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  • Community Reinvestment Act Assessment Area Expansion by CBSI, After ICP Comments

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    Matthew Russell Lee
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    ICP Comments on Goldman Sachs, Will on Key & NY Community Bank By Matthew R. Lee NEW YORK, October 30 -- The lack of seriousness in US bank regulation grows from the relatively smaller to the largest banks, with Goldman Sachs the most recent example. Goldman is trying to speed through Federal Reserve approval to buy $16 billion in insured deposits from GE Capital, and the Fed, documents released to Inner City Press under the Freedom of Information Act show, is inappropriately bent on helping, including by closing its comment period. At the other end of the spectrum, after Fair Finance Watch advocacy, Community Bank System Inc is expanding its Community Reinvestment Act assessment area, here. In between, and going forward, KeyCorp is trying to buy First Niagara in the same area as CBSI; there will be opposition. As to Goldman Sachs, Inner City Press / Fair Finance Watch filed a supplement comment on October 30 including Goldman's new and troubling settlement with the NYS Department of Financial Services regarding a former Federal Reserve employee impermissibly using Fed information for them. Public hearings and an extension of the comment period are needed. As detailed below, the Federal Reserve's General Counsel Scott Alvarez solicitiously agreed to weekend phone calls with Goldman's outside council Rodgin "Rodge" Cohen at Sullivan & Cromwell, and the Fed submitted its "Additional Information" request to Goldman in July, a full month before any application was submitted or the deal publicly announced. Thus there was no way for the public to be involved in the Fed's review, which is required by the Bank Merger Act (and the Administrative Procedures Act). The Fed began trying to essentially pre-approve some applications with a 2012 letter to banks, here - but it said no major issues could be addressed this way, and the interchanged would be subject to FOIA. In this case, though, where Inner City Press submitted its FOIA request as soon as it became aware of Goldman's GE proposal and application, none of the information would have been available until after the comment period was set to close on September. It has been extended to October 30, due to requests from ICP and other NCRC members, but the Fed is still withholding portions of its communication with Goldman in the face of the FOIA Appeal Inner City Press immediately filed. (ICP has also submitted a timely additional comment on these issues.) Inner City Press has previously litigated FOIA requests with the Fed and won, at least in part, for example in obtaining subprime lending information the Fed wanted to withhold, here. But this should not be necessary in order for the public to have this basic information, during the comment period. Will members of Congress and other chime in? Watch this site.

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    ICP Comments on Goldman Sachs, Will on Key & NY Community Bank By Matthew R. Lee NEW YORK, October 30 -- The lack of seriousness in US bank regulation grows from the relatively smaller to the largest banks, with Goldman Sachs the most recent example. Goldman is trying to speed through Federal Reserve approval to buy $16 billion in insured deposits from GE Capital, and the Fed, documents released to Inner City Press under the Freedom of Information Act show, is inappropriately bent on helping, including by closing its comment period. At the other end of the spectrum, after Fair Finance Watch advocacy, Community Bank System Inc is expanding its Community Reinvestment Act assessment area, here. In between, and going forward, KeyCorp is trying to buy First Niagara in the same area as CBSI; there will be opposition. As to Goldman Sachs, Inner City Press / Fair Finance Watch filed a supplement comment on October 30 including Goldman's new and troubling settlement with the NYS Department of Financial Services regarding a former Federal Reserve employee impermissibly using Fed information for them. Public hearings and an extension of the comment period are needed. As detailed below, the Federal Reserve's General Counsel Scott Alvarez solicitiously agreed to weekend phone calls with Goldman's outside council Rodgin "Rodge" Cohen at Sullivan & Cromwell, and the Fed submitted its "Additional Information" request to Goldman in July, a full month before any application was submitted or the deal publicly announced. Thus there was no way for the public to be involved in the Fed's review, which is required by the Bank Merger Act (and the Administrative Procedures Act). The Fed began trying to essentially pre-approve some applications with a 2012 letter to banks, here - but it said no major issues could be addressed this way, and the interchanged would be subject to FOIA. In this case, though, where Inner City Press submitted its FOIA request as soon as it became aware of Goldman's GE proposal and application, none of the information would have been available until after the comment period was set to close on September. It has been extended to October 30, due to requests from ICP and other NCRC members, but the Fed is still withholding portions of its communication with Goldman in the face of the FOIA Appeal Inner City Press immediately filed. (ICP has also submitted a timely additional comment on these issues.) Inner City Press has previously litigated FOIA requests with the Fed and won, at least in part, for example in obtaining subprime lending information the Fed wanted to withhold, here. But this should not be necessary in order for the public to have this basic information, during the comment period. Will members of Congress and other chime in? Watch this site.

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    © All Rights Reserved
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    106 views6 pages

    Community Reinvestment Act Assessment Area Expansion by CBSI, After ICP Comments

    Uploaded by

    Matthew Russell Lee
    ICP Comments on Goldman Sachs, Will on Key & NY Community Bank By Matthew R. Lee NEW YORK, October 30 -- The lack of seriousness in US bank regulation grows from the relatively smaller to the largest banks, with Goldman Sachs the most recent example. Goldman is trying to speed through Federal Reserve approval to buy $16 billion in insured deposits from GE Capital, and the Fed, documents released to Inner City Press under the Freedom of Information Act show, is inappropriately bent on helping, including by closing its comment period. At the other end of the spectrum, after Fair Finance Watch advocacy, Community Bank System Inc is expanding its Community Reinvestment Act assessment area, here. In between, and going forward, KeyCorp is trying to buy First Niagara in the same area as CBSI; there will be opposition. As to Goldman Sachs, Inner City Press / Fair Finance Watch filed a supplement comment on October 30 including Goldman's new and troubling settlement with the NYS Department of Financial Services regarding a former Federal Reserve employee impermissibly using Fed information for them. Public hearings and an extension of the comment period are needed. As detailed below, the Federal Reserve's General Counsel Scott Alvarez solicitiously agreed to weekend phone calls with Goldman's outside council Rodgin "Rodge" Cohen at Sullivan & Cromwell, and the Fed submitted its "Additional Information" request to Goldman in July, a full month before any application was submitted or the deal publicly announced. Thus there was no way for the public to be involved in the Fed's review, which is required by the Bank Merger Act (and the Administrative Procedures Act). The Fed began trying to essentially pre-approve some applications with a 2012 letter to banks, here - but it said no major issues could be addressed this way, and the interchanged would be subject to FOIA. In this case, though, where Inner City Press submitted its FOIA request as soon as it became aware of Goldman's GE proposal and application, none of the information would have been available until after the comment period was set to close on September. It has been extended to October 30, due to requests from ICP and other NCRC members, but the Fed is still withholding portions of its communication with Goldman in the face of the FOIA Appeal Inner City Press immediately filed. (ICP has also submitted a timely additional comment on these issues.) Inner City Press has previously litigated FOIA requests with the Fed and won, at least in part, for example in obtaining subprime lending information the Fed wanted to withhold, here. But this should not be necessary in order for the public to have this basic information, during the comment period. Will members of Congress and other chime in? Watch this site.

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    © All Rights Reserved
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    of 6

    Community

    ~J~J Bank N.A.


    COMMUNITY BANK,N.A.
    5790 Widewaters Parkway, DeWitt, New York 13214
    GEORGE J. GETMAN
    Executive Vice President
    General Counsel

    October 29, 2015


    VIA ELECTRONIC MAIL AND OVERNIGHT MAIL

    Ms. Marva V. Cummings


    Director for District Licensing
    Office ofthe Comptroller ofthe Currency
    Northeastern District
    340 Madison Ave., Fifth Floor
    New York, NY 10173
    Re:

    The Applications by Community Bank System,Inc., DeWitt, New York, to Acquire


    Oneida Financial Corp., Oneida, New York
    2015- NE-Combination-142284
    OCC Control Number:

    Dear Ms. Cummings:


    I am writing on behalf of Community Bank System, Inc.("CBSI") in connection with the
    applications by CBSI, the parent of Community Bank N.A.("Community Bank" or the "Bank")to
    acquire Oneida Financial Corp. ("Oneida"), the parent of Oneida Savings Bank ("OSB"), and
    OSB's wholly-owned limited purpose commercial bank, the State Bank of Chittenango (the
    "Muni-Sub"). The purpose of this letter is to update information we provided previously in
    connection with these applications.
    In connection with the Federal Reserve Bank's July 13, 2015 letter, we confirmed on
    August 18, 2015 that Community Bank intended to adopt the entirety of OSB's existing CRA
    assessment areas on apost-merger basis. We further indicated that the Bank would continue to
    evaluate its post-merger assessment areas and adjust it as needed. Accordingly, in recognition of
    the Bank's continued growth in the central portion of New York State and northeastern
    Pennsylvania and its increasing loan production in such areas, Community Bank believes that, in
    light of the anticipated merger with OSB, this is an appropriate time to formally reflect such
    growth in the Bank's assessment area map.
    Accordingly, Community Bank hereby committing to add the following areas to the Bank's
    post-merger CRA assessment areas:
    ~

    Syracuse MSA(NY)All of Oswego County(NY)(including the areas north of


    the Oswego River and the north shore of Oneida Lake);

    Ms. Marva V. Cummings


    October 29, 2015
    Page 2
    Utica MSA(N~ all of Oneida County(NY),including the city of Utica.
    Ulster County(NY)-the census tracts that form a triangle in between the Bank's
    Boiceville (Ulster County) and Fleischmanns (Delaware County) branches. See
    Exhibit 1.
    Binghamton MSA (NY)-the City of Binghamton, the census tracts south of the
    Susquehanna River and north of the New York/Pennsylvania border (see Exhibit
    2)and all of Tioga County(N~.
    Chemung County(NY)all of Chemung County(NY).
    City ofIthaca/ Tompkins County(NY)all of Tompkins County(NY).
    Carbon and Schuylkill Counties (PA) the census tracts between the Bank's
    Lansford (Carbon County) and Lehighton branches (Carbon County) and its
    Hazelton branch (Luzerne County) namely, census tracts 201.01, 202 and 207 in
    Carbon County and census tracts 26,27 and 28 in Schuylkill County.

    Please let me know if I can provide further information. Thank you for your assistance.
    Very truly yours,

    George J. Getman
    EVP and General Counsel

    cc:
    Laurie Powell, Licensing Analyst, Office ofthe Comptroller ofthe Currency (via email)
    Carla Holiman, Senior Licensing Analyst, Office ofthe Comptroller ofthe Currency (via
    email)
    Brian S. Steffey, Bank Applications Officer, Federal Reserve Bank of New York (via email)\
    Scott A. Cammarn, Esq., Cadwalader Wickersham &Taft, LLP (via email)
    Matthew Lee, Esq., Executive Director, Inner City Press/Finance Watch

    Ms. Marva V. Cummings


    October 29,2015
    Page 3
    EXHIBIT 1

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    October 29, 2015
    Page 4
    EXHIBIT 2

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