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.
Woodstock Institute submitted a comment letter requesting the denial of the application of H&R Block to become a national thrift. The OTS, which regulates thrifts and approved the application in March of 2006, should withhold approval based on new information provided by the Attorney General of New York describing the bank's intent to use the thrift charter to continue offering a type of retirement product that has been shown to consume any potential earnings with undisclosed fees.
Woodstock Institute's comments in response to the
request for comments by the Board of Governors of the Federal Reserve
System on proposed changes to Regulation C: Home Mortgage Disclosure
Act data regulations. The letter supports the proposed changes to
require the collection of the annual percentage rate, HOEPA status, and
manufactured home status. Additionally, the letter suggests that
additional fields should be adding including points and fees, the age
of the applicant, and an indicator of credit history.
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.
Suggests several methods for screening loans in such a way as to reduce the number of loans covered by the law and more effectively focus the act and the resources of couseling agencies on borrowers seeking higher cost loans with potentially risky features.
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.
