Files

DocumentsDate added

Comment letter on proposed interagency statement on subprime lending

May 21, 2007

Suggests that the responsible underwriting guidelines and the disclosure of a mortgage's full cost proposed in the interagency statement be applied to all loans, not strictly subprime adjustable-rate loans.

Comment letter on the proposed amendments to the rule implementing the Illinois Predatory Lending Database Pilot Program (HB4050)

May 21, 2007

Suggests several methods for screening loans in such a way as to reduce the number of loans covered by the law and more effectively focus the act and the resources of couseling agencies on borrowers seeking higher cost loans with potentially risky features.

Comment letter on proposed Department of Defense guidelines on small loan limits

February 06, 2007

Suggests the regulation implementing the small loan limits passed by the Department of Defense for service members and their dependants be applied all types of lenders, covers all types of loans not excluded by the law, and does place the burden on Service members to opt into protections.

Comments on 2007 FDIC Guidance on Small Loans

February 01, 2007

Comment letter in support of the proposed FDIC Guidelines for Affordable Small Dollar Lending announced in early December to assist banks in responsibly meeting the small loan needs of their customers. The letter also supports the proposal to reward banks through the Community Reinvestment Act for developing appropriate loan products as well as the proposal to limit interest rates on these types of products to 36 percent.

Comment letter to the Office of Thrift Supervision in Favor of CRA Regulatory Changes

January 19, 2007

Comment letter on 2006 Office of Thrift Supervision proposal to make its Community Reinvestment Act examination procedures consistent with the other federal bank regulatory agencies.