OneWest CIT Comment Letter final.pdf

This letter to the Federal Reserve and the Office of the Comptroller of the Currency comments on the proposed merger between CIT Group and OneWest Bank. The merger highlights several issues that should be addressed before completed. The first issue is that the merger would create a Systematically Important Financial Institution. The second issue is that both banks lack a strong history in community reinvestment. OneWest Bank received a “low satisfactory” rating from the Community Reinvestment Act and CIT Group invests primarily in communities near its headquarters. This letter recommends against the merger of these two banks. The merger would turn CIT Group and OneWest Bank into a major financial institution, but with a poor record of investing in communities.