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northerntrust_april2004_cracomments.pdfComment letter on the 2004 CRA examination of The Northern Trust Company.  Our analysis of Northern Trust’s mortgage lending shows room for improvement in certain of the bank’s product lines, however, Northern Trust’s home purchase lending to African-Americans and refinance lending to African-Americans and Hispanics appear fairly strong.  The bank is also a strong investor in the Chicago CDFI industry.