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