Testimony of Geoff Smith, Woodstock Institute
research associate, to the Illinois Office of Banks and Real Estate on
several proposed changes. Woodstock opposes changes to the
regulation of high risk loans because the changes do not add any
substantive protections. Woodstock supports the proposed
licensing changes and the increase in the net worth requirements for
mortgage lenders and brokers.
Woodstock President Malcolm Bush argues that the
State Farm application will establish a critical precedent for the
terms under which insurance companies enter the banking business and in
this case seriously violates the letter and intent of the CRAand its
regulations.