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 proposing revisions to the Federal Reserve Board’s disclosure requirements for credit card and other open end credit under the Truth in Lending Act (TILA). These comments strong support the requirement to disclose the Annual Percent Rate for these types of credit.
Comment letter sent in support of recent proposed interagency questions and answers regarding community reinvestment. The proposal includes several changes to the list of qualified CRA activities including 1) stablishing a loan program to provide relief for low- and moderate-income homeowners facing foreclosure is an example of a type of program that is responsive to community credit needs, 2) assisting in foreclosure prevention counseling will be considered under community development services, 3)investing in a community development venture capital fund, or 4) participating in a SBA 504 loan over $1 million.
Comment letter submitted to the Federal Reserve recommending that, in addition to meaningful national predatory lending legislative, existing protections should cover loans originated by all lenders. It continues to state that the Board must use its rulemaking authority under HOEPA and adopt the above guidelines in order to protect consumers from mortgages with unfair and deceptive terms.
Suggests several methods for screening loans in such a way as to reduce the number of loans covered by the law and more effectively focus the act and the resources of couseling agencies on borrowers seeking higher cost loans with potentially risky features.
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.
