Chase CRA Comment Letter_Final.pdf

This letter comments on Chase Bank’s performance under the Community Reinvestment Act. The Community Reinvestment Act requires banks to work with low- to moderate-income communities to ensure their financial needs are being met. It assesses the bank’s mortgage lending, small business lending, products and services, and community grants and investments in the Rockford MSA and the Illinois counties within the Chicago-Joliet-Naperville MMSA.  We believe that while the bank is performing well in certain areas, including community development grants and investments, and refinance loan originations, there is need for improvement. Chase should: increase its home purchase lending to bring it more in line with other banks and increase access to small business loans in low- and moderate-income (LMI) communities; reform its current overdraft policies to ensure that consumers are not unwittingly signing up for products they do not want and incurring high fees or charges; increase access to the bank’s financial services by considering municipal IDs to be an acceptable form of identification; and ensure that additional bank branches are located in LMI census tracts to more accurately reflect the total percentage of the Assessment Area population residing in those tracts.