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.
Comment letter on the proposed 2000 strategic plan filed by Netbank. Argues that the definition of assessment area needs to reflect the changing industry in order to keep in line with the intent and the language of the CRA statute.
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.
