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 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.
Written testimony outlining the five key principles of the Monsignor Egan Campaign for Payday Loan Reform presented to a working group on Short-Term Installment Lending sponsored by State Representative Julie Hamos.
Suggestions submitted under the Advance Notice of Proposed Rulemaking
for the 2001 revisions to the 1995 regulation of the Community
Reinvestment Act. In particular these comments proposed different
qualifications for CRA qualified small business lending, evaluating
lending done by affiliates, and a new definition of community
development loan.
Comment letter submitted in support of recent rules proposed by the Illinois Department of Financial and Professional Regulations (ILDFPR) developed in cooperation with the Egan Campaign for Payday Loan Reform.
The 2005 Payday Loan Reform Act applies to loans with terms of 120 or less, which the payday loan industry has circumvented by making loans with terms over 120 days. The proposed rules extended PLRA consumer protections to all payday loans, including those with terms over 120 days. Recent data documents that one-third of payday loans made to Illinois consumers in early February have terms over 120 days.
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.
