Legislative and Regulatory Comment Letters

Woodstock Institute influences policy at the local, regional, and national level by closely analyzing the impact of pending proposals on low-wealth communities and communities of color.
September 27, 2010

Discusses the types of financial institutions that should have reinvestment responsibilities and the geographies where those responsibilities are assessed. Also includes recommendations to improve the services test portion of the CRA and improve the ratings and incentive structure of the CRA.

September 2, 2010

Recommends that the FDIC limit overdrafts to one per day and six per year as well as extend opt-in requirements to non-electronic transactions.


July 8, 2010

Comment letter requesting the favorable consideration of NSP-related services to middle-income communities contingent on a sunset provision, investments, loans, and services to NSP target areas, and the donation of blighted REO property contingent on support for demolition costs.

June 8, 2010

Woodstock Institute comments to the FDIC's Advisory Committee on Economic Inclusion regarding the proposed templates for safe, low-cost transactional and basic savings account products for lower-wealth consumers.

April 7, 2010

Comment letter to CDFI Fund requesting that certification and funding criteria be expanded to include de novo financial institutions planning to organize as CDFIs.

February 5, 2010

This comment letter was submitted by Woodstock and a coalition of community reinvestment and consumer groups to the Office of the Comptroller of the Currency requesting that the agency immediately implement their tax refund anticipation loan (RAL) guidance. Additionally, it asks that no new banks be allowed into the RAL market and that a discussion is convened to plan the exit of banks from the RAL market in 2011.

February 4, 2010

Comment letter submitted to the Federal Reserve Board opposing the proposed changes to the disclosure requirements for open-ended credit oppose the proposed changes to the disclosure requirements for open-ended credit.

February 4, 2010

Comment letter submitted in support of the Federal Reserve Board’s proposal to improve disclosure and prohibit yield spread premiums and to encourage the Board to strengthen the proposal by including loan amount in the definition of loan terms, and improve its anti-steering proposal.

October 14, 2009
This comment letter was submitted by Woodstock Institute and members of Americans for Financial Reform and requests that the House Financial Services Committee include enforcement of the Community Reinvestment Act in the mandate of the Consumer Protection Agency.
October 8, 2009
Comment letter submitted to House Financial Services Committee outlining concerns that educational services might inadvertently fall outside the jurisdiction of the proposed Consumer Financial Protection Agency's jurisdiction.
October 6, 2009
Comment letter submitted to the House Financial Services Committee requesting that all activities of auto dealers related to the financing of cars are fully included under the jurisdiction of the Consumer Financial Protection Agency.
August 31, 2009

This comment letter answers two of the nine questions posed by the IRS in Notice 2009-60. These two questions address the need for additional legislative, regulatory, or administrative rules to prohibit the sale of financial products connected with the tax preparation process, and the need for the IRS to register or license preparers, and establish testing and educational requirements. This comment letter will also illustrate the impact of refund anticipation loans on the asset-building potential of low-wealth people receiving the Earned Income Tax Credit (EITC) in the Chicago region.

July 31, 2009

Comment letter submitted in support of the proposed changes to the rules implementing the Community Reinvestment Act (CRA) as they apply to assessing an institution’s record of providing low-cost education loans.  The comment letter also opposes a proposed rule change that would allow financial institutions to receive favorable consideration under the Community Reinvestment Act for investments in women- and minority-owned financial institutions or low-income credit unions outside of the communities in which the financial institutions does business.

May 27, 2009

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. 

May 20, 2009
Woodstock comment letter submitted in support of the Illinois Department of Human Services proposed elimination of the asset test in TANF and GA, which would encourage families to build savings and assets.
May 20, 2009

Woodstock comment letter submitted in support of the Illinois Department of Human Services proposed elimination of the asset test for the Food Stamp program. The proposed change would adopt the categorical eligibility rule and eliminate the asset test, allowing more Illinois individuals and families to qualify for federally-funded Food Stamp benefits. In addition, Illinois residents would be encouraged to build savings and assets that would assist them in maintaining self-sufficiency.


April 15, 2009
Woodstock Institute submitted a comment letter to the Office of the Comptroller of the Currency to request that the OCC take action to establish meaningful third party supervision requirements for national banks that partner with tax preparers to make refund anticipation loans (RALs) A recent ruling by the FDIC establishes a new standard requiring banks to supervise and monitor their partner tax preparers for compliance with safety and soundness and consumer protection laws. The letter argues that the same standards should be adopted by the OCC for the national banks engaged in RAL lending.
March 9, 2009
Woodstock asks federal banking regulators to modify CRA regulations to ensure purchsed loans are not resold merely to inflate their value for CRA purposes, and pro rate CRA credit for mixed-income housing development.
March 5, 2009
Woodstock Institute endorses the “Protecting Consumers from Unreasonable Credit Rates Act” as introduced by Senator Richard Durbin.  The Act limits the total cost of consumer credit to 36 percent.
January 23, 2009
Comment letter in response to proposed Federal Reserve appraisal and evaluation guidelines suggesting necessary changes to eliminate the undue influence of brokers on the appraisal and evaluation process, establish robust internal controls for the appraisal process during the loan origination process. Woodstock recommends additional quality controls for institutions purchasing mortgage-backed securities.
September 10, 2008
This comment letter was submitted to formally request a public meeting so that community groups and customers unable to submit a written comment will have the chance to raise their objections to Republic’s business practices and to the requested change in charter. This wider participation will help to rectify the inadequacy of written comments to express the widespread concern about the negative impact of Republic’s refund anticipation lending on lower income people.

September 10, 2008
Woodstock Institute supports the Illinois Department of Financial and Professional Regulation proposed changes to the definition of a short-term title-secured loan under the Consumer Installment Loan Act and suggests eight additional protections necessary to eliminate other abuses common to the automobile title loan industry.

September 9, 2008
Woodstock Institute supports the OCC rule implementing the Housing and Economic Recovery Act of 2008 which permits national banks to make qualified direct or indirect investments in community development projects totaling 15 percent of their combined tier one and tier two capital, so long as 51 percent of the portfolio benefits low- and moderate-income communities or families.

August 25, 2008
Written testimony outlining the five key principles of the Monsignor Egan Campaign for Payday Loan Reform presented to a working group on Short-Term Installment Lending sponsored by State Representative Julie Hamos.

July 21, 2008
Comment on a Federal Reserve proposal requesting that the Federal Reserve set a maximum permissible default or penalty rate for credit cards and include additional borrower protections, eliminate double-cycle billing, eliminate universal default, forbid unfair payment cut-off times, and add additional borrower protections.
July 21, 2008
Comment on a Federal Reserve proposal requiring financial institutions to provide an opt-out right for overdraft loan programs.  Woodstock believes that this is insufficient and the Proposed Rule should be modified to require consumers to opt in, rather than opt out.
July 10, 2008

Comment letter in support of the FDIC’s Interim Final Rule to permit state non-member banks to participate or assist in financial education programs conducted on school premises, including the receipt of deposits, payment of checks, or lending of money.

April 22, 2008
Woodstock Institute testimony requesting the Federal Reserve Board to require a public action plan to address problem loans before approving the acquisition of Countrywide Financial by Bank of America.
April 7, 2008
Comment letter submitted to the Internal Revenue Service regarding the disclosure and use of tax return information by tax preparers for the purpose of marketing products such as RALs.
October 12, 2007
Comment letter proposing revisions to the Federal Reserve Board’s disclosure requirements for credit card and other open end credit under the Truth in Lending Act (TILA).  These comments strong support the requirement to disclose the Annual Percent Rate for these types of credit.