CRA Comment letters submitted during a bank's regular CRA examination. Woodstock Institute regularly comments on bank mergers throughout the Chicago region, and the nation. For information on a specific bank, please contact Woodstock Institute through the comment page.
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 submitted as part of the bank's 2004 CRA performance evaluation. Comments evaluate the bank's mortgage and small business lending to low- and moderate-income borrowers and communities; levels of grants and investments for community development organizations serving LMI communities; and access to bank branches in LMI communities.
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.
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.
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.
