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.
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.
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 on a Federal
Reserve proposal requiring financial institutions to provide an opt-out right
for overdraft loan programs. Woodstock believes that this is insufficient and
the Proposed Rule should be modified to require consumers to opt in, rather than
opt out.
Comment letter in support of the FDIC’s Interim
Final Rule to permit state non-member banks to participate or assist in
financial education programs conducted on school premises, including the receipt
of deposits, payment of checks, or lending of money.
Comment on a Federal Reserve
proposal requesting that the Federal Reserve set
a maximum permissible default or penalty rate for credit cards and include
additional borrower protections, eliminate double-cycle billing, eliminate
universal default, forbid unfair payment cut-off times, and add additional
borrower protections.
