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Woodstock Institute comment letter requesting clarification of Morgan Stanley’s Community Reinvestment Act responsibilities as a bank holding company

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fed_may2009_morganstanley.pdf

Comment
letter stating requesting that the Federal Reserve expand the CRA
responsibilities of Morgan Stanley Bank beyond its historic Salt Lake County
Utah CRA Assessment Area since it converted to a bank holding company. 
Since Morgan Stanley does not meet any of the exemptions of Section 2c2 of the
Bank Holding Company Act, the comment letter requests that the bank’s
assessment areas include the locations of all 500 Morgan Stanley Branches that
provide full deposit services.  We ask the Federal Reserve to require
Morgan Stanley to provide a full CRA plan that details how it will provide
deposit services, mortgage loans, small business loans, and community
development investments, loans and services for low and moderate income
households in the assessment areas of its 500 branches. 

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