Latest on the Community Reinvestment Act
Statement of Horacio Mendez at Economic Growth and Regulatory Paperwork Reduction Act public meeting
Comment letter opposing Enova International’s application to become a bank holding company and acquire Grasshopper Bank
The Illinois Community Reinvestment Act
An in-depth video presentation going over the IL-CRA rules is available here.
Signed into law in March 2021, the Illinois Community Reinvestment Act (IL-CRA) creates an oversight system to ensure that residents are equitably served by all three main segments of the mortgage lending market: state-chartered banks, state-chartered credit unions, and mortgage companies. The Federal CRA only covers banks, but research shows that 60 to 70 percent of mortgages are originated by credit unions and mortgage companies.
In May 2024, Illinois regulators finalized rules for implementation of the IL-CRA. Woodstock Institute is currently working with the IL-CRA Coalition to educate stakeholders, including lenders and community organizations, on how the new law impacts their work. Learn more about the Coalition at ILCRACoalition.org.
Throughout 2025, Illinois regulators will begin evaluating financial institutions for IL-CRA compliance. For more information on who is currently being evaluated and how you can submit comments about these institutions, click here.
Fourth Quarter 2026 Illinois CRA Examination Schedule
Parkway Bank and Trust Company (Harwood Heights)
Community State Bank of Rock Falls (Rock Falls)
Premier Mortgage Resources, L.L.C. (Schaumburg)
Barrett Financial Group, L.L.C. (Lisle)
IH Mississippi Valley Credit Union (Moline)
Dupage Credit Union (Downers Grove)
Federal Community Reinvestment Act
The federal Community Reinvestment Act (CRA) became law in 1977 following a national grassroots movement against redlining, or the practice of denying credit to nonwhite and/or lower-income communities. Federal regulators evaluate CRA-covered banks based on their provision of safe and accessible financial products and services to the communities they serve, including lower-income communities.
CRA evaluations can then be used to evaluate applications for bank mergers, acquisitions, branch openings, and more. Over the decades, Woodstock Institute has leveraged this process to help negotiate community benefits agreements with financial institutions, which have channeled billions in investments to lower-income areas.
In October 2023, federal regulators released the first comprehensive update to the federal CRA rules since 1995. A webinar breaking down the positives and negatives of the finalized new rule is available here. UPDATE: In March 2025, the federal bank regulatory agencies announced their intent to rescind the CRA final rule issues in October 2023 and return to the prior CRA rule.
Racial Equity Lens
A key goal of Woodstock Institute’s CRA advocacy efforts is ensuring the laws explicitly address racial bias in lending. Decades of systemic discrimination in the financial sector have locked generations of Black and brown households out of homeownership and the wealth building opportunities it offers. This dynamic remains a major factor driving the racial wealth gap.
In “The CRA Prohibits Race Discrimination” longtime CRA expert and Woodstock Senior Research Fellow Calvin Bradford shows why considering race in CRA evaluations is central to the intent of the federal law.
For the IL-CRA, advocates succeeded in passing SB 3235 (fact sheet here) in 2024, which authorizes a study analyzing disparities experienced by protected classes under the Illinois Human Rights Act, including, but not limited to, race, national origin, sex and marital status. Illinois regulators can use the findings of this study as part of IL-CRA exams.
Featured Resources & Research
Illinois Community Reinvestment Act Coalition
Woodstock Institute co-leads the IL-CRA Coalition alongside Housing Action Illinois, which is a group of organizations dedicated to protecting and strengthening the federal and the Illinois Community Reinvestment Acts. More info and resources on both laws is available on the coalition website: ILCRACoalition.org.
Community Lending Data Portal and Fact Books
Since 1984, Woodstock has published and analyzed data on annual housing trends across the Chicago region down to the neighborhood level. Advocates can use this data to identify lending disparities and hold CRA-covered lenders accountable for their obligation to adequately serve the credit and financial service needs of lower-income communities.
CRA Mortgages: A Failure to Implement
This report uses Woodstock Institute’s annual Community Lending Fact Book data of mortgage lending in Chicago from 1984 to 2019 as a proxy to evaluate whether the CRA has achieved its goal of closing the gap in lending disparities.
Despite the data showing CRA banks failed to meet the goal of lending to low- and moderate-income borrowers and neighborhoods, with gaps widening substantially between 1984 and 1989, between 90 and 95% of banks received Satisfactory or Outstanding CRA ratings.
These findings suggest that CRA reform efforts must hold banks to a higher standard and include effective sanctions on financial institutions for receiving less than a Satisfactory rating.
Violating Your Way to an Outstanding CRA Rating
A series of Federal laws in the 1960s and 1970s was supposed to arm the bank regulatory agencies with the legal resources to overcome a long history of racial discrimination. It has not worked.
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