June 22, 2021
The Honorable Maxine Waters
Chairwoman
Committee on Financial Services
United States House of Representatives
Washington, DC 20515
The Honorable Patrick McHenry
Ranking Member
Committee on Financial Services
United States House of Representatives
Washington, DC 20515
Dear Chairwoman Waters, Ranking Member McHenry and Members of the Committee:
We are writing to urge your support for H.R. 3948, the Greater Supervision in Banking Act. The bill creates an important way to consolidate and make public information about bank governance and regulatory records, diversity and environmental efforts and other key practices at the nation’s most financially sophisticated and complex financial institutions. These are bank practices affecting not just consumers and financial markets but also the larger communities in which they operate.
Because of the impact of bank mergers on lending, investments, bank branches and financial services in local communities, and particularly those that are low- and moderate and underserved, we have long urged regulators to better assess the public benefits of these transactions. For more than 50 years, federal law has required federal regulators to consider the public’s interest when approving bank mergers and acquisitions. Both the Bank Holding Company Act and the Bank Merger Act require regulators to consider “the convenience and needs of the community to be served.”[1]. Anti-competitive effects must be “clearly outweighed in the public interest by the probable effect of the transaction in meeting the convenience and needs of the community to be served.”[2] The public benefit standard should be strengthened and clarified so that both the public and financial institutions better understand this factor’s importance and its requirements, and regulators should consistently monitor and enforce banks’ claimed public benefits to ensure that institutions fulfill their promises.
If adopted, the Amendment in the Nature of the Substitute, would elevate the policy dialogue around the public benefits banks claim during bank mergers as well as the lending and other future commitments made to the local communities impacted by these transactions. For these reasons and more, we urge you to support the Amendment in the Nature of a Substitute and vote yea on H.R. 3948.
If you should have any further questions, then please feel free to contact Gerron S. Levi, NCRC’s Senior Director of Government Affairs, at 202-464-2708.
Sincerely,
National Community Reinvestment Coalition (NCRC)
California Reinvestment Coalition
Fair Finance Watch
[1] 12 U.S.C. § 1842(c)(2)
[2] 12 U.S.C. § 1828(c)(5)(B)
The nation needs better monitoring of it banks, especially its larger banks. Dodd-Frank Act needs more support after attacks by Trump. Mergers of banks needs to stop.