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.
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 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 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.
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.
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.
