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2. On December 28, 2016, the Board received a public comment from Inner City Press/Fair
Finance Watch (Inner City) that, among other things, alleged disparities in the rates at
which Simmons denied applications by African Americans, as compared to whites, for
conventional home purchase loans in the Little Rock, Arkansas, and Memphis,
Tennessee-Mississippi-Arkansas, metropolitan statistical areas. In response to Inner
Citys comment, Simmons stated in a letter to the Board dated January 10, 2017, that
Inner Citys allegation does not fairly present the lending activities of Simmons in those
markets. Please discuss further why the 2015 HMDA data referenced by Inner City
does not fairly present Simmonss lending record (e.g., policies and procedures, overall
lending) in the Arkansas and Memphis MSAs.
3. Discuss whether Simmons anticipates that there would be any changes to the products
and services currently offered to customers of Simmonss wholly-owned subsidiary,
Simmons Bank, Pine Bluff, Arkansas, and First South Bank during the period between
consummation of the holding company merger and the proposed merger of Simmons
Bank and First South Bank.
5. Provide a copy of the latest CRA Strategic Plan referred to on page 13 of the FR Y-3N
Notification filed by Simmons on November 23, 2016. In addition, please discuss
whether Simmons intends to make any changes to its current CRA Strategic Plan or other
CRA-related initiatives upon the merger of Simmons and Hardeman.
Please address your responses within eight business days to Paul F. Lippold at the
Federal Reserve Bank of St. Louis. Any information for which you desire confidential treatment
should be so labeled and separately bound in accordance with the Boards rules regarding
confidential treatment of information at 12 CFR 261.15.
If you have any questions concerning this letter, please contact Vicki Szybillo at
(202-475-6325) or Evans Muzere at (202-452-2621), both of the Boards Legal Division.