NCRC Comment in Opposition to Application for Business Combination of Pinnacle Bank and Synovus Bank

September 29, 2025

Ann E. Misback, Secretary
Board of Governors of the Federal Reserve
20th Street and Constitution Avenue, N.W.
Washington D.C. 20551
regs.comments@federalreserve.gov

Erien O. Terry
Assistant Vice President
Federal Reserve Bank of Atlanta
1000 Peachtree Street, N.E.
Atlanta, Georgia 30309
Applications.Comments@atl.frb.org

Submitted Electronically

RE: Application by Steel Newco Inc., Peachtree Corners, Georgia; to acquire Synovus Financial Corp., and thereby indirectly acquire Synovus Bank, both of Columbus, Georgia, as well as Pinnacle Financial Partners, Inc., and Pinnacle Bank, both of Nashville, Tennessee; Need for a Community Benefits Agreement

Dear Ms. Misback and Mr. Terry,

The National Community Reinvestment Coalition (NCRC) submits this comment in response to the Federal Reserve’s notice regarding the proposed merger of Synovus Financial Corp. and Pinnacle Financial Partners, Inc. Together, these institutions would create a regional banking organization with more than $100 billion in assets, greatly expanding their reach and influence across the Southeast. Because of the transaction’s scale and its potential impact on competition, fair access to credit, and banking services for low- and moderate-income (LMI) communities, NCRC strongly urges the Board of Governors and the Federal Reserve Bank of Atlanta to condition approval of this application on the adoption of a robust Community Benefits Agreement (CBA).

NCRC is a coalition of more than 700 community-based organizations that promote fairness and equity in banking, housing, and lending. Our members include community development financial institutions (CDFIs), housing counselors, civil rights organizations, and local nonprofits that work directly with consumers and small businesses most affected by the banking system. Given our expertise and direct engagement with communities across the proposed footprint of the combined institution, we are uniquely positioned to assess the merger’s likely effects on community reinvestment and economic opportunity.

CRA Performance and Community Impact

The Community Reinvestment Act (CRA) requires banks to serve the credit needs of the entire community, including LMI borrowers and neighborhoods. Both Synovus and Pinnacle have mixed CRA records. Public CRA performance evaluations and HMDA data reveal disparities in lending to communities of color and persistent gaps in affordable housing finance.

A review of Pinnacle’s and Synovus’ CRA performance in their assessment areas reveals consistent fair lending and branch distribution concerns that should be carefully weighed in this merger application, and that could be addressed in a CBA.

Pinnacle operates in 23 assessment areas, but its CRA record shows notable weaknesses. The bank trails other mortgage lenders by more than ten percentage points in mortgage lending in seven markets, raising concerns about its ability to meet housing credit needs equitably. While Pinnacle’s small business lending volumes are generally on par with or stronger than peers, the average loan sizes are significantly higher, suggesting the bank may not be reaching the smallest firms effectively. Branch distribution also falls short: overall, Pinnacle is roughly 12 percent behind peers in placing branches in majority-minority census tracts. The gaps are especially concerning in Charlotte, Raleigh, Winston-Salem, Greenville, Memphis, and Roanoke—three of which (Greenville, Raleigh, and Roanoke) have no branches in LMI or MMCT neighborhoods at all.[1]

Synovus, with 56 assessment areas, demonstrates even broader disparities. The bank lags behind other mortgage lenders by more than ten percentage points in mortgage lending in 28 assessment areas—nearly half its footprint—indicating serious CRA and fair lending issues. Its small business lending is broadly comparable to peers, but average loan amounts are high, particularly in lending to businesses with annual revenues under $1 million, raising doubts about accessibility for the smallest enterprises. Synovus also trails peers by more than ten percentage points in small business lending in Lee, South Carolina; Sumter, Georgia; and Walker, Alabama. While overall branch distribution is closer to peer averages, significant gaps persist, including in Birmingham, where none of the bank’s ten branches are in either low- or moderate-income or majority-minority census tracts.[2]

A merger of this magnitude presents both risks and opportunities. As the CRA records of both Pinnacle and Synovus demonstrate, each institution already exhibits significant weaknesses in mortgage lending, small-business credit accessibility, and equitable branch distribution. Without enforceable commitments, combining these institutions could magnify existing inequities by further reducing physical branch access and concentrating decision-making away from local communities. By contrast, with a strong, measurable, and enforceable Community Benefits Agreement, this merger could be leveraged to address these deficiencies head-on—expanding lending, investment, and services for underserved borrowers while ensuring the new institution meets its full CRA obligations.

Branch Access and Digital Banking

Synovus and Pinnacle both operate significant branch networks in overlapping markets, including Georgia, Alabama, and South Carolina. This overlap raises concerns about branch consolidations, potential job losses, and reduced consumer choice in affected markets. Branch closures are common after mergers, as institutions seek to cut costs and eliminate overlap.

Branch access remains critical for many rural, older, and lower-income households who lack reliable internet access or comfort with digital-only banking. Regulators must ensure that the merged institution does not accelerate financial exclusion by closing branches disproportionately in LMI or minority communities. Any merger approval should require commitments to preserving branch presence in underserved areas and to expand digital access equitably.

In addition, regulators must condition the merger approval on improving branch distribution by increasing branch presence in low- and moderate-income (LMI) census tracts and in majority-minority (MM) census tracts in markets where either bank operates several branches, but where the bank(s) significantly trails peers or operate zero branches in LMI or MM census tracts.

Recommendations

NCRC urges the Federal Reserve to condition approval of this application on the negotiation and adoption of a Community Benefits Agreement that includes the following commitments:

1.Affordable Housing and Mortgage Lending

• Increased lending to LMI borrowers and neighborhoods, with measurable benchmarks for home purchase, home improvement, and refinance loans.

2. Small Business Lending

• Expanded access to credit for underserved businesses.

3. Community Development Investments

• Significant commitments to support affordable housing, CDFIs, and nonprofit partners.

4. Branch and Service Access

• A commitment to open at least five branches within five years of the merger closing date, in LMI or MM census tracts in assessment areas where the bank(s) trail peers in branch distribution.
• A moratorium on branch closures in LMI and rural markets, along with targeted investments in equitable digital banking access.

5. Transparency and Accountability

• Regular public reporting on progress toward CBA goals, with ongoing input from community stakeholders.
• Formation of a Community Advisory Council, made up of community leaders throughout the combined bank’s footprint, which meets 2-4 times per year to discuss CBA goals progress.

Conclusion

The Synovus–Pinnacle merger is one of the largest proposed regional bank consolidations in recent years. Regulators must ensure that its approval delivers tangible, measurable benefits for the communities the combined institution will serve. Without enforceable conditions, the risks to competition, financial inclusion, and community reinvestment outweigh the potential benefits.

For these reasons, NCRC respectfully requests that the Federal Reserve condition any approval of this application on the adoption of a comprehensive Community Benefits Agreement, negotiated with community stakeholders and aligned with the CRA’s purpose of meeting the credit needs of all communities.

Thank you for your consideration.

Sincerely,
Jesse Van Tol
Chief Executive Officer, NCRC