Woodstock Institute's response to the Consumer Financial Protection Bureau's request for information on promoting affordability in the private student loan market. The letter describes the growing need for better options to help private student loan borrowers avoid defaulting on their loans and summarizes key principles that should be included in any affordability program, drawing upon lessons learned from mortgage modification programs. Woodstock Institute's response to the Consumer Financial Protection Bureau's request for information on promoting affordability in the private student loan market. The letter describes the growing need for better options to help private student loan borrowers avoid defaulting on their loans and summarizes key principles that should be included in any affordability program, drawing upon lessons learned from mortgage modification programs.

Sign-on letter Sen. Mark Kirk asking him to confirm Richard Cordray as Director of the Consumer Financial Protection Bureau. Delaying his confirmation because of political brinksmanship would harm consumers, introduce destructive uncertainty into the financial system, and allow predatory financial practices to flourish.

Woodstock Institute response to the Consumer Financial Protection Bureau’s Advanced Notice of Proposed Rulemaking on general purpose reloadable cards. Comments address three main areas of consumer protection that the Consumer Financial Protection Bureau should address as part of its rulemaking process: the regulatory coverage of products; product fees and disclosures; and, product features. Woodstock requests that Regulation E be extended to all GPR cards and the FDIC insurance be required. Woodstock also recommends that credit products, such as overdraft or deposit advance products, be prohibited.

Woodstock Institute response to the Consumer Financial Protection Bureau's request for information on overdraft protection programs describing challenges to developing low-cost alternatives to overdraft programs, the need to develop an overdraft guidance specific to the payment channel used to overdraft, and the importance of placing regulatory limitations on repeat usage of overdraft programs.

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.