While HMDA data have been a valuable tool in fighting discrimination and redlining and improving access to credit to underserved markets, there are substantial opportunities to improve the data collected to make it even more effective. One of the main limitations of the current HMDA data is the lack of sufficient information on underwriting and product characteristics. One of the major frustrations experienced when analyzing HMDA data is being able to document clear patterns that indicate discriminatory lending, but lacking the necessary data to prove that discrimination is occurring. This frustration has been compounded by the lack of action taken by regulatory agencies in the face of clear indications of discriminatory lending behavior. Whle the Dodd-Frank Act will add key data points that will solve many of these concerns, Woodstock believes that there is still opportunity to improve the data collected.

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.

Testimony presented to the Office of Thrift Supervision opposing Republic Bancorp’s application for a charter conversion from a bank holding company to a savings and loan holding company.  Discusses the impact of the RAL product on lower-income Chicago communities and need to eliminate the refund anticipation loan product or require additional consumer protections.

Testimony before the US House of Representatives Subcommittee on Oversight and Investigations on OTS’s actions to weaken CRA.  Comments offered suggestions to promote improvements to CRA that would increase access to lending, investments, and services in low- and moderate-income markets such as the requiring the continued reporting of small business lending data for mid-sized banks and thrifts.  They also requested that the OTS collect data on new retail accounts opened for low- and moderate-income households; and promoting investment in declining and underserved rural markets.  

Woodstock Institute opposes this merger on the grounds that Capital One has an inadequate past record of meeting community financial needs. We also believe that the combined financial institution, as the fifth largest bank by deposits with a vulnerable portfolio heavily concentrated in credit cards, would pose significant risk to the financial system. Finally, this application demonstrates the inadequacy of current regulatory for ensuring that large financial institutions with limited branch networks are meeting the lending and financial services needs of low-wealth communities.