Civil rights and consumer advocacy organizations wrote to the Federal Reserve Board to lodge objection to the merger application of Enova International, Inc. (Enova) and Grasshopper Bank and to request a meeting. Objections arise specifically under the Federal Reserve’s review authority under the Bank Holding Company Act (BHCA), which requires consideration of financial resources, managerial competence, the convenience and needs of communities to be served, and anti-competitive effects. Each of these criteria weighs against approval. The Federal Reserve’s BHCA review is broad: it encompasses a consolidated assessment of the holding company’s managerial competence, its overall financial condition, and — critically — the convenience and needs of the communities the resulting institution will serve. Those are precisely the dimensions on which Enova’s record is most troubling, and they are dimensions the OCC’s process does not fully reach. The groups therefore urged the Federal Reserve to conduct a rigorous, independent review that does not simply defer to the OCC’s determination.
See all resources related to: Banking, Payments & Remittances, High-Cost Credit