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.
Comments in response to the 2002 interagency
Advanced Notice of Proposed Rulemaking on the Community Reinvestment
Act. Woodstock Institute comments support the current regulations
and primarily address Section 1 on large retail institutions, Section 2
on small banks, and Section 3, addressing the CRA examination of
wholesale banks under the community development test. Comments on
the activities of affiliates, the strategic plan option, community
contacts procedure, the definition of assessment areas, and the
collection and distribution of public data files are also included.
Suggestions submitted under the Advance Notice of Proposed Rulemaking
for the 2001 revisions to the 1995 regulation of the Community
Reinvestment Act. In particular these comments proposed different
qualifications for CRA qualified small business lending, evaluating
lending done by affiliates, and a new definition of community
development loan.
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.
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.
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.
