Legislative and Regulatory Comment Letters

Woodstock Institute influences policy at the local, regional, and national level by closely analyzing the impact of pending proposals on low-wealth communities and communities of color.
November 15, 2000
Comment letter on the CRA examination of M&I Bank FSB’s proposed strategic plan.  This letter states that banks such as M&I Bank FSB that do a significant amount of business nationwide over the Internet should consider even more expansive assessment areas in order to remain accountable to all of the communities that they serve.
October 2, 2000
Comment letter opposing the proposed 2000 acquisition of the Associates by Citigroup. Under normal merger application procedures, the letter states that this acquisition should be denied or at least conditioned on Community
Reinvestment Act (CRA) and fair lending grounds.
August 1, 2000
Comment letter on the 2001 proposed acquisition of  proposed acquisition of Mid Town Bancorp (parent of Mid Town Bank) by MAF Bancorp.

May 17, 2000
Comment letter on Harris Trust and Savings Bank's 2000 CRA Exam.  Although the bank received a Satisfactory rating for its CRA exam in 1998, this letter highlights some shortcomings in Harris Trust and Saving  Bank's community development performance.
March 17, 2000
Comment letter on the 2000 CRA exam of Chorus Bank.  The letter evaluates the bank on lending, services, grants, and investments and suggests that the bank recievee a rating of Substantial Noncompliance or Needs to
November 3, 1999
Comment letter on proposed Regulation B rule stating that small business loan disclosure should mirror the provisions in the Home Mortgage Disclosure Act for home mortgage disclosure data and that disclosure provisions should be extended to pre-applications.
October 28, 1999
Comment letter on the 1999 CRA examination of The Northern Trust Company strategic plan.  Addresses the bank's low levels of lending, services, and investments in lower-income communities recommends that the Federal Reserve reject Northern Trust's 2000-2002 Strategic Plan.
August 11, 1999
Comment letter on Household Bank FSB’s 1999 CRA Strategic Plan.  The letter suggests that future strategic plans include a detailed break out  of community development lending vs. investments; and a commitment to at least $250,000 per year in below-market equity-equivalent investments in CDFIs.
June 11, 1998
Comment letter expressing concerns about the proposed 1998 merger between NationsBank and Bank of America.  The letter cites the same concerns raised by the Community Reinvestment Association of North Carolina and the California Reinvestment Committee, including the activities of NationsBank subprime lending subsidiaries and urges the Federal Reserve to extend its public comment period substantially and to hold public hearings on the merger in multiple locations, including North Carolina, California, and Chicago.