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 proposed interagency guidance on overdraft protection finds that the the guidance will not protect consumers from a risky “service” that effectively amounts to a short-term, high-rate loan program. Suggests that bounced check loans ought to be regulated under the Truth in Lending Act rather than the Truth in Saving Act. TILA coverage would require that banks disclose the APR, solicit the affirmative assent of the consumer before enrolling them in a bounced check loan product, and ensures private right of action.
Comment letter on the proposed housing goals for
Fannie Mae and Freddie Mac covering years 2005 to 2008. The
letter suggests that stronger goals are necessary in the areas of
increasing homeownership among minorities, fighting predatory refinance
lending, and improving access to financing for affordable multi-family
rental housing.
Woodstock Institute's comment letter opposing the OCC preemption of state consumer protection statutes for
national banks. This preemption removed much of the consumer and fair
lending authority previously granted to states by Congress and failed to provide a national policy to protect borrowers from
abusive lending practices.
Comment letter on Bank of America’s proposed 2003 acquisition of
Fleet. Woodstock Institute requests that the Federal Reserve Bank
of Richmond and the Federal Reserve Board hold multiple public hearings
on Bank of America’s acquisition of Fleet.
Comments on the revised CRA proposal offered by the Federal Reserve Board for the regulation of intermediate small banks. Woodstock Institute finds that the proposal is an improvement over the one previously issued by the FDIC and a vast improvement over recent changes the OTS has made to its CRA regulation which eliminated several key provisions. The letter primarily addresses the elimination of the requirement to disclose small business data, regulation of bank branching, and the implementation of a community development test.
