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 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.
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.
Comment letter on the proposed housing goals for
Fannie Mae and Freddie Mac covering years 2005 to 2008. The
letter suggests that stronger goals are necessary in the areas of
increasing homeownership among minorities, fighting predatory refinance
lending, and improving access to financing for affordable multi-family
rental housing.
Comment letter opposing the proposed CRA
regulation would change the definition of “small bank” from any
institution with less that $250 million in assets and not part of a
holding company with over $1 billion in assets to include all
institutions with less than $500 million in assets regardless of
holding company size. This change will dramatically increase the number
of banks considered “small” that, for CRA purposes, are not examined
for their levels of community investment and services under the
streamlined small bank CRA examination.
Comment letter on Bank of America’s proposed 2003 acquisition of
Fleet. Woodstock Institute requests that the Federal Reserve Bank
of Richmond and the Federal Reserve Board hold multiple public hearings
on Bank of America’s acquisition of Fleet.
