Testimony of Tom Feltner, vice president of Woodstock Institute, addressing deposit insurance, access to mainstream financial products, and credit products such as overdraft protection or payday loan-like deposit advances for general purpose reloadable cards.

Testimony of Spencer Cowan, vice president of Woodstock Institute, on access to employment-based retirement savings plans in Illinois.

Senior Vice President Geoff Smith testifies before the Housing Committee of the Illinois House of Representatives on the issue of "red flag" properties and servicer accountability.

Testimony before the US House of Representatives Subcommittee on Oversight and Investigations on OTS’s actions to weaken CRA.  Comments offered suggestions to promote improvements to CRA that would increase access to lending, investments, and services in low- and moderate-income markets such as the requiring the continued reporting of small business lending data for mid-sized banks and thrifts.  They also requested that the OTS collect data on new retail accounts opened for low- and moderate-income households; and promoting investment in declining and underserved rural markets.  

While HMDA data have been a valuable tool in fighting discrimination and redlining and improving access to credit to underserved markets, there are substantial opportunities to improve the data collected to make it even more effective. One of the main limitations of the current HMDA data is the lack of sufficient information on underwriting and product characteristics. One of the major frustrations experienced when analyzing HMDA data is being able to document clear patterns that indicate discriminatory lending, but lacking the necessary data to prove that discrimination is occurring. This frustration has been compounded by the lack of action taken by regulatory agencies in the face of clear indications of discriminatory lending behavior. Whle the Dodd-Frank Act will add key data points that will solve many of these concerns, Woodstock believes that there is still opportunity to improve the data collected.

Woodstock Institute opposes this merger on the grounds that Capital One has an inadequate past record of meeting community financial needs. We also believe that the combined financial institution, as the fifth largest bank by deposits with a vulnerable portfolio heavily concentrated in credit cards, would pose significant risk to the financial system. Finally, this application demonstrates the inadequacy of current regulatory for ensuring that large financial institutions with limited branch networks are meeting the lending and financial services needs of low-wealth communities.