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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 added
Advanced Notice of Proposed Rulemaking Comments on 2001 Changes to the 1995 Regulation of CRA
03/20/2001
Suggestions submitted under the Advance Notice of Proposed Rulemaking
for the 2001 revisions to the 1995 regulation of the Community
Reinvestment Act. In particular these comments proposed different
qualifications for CRA qualified small business lending, evaluating
lending done by affiliates, and a new definition of community
development loan.
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 in response to 2002 interagency ANPR on changes to the Community Reinvestment Act
10/09/2001
Comments in response to the 2002 interagency
Advanced Notice of Proposed Rulemaking on the Community Reinvestment
Act. Woodstock Institute comments support the current regulations
and primarily address Section 1 on large retail institutions, Section 2
on small banks, and Section 3, addressing the CRA examination of
wholesale banks under the community development test. Comments on
the activities of affiliates, the strategic plan option, community
contacts procedure, the definition of assessment areas, and the
collection and distribution of public data files are also included. 
Comment letter in response to proposed Federal Reserve appraisal and evaluation guidelines
01/23/2009
Comment letter in response to proposed Federal Reserve appraisal and evaluation
guidelines suggesting necessary changes to eliminate the undue influence of
brokers on the appraisal and evaluation process, establish robust internal
controls for the appraisal process during the loan origination process.
Woodstock
recommends additional quality controls for institutions purchasing
mortgage-backed securities.
Comment letter submitted in support of the proposed changes to the rules implementing the Community Reinvestment Act (CRA) as they apply to assessing an institution’s record of providing low-cost education loans. The comment letter also opposes a proposed rule change that would allow financial institutions to receive favorable consideration under the Community Reinvestment Act for investments in women- and minority-owned financial institutions or low-income credit unions outside of the communities in which the financial institutions does business. Comment letter in support of the FDIC’s Interim Final Rule to permit state non-member banks to participate or assist in financial education programs conducted on school premises, including the receipt of deposits, payment of checks, or lending of money. Woodstock comment letter submitted in support of the Illinois Department of Human Services proposed elimination of the asset test for the Food Stamp program. The proposed change would adopt the categorical eligibility rule and eliminate the asset test, allowing more Illinois individuals and families to qualify for federally-funded Food Stamp benefits. In addition, Illinois residents would be encouraged to build savings and assets that would assist them in maintaining self-sufficiency.
Woodstock comment letter submitted in support of the Illinois Department of Human Services proposed elimination of the asset test in TANF and GA, which would encourage families to build savings and assets.
Comment letter on Bank of America’s proposed 2003 acquisition of
Fleet. Woodstock Institute requests that the Federal Reserve Bank
of Richmond and the Federal Reserve Board hold multiple public hearings
on Bank of America’s acquisition of Fleet. Woodstock Institute comments to the Office of the
Comptroller of the Currency on National City’s request to the OCC to
pre-empt the Georgia Fair Lending Act. National City claims that
the National Bank Act authorizes the OCC to occupy the field of real
estate lending regulation thus suggesting that all the provisions of
GFLA are preempted.
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