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 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 on proposed Regulation B rule stating that small
business loan disclosure should mirror the provisions in the Home
Mortgage Disclosure Act for home mortgage disclosure data and that disclosure provisions should be extended to pre-applications.
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.
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.
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.