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 on the FDIC's proposed changes to their regulation of the Community Reinvestment Act (RIN3064-AC50) which would repleace the three part test with the lending and community development test for FDIC banks between $250 million and $1 billion in assets.
Comment letter on the advance notice of proposed rulemaking (ANPR) on the open-end credit rules of Regulation Z. Finds that some of the policies examined in the ANPR – such as increasing interest rates and credit limits on short notice to those in debt – are particularly destructive. Suggests changes to the regulation that would end unreasonable fees, deceptive payment allocation, cut-off times, and universal default.
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 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.
Woodstock Institute comments to federal banking regulators regarding the proposed Questions and Answers for the implementation of the Community Reinvestment Act regulations adopted by the Office of Thrift Supervision. Comments support a common, interagency definition of "community development" and encourage the OTS to adopt the "intermediate small bank" test currently in use by the remaining three bank regulators.
