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 the advance notice of proposed rulemaking (ANPR) on the open-end credit rules of Regulation Z. Finds that some of the policies examined in the ANPR – such as increasing interest rates and credit limits on short notice to those in debt – are particularly destructive. Suggests changes to the regulation that would end unreasonable fees, deceptive payment allocation, cut-off times, and universal default.
Comment letter opposing the proposed NCUA rule part 701.1 which would restrict the adoption of underserved areas to credit unions with a multiple common bond charter.
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 in support of proposed
predatory lending regulations to the Joint Committee on Administrative
Rules as introduced in December, 2000 by Gov. George Ryan.
The rules would prohibit lump-sum financed credit life insurance,
require lenders to document that the borrower can repay the loan, limit
prepayment penalties that can trap borrowers in high-cost debt, and
prohibit balloon payments of less than 15 years. These rules do
not impose an interest rate cap and would allow lenders to price loans
according to risk.
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.
