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 submitted to the Internal Revenue Service regarding the disclosure and use of tax return information by tax preparers for the purpose of marketing products such as RALs.
Comment letter proposing revisions to the Federal Reserve Board’s disclosure requirements for credit card and other open end credit under the Truth in Lending Act (TILA). These comments strong support the requirement to disclose the Annual Percent Rate for these types of credit.
Comment letter submitted to the Federal Reserve recommending that, in addition to meaningful national predatory lending legislative, existing protections should cover loans originated by all lenders. It continues to state that the Board must use its rulemaking authority under HOEPA and adopt the above guidelines in order to protect consumers from mortgages with unfair and deceptive terms.
Comment letter sent in support of recent proposed interagency questions and answers regarding community reinvestment. The proposal includes several changes to the list of qualified CRA activities including 1) stablishing a loan program to provide relief for low- and moderate-income homeowners facing foreclosure is an example of a type of program that is responsive to community credit needs, 2) assisting in foreclosure prevention counseling will be considered under community development services, 3)investing in a community development venture capital fund, or 4) participating in a SBA 504 loan over $1 million.
During the 2002-2005 regulatory review process, and again in this Q & A, Woodstock Institute has sought to clarify that any activity for which a bank receives CRA credit should directly impact low- and moderate-income people. Under the current regulatory guidance, banks may receive CRA credit for investing in projects that benefit middle- and upper-income individuals if that project is located in a designated distressed or underserved middle-income non-metropolitan geography or disaster areas. The letter also addresses the key concerns Woodstock Institute has raised during the past year regarding the evaluation of banks under the new intermediate small bank test, how innovative financial services are considered, and how innovative long-term investments should be considered if they extend beyond a single evaluation period.
