The promises and perils of community benefits agreements: evidence from public comments to a large bank merger

Communities are using benefits agreements to advocate for economic investments in the context of bank mergers. This study used descriptive and critical discourse analyses to analyze 438 public comments on the 2016 KeyBank-First Niagara merger that included a five-year, $16.5B benefits agreement. Community members universally expressed opposition to the merger. However, the Federal Reserve's process disempowered community members whose opposition was not voluminous enough to countervail the support strategically orchestrated by KeyBank. Organizations benefitting from KeyBank's philanthropy leveraged the marginalized communities they served to proffer evidence of the bank's compliance with the Community Reinvestment Act. Implications are discussed.