CRA Comment letters submitted as part on the occasion of a merger or acquisition. 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 opposing the proposed 2000
acquisition of the Associates by Citigroup. Under normal merger
application procedures, the letter states that this acquisition should
be denied or at least conditioned on Community
Reinvestment Act (CRA) and fair lending grounds.
Woodstock Institute requests an extended public comment period and exhaustive review of the combine banks deposits on the grounds that the proposed merger would violate the 10 percent limit on domestic deposits under the Reigle-Neil Act. Woodstock also requests a thorough review of the deceptive effect of credit card rate structures, fees, terms, and conditions offered by both financial institutions.
Comment letter on the proposed 2004 acquisition of Charter One Bank by Citizens Financial Group, a subsidiary of Royal Bank of Scotland. Woodstock Institute recognizes Charter One's improvement under the five year CRA agreement with the Chicago CRA Coalition and encourages the new bank to reduce its dependence on purchased loans for CRA purposes.
Comment letter on the proposed 2003 acquisition of St. Francis Bank, FSB, by MAF Bancorp, holding company of MidAmerica Bank in Chicago. In light of MAF Bancorp’s recent settlement with the Department of Justice regarding MidAmerica’s fair lending record, the Institute has several concerns about the proposed merger.
