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.
Woodstock Institute submitted a comment letter requesting the denial of the application of H&R Block to become a national thrift. The OTS, which regulates thrifts and approved the application in March of 2006, should withhold approval based on new information provided by the Attorney General of New York describing the bank's intent to use the thrift charter to continue offering a type of retirement product that has been shown to consume any potential earnings with undisclosed fees.
Respond to the request for comments by the Board of Governors of the
Federal Reserve System on changes to Regulation Z under the Home
Ownership and Equity Protection Act (HOEPA). HOEPA gives the Board
broad regulatory authority over the predatory lending issue. The
comment letter suggests several improvements to the proposed consumer
protections such as monthly payment disclosure, APR triggers, and
counseling requirements.
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.
Comment letter opposing the proposed NCUA rule part 701.1 which would restrict the adoption of underserved areas to credit unions with a multiple common bond charter.
Comments on the FDIC's proposed changes to their regulation of the Community Reinvestment Act (RIN3064-AC50) which would repleace the three part test with the lending and community development test for FDIC banks between $250 million and $1 billion in assets.
