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Legislative and Regulatory Comment Letters
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.

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Comment Letter to the Office of Thrift Supervision on Proposed Interagency Questions and Answers Regarding Community Reinvestment
June 12, 2006
Woodstock Institute comments to federal banking regulators regarding the proposed Questions and Answers for the implementation of the Community Reinvestment Act regulations adopted by the Office of Thrift Supervision.  Comments support a common, interagency definition of "community development" and encourage the OTS to adopt the "intermediate small bank" test currently in use by the remaining three bank regulators.
Comment letter to the Office of Thrift Supervision in Favor of CRA Regulatory Changes
January 19, 2007
Comment letter on 2006 Office of Thrift Supervision proposal to make its Community Reinvestment Act examination procedures consistent with the other federal bank regulatory agencies.
Comments on 2007 FDIC Guidance on Small Loans
February 01, 2007
Comment letter in support of the proposed FDIC Guidelines for Affordable Small Dollar Lending announced in early December to assist banks in responsibly meeting the small loan needs of their customers. The letter also supports the proposal to reward banks through the Community Reinvestment Act for developing appropriate loan products as well as the proposal to limit interest rates on these types of products to 36 percent.
Comment letter on proposed Department of Defense guidelines on small loan limits
February 06, 2007
Suggests the regulation implementing the small loan limits passed by the Department of Defense for service members and their dependants be applied all types of lenders, covers all types of loans not excluded by the law, and does place the burden on Service members to opt into protections.
Comment letter on proposed interagency statement on subprime lending
May 21, 2007
Suggests that the responsible underwriting guidelines and the disclosure of a mortgage's full cost proposed in the interagency statement be applied to all loans, not strictly subprime adjustable-rate loans.
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