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 the proposed interagency guidance on overdraft protection finds that the the guidance will not protect consumers from a risky “service” that effectively amounts to a short-term, high-rate loan program. Suggests that bounced check loans ought to be regulated under the Truth in Lending Act rather than the Truth in Saving Act. TILA coverage would require that banks disclose the APR, solicit the affirmative assent of the consumer before enrolling them in a bounced check loan product, and ensures private right of action.
Woodstock Institute comments to federal banking regulators regarding the proposed Questions and Answers for the implementation of the Community Reinvestment Act regulations adopted by the Office of Thrift Supervision. Comments support a common, interagency definition of "community development" and encourage the OTS to adopt the "intermediate small bank" test currently in use by the remaining three bank regulators.
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.
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 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.
