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.

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.

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
Improve.

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.

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.

Comment letter on the CRA examination of First National Bank of Brookings, South Dakota. This letter states that Brookings should receive a lending test rating of no higher than ‘Needs to Improve’ due to its partnership with Cash America to offer payday loans in Illinois and other states.

Comment letter on the 2002 CRA exam of State Farm Bank.  Suggests that State Farm Bank should include :  MSAs or counties where it has branches and ATMs, and any MSA or non-metro county where it has originated a significant portion of its loans in its definition of its assessment area.

Comment letter on the 2002 CRA examination of Banco Popular NA.  The letter discusses Banco Popular’s  basic checking account, which is  more expensive and contains more restrictions than accounts offered by other banks in the area.  The letter also expresses serious concern regarding Banco’s invisibility in the home purchase and refinance lending markets. An analysis of Banco Popular’s HMDA data shows the Bank made 2 home purchase loans and only 1 refinance loan in its Illinois assessment area in 2001.

Addendum to the 2002 CRA exam comment letter submitted regarding Banco Popular North America.  The bank claimed that they make most of their lending through Equity One (a subprime lender) and an entity known as Banco Popular, N.A.