Additional comments regarding the 2004 Marquette Bank CRA exam.  This letter  discusses several concerns that arose as a result of Marquette's response to Woodstock Institute's initial comment letter.  Woodstock Institute found that , in its lending analysis, Marquette Bank uses the Chicago MSA as its geographic region of analysis rather than its designated CRA assessment area.  In addition, the five peer institutions Marquette uses in its comparisons are not compariable because they serve distinctly different communities.

CRA examination of Marquette Bank.  Our analysis of Marquette Bank’s 2002 lending shows extreme disparity between the bank’s lending to minorities and whites. For example, within its limited yet diverse assessment area in 2002, Marquette Bank was the 10th largest home purchase lender to white borrowers, but was not in the top 60 for home purchase lending to African-Americans and not in the top 30 to Hispanics.  The letter suggests that Marquette Bank  receive a Substantial Noncompliance on its CRA Lending Test and that the bank’s lending practices should be investigated for fair lending violations by the Federal Reserve and Department of Justice.

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 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.

Woodstock Institute commended the bank on its regular Neighborhood Review Board meetings and its equitable pattern of lending in low-income and Hispanic communities, but expresses some concern over its poor performance in predominately African-American communities.

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 requesting that the Federal Deposit Insurance Corporation consider the payday lending operations in its current safety and soundness examinations of Republic Bank & Trust.

This is a comment letter opposing the application submitted by Dearborn Federal Credit Union to the Office of Thrift Supervision to convert to a mutual savings bank, which is proposed to be known as DFCU Financial, FSB. It notes that the Community Reinvestment Act plan of DFCU Financial does not adequately meet the community reinvestment needs of the proposed bank’s assessment area.

Comment letter on the 2004 CRA examination of The Northern Trust Company.  Our analysis of Northern Trust’s mortgage lending shows room for improvement in certain of the bank’s product lines, however, Northern Trust’s home purchase lending to African-Americans and refinance lending to African-Americans and Hispanics appear fairly strong.  The bank is also a strong investor in the Chicago CDFI industry.