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May 7, 2019 Matthew Russell Lee Inner City Press PO Box 20047 Dag Hammarskjold Station

May 7, 2019

Matthew Russell Lee Inner City Press PO Box 20047 Dag Hammarskjold Station New York, NY 10017

Dear Mr. Lee:

This relates to your Freedom of Information Act request dated December 1, 2018, which was received in my office on March 29, 2019.

You requested all withheld portions of the applications by WSFS to acquire Beneficial. You also requested a fee waiver for this request and provided a justification you believe that the transaction is subject to a CRA public comment closing 25 branches and as such will contribute to a better understanding of relevant government procedures.

Fee waivers are not automatically granted. Our regulations at 12 C.F.R. 4.17(b)(4) state that the Office of the Comptroller of the Currency (OCC) may “waive or reduce a fee under this section whenever, in its opinion, disclosure of records is in the public interest because the disclosure: (i) is likely to contribute significantly to public understanding of the operations or activities of the government; and (ii) is not primarily in the commercial interest of the requester.” If either one of these requirements is not satisfied, a fee waiver or reduction in fees will not be granted.

Your request for a fee waiver is denied because you failed to provide sufficient justification that warrants our granting your request. In reviewing your justification as it relates to 12 C.F.R. 4.17(b)(4)(i) above, we must analyze four related considerations: (1) the subject of the request, (2) the informative value of the information to be disclosed, (3) the contribution to an understanding of the subject by the public likely to result from disclosure, and (4) the significance of the contribution to public understanding.

Concerning the third consideration, contribution to public understanding, we examined whether or not disclosure of the requested records would contribute to the understanding of the public at large, as opposed to the understanding of the requester or a small number of interested persons. In other words, we considered whether or not you demonstrated how contribution to public understanding outweighs personal benefit to you. I find that you did not demonstrate this component; therefore, you did not satisfy the regulatory requirement of 12 C.F.R. 4.17(b)(4)(i). In light of this, there is no need to analyze your justification with respect to 12 C.F.R. 4.17(b)(4)(ii). Consequently, you are responsible for all appropriate fees for your user category and must submit to this office in writing a firm agreement to pay all applicable fees.


If you consider any of the above to be an improper denial of your request, you may appeal such denial to the Comptroller of the Currency. The appeal should be filed within 35 days of the date of this letter, should state the circumstances and reasons or arguments in support of the appeal, and be submitted via our online FOIA application at or be mailed to the Manager, Disclosure Services & Freedom of Information Act Officer, Communications Division, Office of the Comptroller of the Currency, Suite 3E-218, Washington, DC 20219.

Sincerely yours,

Frank D. Vance, Jr.

Frank D. Vance, Jr. Manager, Disclosure Services & Freedom of Information Act Officer Communications Division