In 1994 there were 12,000 banks; today fewer than 4,600. When banks merge, they standardize underwriting to satisfy regulators and shareholders. They adhered more strictly to DSCR models that lock out small business owners from buying commercial real estate.

And *this* has decimated Main Street.

What I didn't know was WHY things had changed in that era.

Then I found this: a 2020 analysis of Arthur Morgan’s 'Industries for Small Communities' that draws a direct line from Morgan's 1953 critique of “bigness” to a 1994 banking act that set off a wave of mergers and acquisitions.

For my PLACES talk, I showed changes in my business district from 2000 and 2023. In 2000, most commercial parcels were owned by someone who owned just one parcel. In 2023, investment consolidation had taken over. This proves to me that just 20 years ago, business owners DID own their buildings.

My answer was yes: OlyFed. I was so surprised, I asked them WHY they said yes. Their reply? "Because we hold our own mortgages." The Banking Committee staffers nodded vigorously in recognition at this. It's not OCC guidelines themselves, but *selling the mortgages* based on these guidelines.

I also brought this analysis to Capitol Hill last month, to staff from Sen. Elizabeth Warren’s office, Ranking Member on the Senate Banking Committee’s minority. They pointed out that the OCC guidelines aren't binding law. But then they asked: were there any banks that actually *did* lend to you?

When banks underwrite solely based on occupying business cash flow, it's near impossible for businesses to borrow to purchase their buildings. If they don't own the buildings, there's a hole in Main Street. I made this issue a presentation at the Washington Main Street PLACES Conference last month.

I went to a sub basement of a sub basement of research on why banks treat owner occupants differently than investors when underwriting loans, particularly when examining repayment sources. Page 131 of the Comptroller’s Handbook on Commercial Real Estate Lending, to be exact.

There is no excuse for giving in to a bad deal —

especially after voters turned out in record numbers last week to elect Democrats on the promise that they would stand up and fight for working families.