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Legislative and Regulatory Comment Letters
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.
DocumentsDate addedComments 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.
Suggests the regulation implementing the small loan limits passed by the Department of Defense for service members and their dependants be applied all types of lenders, covers all types of loans not excluded by the law, and does place the burden on Service members to opt into protections.
Comment letter on 2006 Office of Thrift Supervision proposal to make its Community Reinvestment Act examination procedures consistent with the other federal bank regulatory agencies.
Comment Letter Supporting NCUA Survey of Credit Union's Service to Low- and Moderate-Income People
03/09/2006
Comment letter in support of the National Credit Union Administration’s proposal to conduct a one-time survey of a sample of credit unions on their penetration of low- and moderate-income communities.
Comment letter opposing the proposed NCUA rule part 701.1 which would restrict the adoption of underserved areas to credit unions with a multiple common bond charter.
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.
Comment letter opposing the Office of Thrift Supervision’s proposed changes (No. 2004-53) to their regulation of the Community Reinvestment Act. The proposal would change the way that a “large” institution’s CRA rating is assigned, as well as broaden the definition of “community development” to include activities that do not benefit low- and moderate-income households and communities. 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.
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 proposing revisions to the Federal Reserve Boards 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.
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