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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
Written testimony outlining the five key principles of the Monsignor Egan Campaign for Payday Loan Reform presented to a working group on Short-Term Installment Lending sponsored by State Representative Julie Hamos.
Woodstock Institute supports the OCC rule implementing the Housing and Economic Recovery Act of 2008 which permits national banks to make qualified direct or indirect investments in community development projects totaling 15 percent of their combined tier one and tier two capital, so long as 51 percent of the portfolio benefits low- and moderate-income communities or families.
Woodstock Institute endorses the "Protecting Consumers from Unreasonable Credit Rates Act"
03/05/2009
Woodstock Institute endorses the “Protecting Consumers from Unreasonable Credit
Rates Act” as introduced by Senator Richard Durbin. The Act limits the total
cost of consumer credit to 36 percent.
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.
Woodstock asks federal banking regulators to modify CRA regulations to ensure purchsed loans are not resold merely to inflate their value for CRA purposes, and pro rate CRA credit for mixed-income housing development.
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.
Woodstock Institute supports the Illinois Department of Financial and Professional Regulation proposed changes to the definition of a short-term title-secured loan under the Consumer Installment Loan Act and suggests eight additional protections necessary to eliminate other abuses common to the automobile title loan industry.
Woodstock Institute submitted a comment letter requesting the denial of the application of H&R Block to become a national thrift. The OTS, which regulates thrifts and approved the application in March of 2006, should withhold approval based on new information provided by the Attorney General of New York describing the bank's intent to use the thrift charter to continue offering a type of retirement product that has been shown to consume any potential earnings with undisclosed fees.
Opposes amendment to 2005 appropriations bill which would undermine the final rules adopted by the U.S. Department of the Treasury in accordance with Section 326 of the USA PATRIOT Act, which allows for financial institutions to accept the Matricula Consular.
Comments to OCC Opposing Preemption of State Consumer Protection and Predatory Lending Laws
09/30/2003
Woodstock Institute's comment letter opposing the OCC preemption of state consumer protection statutes for
national banks. This preemption removed much of the consumer and fair
lending authority previously granted to states by Congress and failed to provide a national policy to protect borrowers from
abusive lending practices. |
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