Comment letter on proposed Regulation B rule stating that small business loan disclosure should mirror the provisions in the Home Mortgage Disclosure Act for home mortgage disclosure data and that disclosure provisions should be extended to pre-applications.

Comment letter in support of  proposed predatory lending regulations to the Joint Committee on Administrative Rules as introduced in December, 2000 by Gov. George Ryan.  The rules would prohibit lump-sum financed credit life insurance, require lenders to document that the borrower can repay the loan, limit prepayment penalties that can trap borrowers in high-cost debt, and prohibit balloon payments of less than 15 years.  These rules do not impose an interest rate cap and would allow lenders to price loans according to risk.

Woodstock Institute's comments in response to the request for comments by the Board of Governors of the Federal Reserve System on proposed changes to Regulation C: Home Mortgage Disclosure Act data regulations.  The letter supports the proposed changes to require the collection of the annual percentage rate, HOEPA status, and manufactured home status.  Additionally, the letter suggests that additional fields should be adding including points and fees, the age of the applicant, and an indicator of credit history.

Respond to the request for comments by the Board of Governors of the Federal Reserve System on changes to Regulation Z under the Home Ownership and Equity Protection Act (HOEPA). HOEPA gives the Board broad regulatory authority over the predatory lending issue.  The comment letter suggests several improvements to the proposed consumer protections such as monthly payment disclosure, APR triggers, and counseling requirements.

Comments in response to the 2002 interagency Advanced Notice of Proposed Rulemaking on the Community Reinvestment Act.  Woodstock Institute comments support the current regulations and primarily address Section 1 on large retail institutions, Section 2 on small banks, and Section 3, addressing the CRA examination of wholesale banks under the community development test.  Comments on the activities of affiliates, the strategic plan option, community contacts procedure, the definition of assessment areas, and the collection and distribution of public data files are also included.

Woodstock Institute comments to the Office of the Comptroller of the Currency on National City’s request to the OCC to pre-empt the Georgia Fair Lending Act.  National City claims that the National Bank Act authorizes the OCC to occupy the field of real estate lending regulation thus suggesting that all the provisions of GFLA are preempted.

Woodstock Institute strongly urges  the IRS to not expand pre-certification beyond the initial group of 45,000 filers before a comprehensive evaluation demonstrating that pre-certification is effective in reducing overpayments and can be conducted without significant harm to eligible filers.

Comment letter opposing any changes to the Section 326 customer identification rules that would not allow financial institutions to accept certain types of foreign government-issued identification, such as the Matricula Consular card, to open bank accounts for immigrants.  The letter states that the use of the Matricula Consular card has allowed thousands of families of Mexican origin to access financial services in the traditional banking sector rather than pay exorbitant rates at check cashers and payday loan stores.

Woodstock Institute's comment letter opposing the OCC preemption of state consumer protection statutes for national banks. This preemption removed much of the consumer and fair lending authority previously granted to states by Congress and failed to provide a national policy to protect borrowers from abusive lending practices.