Marquette_april2004_cracomments.pdfCRA 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.