Woodstock Institute influences policy at the local, regional, and national level by closely analyzing the impact of pending proposals on lower-income and minority communities. Many of these letters are available for download.
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.
Suggestions submitted under the Advance Notice of Proposed Rulemaking
for the 2001 revisions to the 1995 regulation of the Community
Reinvestment Act. In particular these comments proposed different
qualifications for CRA qualified small business lending, evaluating
lending done by affiliates, and a new definition of community
development loan.
