August 7, 2012 Ms.

Angelisa Harris Community Affairs Officer Federal Deposit Insurance Corporation-Chicago Regional Office 300 South Riverside Plaza - Suite 1700 Chicago, Illinois 60606 RE: OPPOSITION TO THE SALE OF NORTHERN TRUST SOUTHSIDE BRANCH

Dear Ms. Harris The Monroe Foundation, a 21 year-old community advocacy coalition of 100 community and faithbased groups working to improve the economic quality of life within communities of color through the formation of community reinvestment and investment collaborations with financial institutions, opposes the pending sale of the 79thand State Street community branch of the Northern Trust Company to Urban Partnership Bank without benefit of a public hearing. The 79thand State Street community branch location of the Northern Trust Company was opened in result from the many years this institution neglected to have an urban market presence serving this constituency of clientele, and as a result of a history of adverse lending issues in which federal regulators and community groups have long held (greatly attributed to the lack of a community reinvestment (CRA) commitment to low- to moderate income (LMI)_residents of the Southside, primarily, African American communities). Respectfully, the members of the Monroe Foundation express the following concerns:

1.) Sale of the 79thand State Street branch will eliminate any Northern Trust Company physical
branch commitment to LMI communities and qualifying CRA activity through any of its branch locations on the Southside of Chicago .

2.) If regulatory approval is granted, the Northern Trust Companys CRA qualifying market
presence will be limited to providing access to transactional services through eight ATMs placed primarily in McDonalds restaurants on the Southside of Chicago (assuming Northern Trust will continue to have control of the ATMs albeit the potential reality that these machines could become controlled by Urban Partnership Bank).

The Monroe Foundation 1547 South Wolf Road, Hillside, IL60162 (t) 773.315.9720 (e) omonroe@themonroefoundation.org www.themonroefoundation.org

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3.) In light of the above stated potential reality, that if the ATMs become Urban Partnership Bank
ATMs, then, again, the Northern Trust Companys commitment to Southside communities is effectively eliminated. The Monroe Foundations extreme concern is summed in a simple question: Now, 20 years later, must the LMI African American community relive the nightmare brought on by the potential sale of this branch location, which once was a victory for community reinvestment to ensure that an institution that formerly had little history of such on the Southside of Chicago will potentially become nonexistent again, should regulators approve this sale? We urge regulators to hold a public hearing for the constituents most adversely affectedon the Southside of Chicago, and require Northern Trust Company officials to offer its recommendations as to how selling its only Southside LMI branch location will still allow the institution to demonstrate a commitment to banking, lending and CRA qualifying investments on the Southside of Chicago, and through which strategies it will engage to continue a commitment to community reinvestment, absent a physical branch. Further, we ask you to help save this very important Northern Trust community bank branch! Respectfully,

Otis C. Monroe, III, CEO cc: Federal Regulators

The Monroe Foundation 1547 South Wolf Road, Hillside, IL60162 (t) 773.315.9720 (e) omonroe@themonroefoundation.org www.themonroefoundation.org