June 30, 2026
Submitted Electronically
Mark Taylor
Regional Director
Federal Deposit Insurance Corporation
600 North Pearl Street, Suite 700
Dallas, TX 75201
Via Email: mtaylor@fdic.gov
J. Mark Love
Deputy Regional Director
Federal Deposit Insurance Corporation
600 North Pearl Street, Suite 700
Dallas, TX 7520
Via Email: jlove@fdic.gov
Matthew Z. Zamora
Deputy Regional Director
Federal Deposit Insurance Corporation
600 North Pearl Street, Suite 700
Dallas, TX 75201
Via Email: mzamora@fdic.gov
Re: Application by Hancock Whitney Corporation, Gulfport, Mississippi; to merge with OFB Bancshares, Inc., Orlando, Florida, and thereby acquire control of One Florida Bank.
Dear Director Taylor,
The National Community Reinvestment Coalition (NCRC) is submitting this comment letter regarding Hancock Whitney Bank’s (Hancock Whitney) application to acquire One Florida Bank (One Florida). NCRC and its members have been concerned with the Community Reinvestment Act (CRA) and lending performance of Hancock Whitney since 2017. Attached to this letter are several letters NCRC and its members previously submitted to the Federal Deposit Insurance Corporation in 2017, 2018 and 2019. Most notably, regulators required Hancock Whitney to establish an Action Plan in 2017 to improve its commitments to uphold the CRA. Although regulators’ assessment of Hancock Whitney’s CRA performance has since improved, to an Outstanding rating overall, the bank’s Lending Test rating is High Satisfactory. One Florida’s CRA performance shows a similar imbalance – One Florida received an Outstanding on its Community Development Test but only a Satisfactory on its Lending Test. In addition, we are concerned with the disparities in both Hancock Whitney and One Florida lending performance with respect to both majority-minority and low-income communities.
To adequately meet their stated post-merger CRA outcomes, NCRC strongly encourages Hancock Whitney and One Florida to work with NCRC and its members to create a comprehensive Community Benefits Agreement (CBA) that will help to ensure the merger benefits the public.[1] Moreover, NCRC and its over 700 member organizations urge the FDIC to condition approval of the merger with the completion of a CBA detailing how Hancock Whitney will continue to improve its own lending performance while also raising the standards of business acquired from One Florida. Finally, following up on our previous letters, NCRC and its members request that Hancock Whitney and the FDIC make public the results of their credit needs assessment and monitoring from the former Action Plan, as well as any information related to steps that Hancock Whitney has taken to address gaps in lending performance through the current date.
Hancock Whitney’s Action Plan and the need for an ongoing commitment through a Community Benefits Plan
In 2017, FDIC regulators required Hancock Whitney to develop an Action Plan that included a credit needs assessment, regular monitoring of application and origination to the underserved, and to the documented steps that Hancock Whitney would take if the bank’s lending performance compared to peer[2] and aggregate performance standards showed gaps. NCRC requests the public release of the results of these assessments and any insights that emerged from them, as well as any ongoing changes implemented by Hancock Whitney that arose from the Action Plan.
As noted below, Hancock Whitney’s lending performance still trails peers in multiple areas, despite steps taken to implement the Action Plan. NCRC and its members have long held that intentional community-centered planning is mutually beneficial, helping banks to meet their CRA obligations while also reaching new customers and markets. CBAs have proven to be effective tools for ensuring a bank’s CRA lending, investments, and services address the specific needs and economic conditions of the communities the bank serves. As Hancock Whitney seeks to expand its business by acquiring One Florida while also improving its lending performance, we urge the Hancock Whitney and One Florida teams to consider working with NCRC and our members in Florida to establish a CBA.
One Florida Lending: Concerning Patterns in Both Mortgage and Small Business Lending[3]
One Florida Mortgage Lending Patterns: One Florida’s mortgage lending in majority-minority census tracts and to Hispanic borrowers were well below peers across both assessment areas. Only 16.67% of One Florida’s mortgage loans originated in majority-minority census tracts compared to roughly 48.20% among peers, and only 7.14% of mortgage borrowers were Hispanic, despite more than 25% of mortgage borrowers at peer institutions identifying as Hispanic. Notably, the Orlando-Kissimmee-Sanford, FL Metro Area population is around 15% African American and 35% Hispanic, demonstrating One Florida’s failure to serve the entire Orlando-Kissimmee-Sanford community.[4] Furthermore, as noted above 16.7% of the bank’s lending in the market is in majority-minority census tracts, while 57% of the census tracts are majority-minority.[5]
One Florida Small Business Lending Patterns: One Florida’s small business lending also reveals a bank not reaching the businesses most in need of credit access. Only 21.78% of One Florida’s small business loans originated in LMI census tracts across its footprint, compared to 32.02% among peers — a gap of more than 10 percentage points, concentrated almost entirely in the Orlando-Kissimmee-Sanford market (21.90% vs. 31.73%, a gap of 9.83 points), where the substantial majority of the bank’s small business lending occurs. More troubling still is One Florida’s pattern of lending to businesses by size: only 14.52% of the bank’s small business loans went to businesses with gross annual revenues under $1 million, compared to 41.30% among peer lenders. This disparity is reinforced by One Florida’s average loan size. The average loan the bank extended to businesses with under $1 million in gross annual revenue was $320,161 — more than 4.6 times the peer average of $69,400 for loans to businesses of the same size.
Taken together, these figures paint a picture of a bank that, even when it does lend to nominally small businesses, is serving the upper end of that category almost exclusively, while the smallest and most underserved businesses in its assessment areas — the sole proprietors, the start-ups, the storefronts that depend on modest-dollar credit — are largely going unserved. Indeed, we are in agreement with regulators’ remarks in One Florida’s most recent CRA Performance Assessment that the bank’s “distribution of loans to borrowers reflects, given the demographics of the assessment areas, poor penetration among businesses of different sizes and individuals of different income levels.”[6]
This is precisely the kind of gap a Community Benefits Agreement with specific lending goals and outreach commitments to small-dollar, small-revenue borrowers is designed to close.
Hancock Whitney’s Own Lending Performance Failures
Hancock Whitney’s own HMDA data reveal lending gaps that mirror, and in some respects exceed, the concerns we raise about One Florida. Across its full footprint from 2020 through 2024, only 14.84% of Hancock Whitney’s mortgage loans went to low- and moderate-income borrowers, compared to 23.85% among peer lenders — a gap of more than 9 percentage points. This is not an isolated weakness in one or two markets: Hancock Whitney trailed peers on LMI borrower lending in 32 of the 38 assessment areas in which it originated mortgage loans during this period, including in several of its largest and most established markets. In New Orleans-Metairie, the bank’s home market and its single largest source of mortgage volume, Hancock Whitney lagged peers by 8.5 percentage points on LMI borrower lending; in Baton Rouge, by 9.6 points; in Tampa-St. Petersburg-Clearwater, by nearly 14 points; and in Jacksonville, by more than 15 points.
Hancock Whitney’s lending in majority-minority census tracts shows a similar, if less uniform, pattern. Overall, the bank originated 19.29% of its mortgage loans in majority-minority tracts compared to 22.43% among peers, trailing by more than 3 percentage points. While Hancock Whitney trails on this measure in only 17 of its 38 assessment areas, several of those are among its highest-volume markets: New Orleans-Metairie (trailing by 1.5 points), Tampa-St. Petersburg-Clearwater (1.1 points), Jacksonville (5.6 points), Houma-Thibodaux (7.8 points), and Tallahassee (8.0 points). Notably, Houston-The Woodlands-Sugar Land is a marked exception, where Hancock Whitney exceeds peer performance in majority-minority tract lending by more than 17 percentage points, suggesting the bank is capable of strong performance on this measure when it prioritizes it. The inconsistency between markets points to an institutional gap in strategy and resource allocation and reinforces NCRC’s view that a comprehensive Community Benefits Agreement — covering Hancock Whitney’s existing footprint and not just the acquired One Florida markets — is warranted as a condition of this merger’s approval.
Request for Conditional Approval: The Need for a Community Benefits Plan
In its merger application, Hancock Whitney states that they intend “to integrate One Florida Bank into its existing robust CRA program, while also drawing from the strengths of One Florida Bank’s program to create an enhanced, combined program that reflects each institution’s knowledge of the needs of its communities.” We believe that it is crucial for the community members themselves to be involved in any such efforts and urge the Hancock Whitney team to work with us and our members on a CBA. NCRC is an association of over 700 community-based organizations whose mission is to increase access to credit and capital in traditionally underserved communities. Our members are actively involved in bank mergers, striving to ensure that mergers do not result in decreases in lending and banking services in their communities but instead provide the public benefits of improved CRA and fair lending performance.
Given the lending disparities discussed above, the FDIC must condition the approval of this merger on a commitment to develop a forward-looking and measurable community benefits plan for the proposed merger between Hancock Whitney and One Florida.
Conclusion
Both Hancock Whitney and One Florida lending patterns show significant failures to lend to underserved borrowers. The FDIC must condition any merger approval upon a forward-looking community benefits plan developed with input from community stakeholders. NCRC members have a strong presence throughout Hancock Whitney and One Florida’s footprints, and are uniquely positioned to assist Hancock Whitney with improving its performance in both its current footprint and in the One Florida footprint. We also repeat our previous request that the details, progress, and steps taken because of Hancock Whitney’s required Action Plan be released to the public.
Thank you for considering this request. If you have any questions about this letter, please contact Jesse Van Tol, NCRC’s Chief Executive Officer, at jvantol@ncrc.org, or Catherine Petrusz, NCRC’s Director of Institutional Accountability, at cpetrusz@ncrc.org.
Jesse Van Tol
President and CEO
NCRC
[1] Bank Merger Act Application for the proposed merger of Hancock Whitney Bank and One Florida Bank pp. 17-31
[2] Peers are defined as lenders making 50% to 200% of the subject bank’s application volume in a given year in a CBSA (for mortgage and SB data).
[3] Mortgage lending analysis is based on HMDA data filtered to owner-occupied, site-built and manufactured home loans on 1-to-4-unit properties, excluding reverse mortgages, for the years 2020 through 2024. Small business lending analysis is based on FFIEC CRA data covering loans under $1 million to businesses with gross annual revenues under $1 million, for the same period. Peer lenders are defined as institutions originating between 50% and 200% of the subject bank’s application volume each year within the relevant CBSA. NCRC is happy to share the full dataset upon request.
[4] U.S. Census Bureau (2024). American Community Survey 1-year estimates. Retrieved from Census Reporter Profile page for Orlando-Kissimmee-Sanford, FL Metro Area, http://censusreporter.org/profiles/31000US36740-orlando-kissimmee-sanford-fl-metro-area/.
[5] U.S. Census Bureau (2023). American Community Survey 5-Year Estimates, Table B03002 (Hispanic or Latino Origin by Race), Census Tracts in Orange, Seminole, Lake, and Osceola Counties, Florida. Retrieved from data.census.gov, https://data.census.gov/table/ACSDT5Y2023.B03002.
[6] “2022 One Florida Bank Community Reinvestment Act Performance Evaluation.” Federal Deposit Insurance Corporation. September 12, 2022. Available online at https://www.onefloridabank.com/assets/files/FOoMID6i
