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 submitted to the Federal Reserve recommending that, in addition to meaningful national predatory lending legislative, existing protections should cover loans originated by all lenders. It continues to state that the Board must use its rulemaking authority under HOEPA and adopt the above guidelines in order to protect consumers from mortgages with unfair and deceptive terms.
Comment letter proposing revisions to the Federal Reserve Board’s disclosure requirements for credit card and other open end credit under the Truth in Lending Act (TILA). These comments strong support the requirement to disclose the Annual Percent Rate for these types of credit.
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 on a Federal Reserve
proposal requesting that the Federal Reserve set
a maximum permissible default or penalty rate for credit cards and include
additional borrower protections, eliminate double-cycle billing, eliminate
universal default, forbid unfair payment cut-off times, and add additional
borrower protections.
Comment on a Federal
Reserve proposal requiring financial institutions to provide an opt-out right
for overdraft loan programs. Woodstock believes that this is insufficient and
the Proposed Rule should be modified to require consumers to opt in, rather than
opt out.
