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.
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.
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.
Comment letter in support of the FDIC’s Interim
Final Rule to permit state non-member banks to participate or assist in
financial education programs conducted on school premises, including the receipt
of deposits, payment of checks, or lending of money.
Comment letter on Bank of America’s proposed 2003 acquisition of
Fleet. Woodstock Institute requests that the Federal Reserve Bank
of Richmond and the Federal Reserve Board hold multiple public hearings
on Bank of America’s acquisition of Fleet.
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.
