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 on the advance notice of proposed rulemaking (ANPR) on the open-end credit rules of Regulation Z. Finds that some of the policies examined in the ANPR – such as increasing interest rates and credit limits on short notice to those in debt – are particularly destructive. Suggests changes to the regulation that would end unreasonable fees, deceptive payment allocation, cut-off times, and universal default.
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.
Comment letter in support of the proposed amendments to Regulation E which protects consumers using payroll cards from unauthorized transfers and undisclosed fees. This amendment would also define a payroll card account directly or indirectly established by an employer to receive wages, salary, or other employee compensation on a recurring basis as an account which receives the consumer protections of the federal Electronic Funds Transfer Act.
Opposes amendment to 2005 appropriations bill which would undermine the final rules adopted by the U.S. Department of the Treasury in accordance with Section 326 of the USA PATRIOT Act, which allows for financial institutions to accept the Matricula Consular.
