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.
Woodstock Institute comments to the Office of the
Comptroller of the Currency on National City’s request to the OCC to
pre-empt the Georgia Fair Lending Act. National City claims that
the National Bank Act authorizes the OCC to occupy the field of real
estate lending regulation thus suggesting that all the provisions of
GFLA are preempted.
Woodstock Institute strongly urges the IRS
to not expand pre-certification beyond the initial group of 45,000
filers before a comprehensive evaluation demonstrating that
pre-certification is effective in reducing overpayments and can be
conducted without significant harm to eligible filers.
Comment letter opposing any changes to the Section
326 customer identification rules that would not allow financial
institutions to accept certain types of foreign government-issued
identification, such as the Matricula Consular card, to open bank
accounts for immigrants. The letter states that the use of the
Matricula Consular card has allowed thousands of families of Mexican
origin to access financial services in the traditional banking sector
rather than pay exorbitant rates at check cashers and payday loan
stores.
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.
