in New Jersey, is proposing to federal regulators to purchase OneWest bank.  The newly merged bank would have almost $70 billion in assets, placing it in the Systemically Important Financial Institution (SIFI) category.  That’s regulator speak for “Too Big to Fail.”

CIT Group received $2.3 billion in TARP funds, but then declared bankruptcy, meaning they never paid back the $2.3 billion.

CIT Group is led by John Thain, the same man who spent over $1 million redecorating his office at Merrill Lynch while the company was faltering.  It would later be sold to Bank of America.


CIT Group received $2.3 billion under TARP that it never repaid.

It’s unclear if the FDIC would continue the loss-share agreements it has with OneWest bank after this merger is completed.  So, CRC submitted a Freedom of Information Act (FOIA) request to the FDIC.

We asked for the following information from the FDIC:

1) Documents that reveal the amount and timing of payments from
the FDIC to OneWest under the March 19, 2009 shared-loss
agreement (Indymac), and any shared-loss agreements relating to
the OneWest purchase of La Jolla Bank F.S.B. and First Federal
Bank of California, F.S.B.

(2) Documents supporting these payments, including as documented in
the “Loss Share Data Specification” templates by OneWest to
receive payments from the FDIC under the shared-loss agreement
or agreements and any documents submitted to or produced by the
FDIC in their process of monitoring OneWest’s compliance with
the terms of the shared-loss agreement or agreements.

(3) All documents that contain correspondence between OneWest and
the FDIC with regard to their participation in loan modifications
programs as required by the share-loss agreement or agreements.

(4) All documents containing correspondence between the FDIC and
CIT Group and/or OneWest and its affiliates and representatives
relating to the possibility of transferring shared-loss agreements.

(5) Criteria used by the FDIC in determining whether to approve the
transfer of a shared-loss agreement from one company to another.


In response, the FDIC informed CRC that they considered our request “commercial in nature,” and that “the subject matter of your request is not now of interest to the general public.”


CRC will continue seeking this information, because we believe the five questions raised above are of interest to the general public.

Are you concerned after reading this?  Sign our petition, asking bank regulators to do their job:

Tell Bank Regulators: Do Your Job!

Want to learn more about this merger?  Here’s some additional resources:

35 Community Organizations Call for Hearings on OneWest and CIT Bank Merger

Too Big to Fail Bank Merger in California Could Hurt Consumers

California Reinvestment Coalition Urges Greater Transparency by Regulators in Merger Creating Too Big to Fail Bank

Shouldn’t communities be considered ‘too big to fail’? Guest commentary