Woodstock Institute submitted a comment letter in opposition to NuMark Credit Union’s application to acquire The Lemont National Bank. These two institutions’ past and continuous failure to serve the economic investment needs of their communities inform Woodstock Institute’s position that their merging will almost certainly widen racial disparities in mortgage lending and harm low- and moderate income Illinois communities in particular.
Woodstock Institute reached this conclusion based on The Lemont National Bank’s five consecutive failing ratings under the Community Reinvestment Act (CRA) and NuMark’s demonstrable racial inequities in loan originations and denials. Given these factors, Woodstock Institute is concerned that the proposed acquisition will only exacerbate lending disparities in our communities.
Read our full comment letter below.
Re: Woodstock Institute comment in opposition to the application by NuMark Credit Union to acquire The Lemont National Bank, and a request for public hearings.
Woodstock Institute submits this comment on the application of NuMark Credit Union (NuMark) to acquire all assets and liabilities of The Lemont National Bank (Lemont Bank) as announced in March 2025. These two institutions’ past and continuous failure to serve the unique needs of their communities inform Woodstock Institute’s position that their merging will widen racial disparities in mortgage lending and harm Illinois communities. We protest this acquisition.
Lemont Bank has no Home Mortgage Disclosure Act (HMDA) data available, but it has repeatedly received “Substantial Non-Compliance” ratings under the Community Reinvestment Act (CRA) in 2015, 2018, 2021, and 2024. Furthermore, it received a “Needs to Improve” rating in 2012, meaning that despite prior warnings, Lemont Bank’s CRA violations have only grown more egregious. The public portions of these CRA exams highlight the same core issue of the bank’s unacceptably low loan-to-deposit (LTD) ratio. From the 2015 exam through the 2024 exam, it seems the bank never even reached a 20% LTD ratio, while peer institutions performed well above that level at around 60-70%.
To earn a “Substantial Noncompliance” rating even once raises a bevy of concerns. Research shows that in recent years 98% of banks received a passing rating on their CRA exam. To fail to meet the bare minimum of CRA obligations not once but five consecutive exams in a row, spanning more than a decade, demonstrates a pattern of systematic neglect or willful disregard for regulatory standards. This is reinforced by the fact that the bank entered into a consent order with the Office of the Comptroller of the Currency in 2024 after the regulator identified safety and soundness concerns. This level of repeated failure suggests serious deficiencies in overall institutional responsibility.
Examining NuMark’s track record does not inspire confidence that this acquisition would meaningfully address Lemont Bank’s problems. An analysis of NuMark’s 2018-2023 HMDA data reveals significant racial disparities in loan originations and denials. Black applicants experience the most pronounced inequities. Black applicants were approved at a rate of 45.9%, compared to 69.5% for White applicants—a disparity ratio of 1.5. Black applicants accounted for 23% of denials, despite being 12.8% of applicants, nearly 2.4 times higher than white applicants. Overall, Black applicants face the largest gaps in both originations (45.9% vs. 69.5% for White applicants) and denials (19.5% vs. 8% for White applicants). Similar, though less severe, disparities exist for Latine, Multiracial, and “Race Not Reported” groups. Latine, Multiracial, and “Race Not Reported” groups also face denial rates 1.7–2.1 times higher than White applicants. These findings raise concerns about systemic barriers to equitable lending and warrant immediate action to align NuMark’s practices with its stated mission of “enriching the financial lives of its members.”
Additionally, very few NuMark Credit Union branches are located in majority-minority census tracts. There are no NuMark branches located in majority-Black census tracts and only three branches lie within a 3-mile radius of majority-Black areas, suggesting potential gaps in physical access. In Cook County, the single branch location within a 3-mile radius of a majority-Black area only serves the northernmost of a Black population that extends all the way into Will County. Given that NuMark has a community common bond and residents of a large swath of Northern and Central Illinois and Northwest Indiana are eligible for membership, the lack of access in communities of color cannot be explained by membership limitations. The lack of branch presence in majority-minority areas combined with the disparities in loan originations and denials suggests that NuMark’s lending practices may not be equitably serving communities of color.
Given these factors, the proposed acquisition of Lemont National Bank by NuMark Credit Union raises serious concerns. Rather than addressing the decade-long issues of Lemont National Bank’s compliance with CRA standards, this acquisition risks exacerbating disparities in lending that both institutions already perpetuate separately. Without clear and enforceable commitments to improving access to credit, increasing investments in underserved communities, and ensuring compliance with fair lending practices, this acquisition does not serve the public interest. As such, Woodstock Institute urges the Office of the Comptroller of the Currency, National Credit Union Administration, and Illinois Department of Financial and Professional Regulation to deny the application of NuMark Credit Union to acquire The Lemont National Bank.
