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.

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.

This comment letter was submitted by Woodstock and a coalition of community reinvestment and consumer groups to the Office of the Comptroller of the Currency requesting that the agency immediately implement their tax refund anticipation loan (RAL) guidance. Additionally, it asks that no new banks be allowed into the RAL market and that a discussion is convened to plan the exit of banks from the RAL market in 2011.

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.

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 answers two of the nine questions posed by the IRS in Notice 2009-60. These two questions address the need for additional legislative, regulatory, or administrative rules to prohibit the sale of financial products connected with the tax preparation process, and the need for the IRS to register or license preparers, and establish testing and educational requirements. This comment letter will also illustrate the impact of refund anticipation loans on the asset-building potential of low-wealth people receiving the Earned Income Tax Credit (EITC) in the Chicago region.