Comments submitted by Woodstock president Dory Rand to the Federal Reserve Board in response to a proposed rule for a Qualified Mortgage or QM. The comments support an obligation to verify, not just consider, the additional criteria. In addition, the comments request that underwriting be based on the maximum interest rate for the entire loan, not just the first five years.

This comment letter describes Woodstock Institute concerns with the application of automated overdraft consumer protections to deposit advance loan products or "bank-based payday loans." Woodstock argues that these types of product are fundamentally different from automated overdraft, has associated payment and reputational risks that exceed the scope of the proposed guidance, and requires substantially different consumer protections.

In this comment letter submitted to the OCC regarding the implementation of te Dodd-Frank, Woodstock Institute urges the agency to repeal its existing preemption orders, make public its process for the preemption of existing state consumer protections and to apply the reformulated preemption standard with the intent of expanding, rather than reducing, consumer protections.

Woodstock Institute submitted this comment letter in support of the USDA proposed rule to no longer counting tax-preferred retirement accounts and education accounts toward the SNAP eligibility resource limit and request several clarifications. Because there is a wide variety of education savings instruments, with different account statements, Woodstock Institute believes that it may be difficult to identify the tax status of a particular type of account. The Department should issue guidance outlining the process by which eligibility workers may identify an education savings or retirement account that must be excluded under this provision.

Discusses the types of financial institutions that should have reinvestment responsibilities and the geographies where those responsibilities are assessed. Also includes recommendations to improve the services test portion of the CRA and improve the ratings and incentive structure of the CRA.

Recommends that the FDIC limit overdrafts to one per day and six per year as well as extend opt-in requirements to non-electronic transactions.

Comment letter requesting the favorable consideration of NSP-related services to middle-income communities contingent on a sunset provision, investments, loans, and services to NSP target areas, and the donation of blighted REO property contingent on support for demolition costs.

Woodstock Institute comments to the FDIC's Advisory Committee on Economic Inclusion regarding the proposed templates for safe, low-cost transactional and basic savings account products for lower-wealth consumers.