Woodstock Institute submitted these comments to the Illinois Department of Financial and Professional Regulation in response to their Advanced Notice of Proposed Rulemaking.
The issues associated with the drafting of implementing rules from which to enforce the IL-CRA are not dissimilar to those facing the Federal bank regulatory agencies as they strive to modernize the Federal CRA.
Illinois has the opportunity to shape and lead that discussion and address the challenges of defining “community” in an increasingly virtual world, of incorporating the growth and scale of lenders that exist outside the regulatory scope of the Federal CRA, and rectifying some of the unintended consequences associated with the current Federal CRA regulation in advance of reform efforts.
