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526 Dissenting Statement

federal regulators for merger approvals. Th e opening section of the report states
(bolded language in the original): 153
Since the passage of CRA in 1977, lenders and community organizations have
signed over 446 CRA agreements totaling more than $4.5 trillion in reinvestment
dollars fl owing to minority and lower income neighborhoods.
Lenders and community groups will oft en sign these agreements when a lender has
submitted an application to merge with another institution or expand its services.
Lenders must seek the approval of federal regulators for their plans to merge or
change their services. Th e four federal fi nancial institution regulatory agencies will
scrutinize the CRA records of lenders and will assess the likely future community
reinvestment performance of lenders. Th e application process, therefore, provides an
incentive for lenders to sign CRA agreements with community groups that will improve
their CRA performance. Recognizing the important role of collaboration between lenders
and community groups, the federal agencies have established mechanisms in their
application procedures that encourage dialogue and cooperation among the parties in
preserving and strengthening community reinvestment. [emphasis supplied]
A footnote to this statement reports:
Th e Federal Reserve Board will grant an extension of the public comment period
during its merger application process upon a joint request by a bank and community
group. In its commentary to Regulation Y, the Board indicates that this procedure
was added to facilitate discussions between banks and community groups regarding
programs that help serve the convenience and needs of the community. In its
Corporate Manual, the Offi ce of the Comptroller of the Currency states that it will
not off er the expedited application process to a lender that does not intend to honor a
CRA agreement made by the institution that it is acquiring.

153 See Note 12 supra.