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.
Comments on the revised CRA proposal offered by the Federal Reserve Board for the regulation of intermediate small banks. Woodstock Institute finds that the proposal is an improvement over the one previously issued by the FDIC and a vast improvement over recent changes the OTS has made to its CRA regulation which eliminated several key provisions. The letter primarily addresses the elimination of the requirement to disclose small business data, regulation of bank branching, and the implementation of a community development test.
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 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 the proposed CRA
regulation would change the definition of “small bank” from any
institution with less that $250 million in assets and not part of a
holding company with over $1 billion in assets to include all
institutions with less than $500 million in assets regardless of
holding company size. This change will dramatically increase the number
of banks considered “small” that, for CRA purposes, are not examined
for their levels of community investment and services under the
streamlined small bank CRA examination.
Comment letter opposing the Office of Thrift Supervision’s proposed changes (No. 2004-53) to their regulation of the Community Reinvestment Act. The proposal would change the way that a “large” institution’s CRA rating is assigned, as well as broaden the definition of “community development” to include activities that do not benefit low- and moderate-income households and communities.
