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 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 in support of the proposed amendments to Regulation E which protects consumers using payroll cards from unauthorized transfers and undisclosed fees. This amendment would also define a payroll card account directly or indirectly established by an employer to receive wages, salary, or other employee compensation on a recurring basis as an account which receives the consumer protections of the federal Electronic Funds Transfer Act.
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.
Comment letter sent in support of recent proposed interagency questions and answers regarding community reinvestment. The proposal includes several changes to the list of qualified CRA activities including 1) stablishing a loan program to provide relief for low- and moderate-income homeowners facing foreclosure is an example of a type of program that is responsive to community credit needs, 2) assisting in foreclosure prevention counseling will be considered under community development services, 3)investing in a community development venture capital fund, or 4) participating in a SBA 504 loan over $1 million.
Comment letter in support of the National Credit Union Administration’s proposal to conduct a one-time survey of a sample of credit unions on their penetration of low- and moderate-income communities.
