Comment letter to CDFI Fund requesting that certification and funding criteria be expanded to include de novo financial institutions planning to organize as CDFIs.

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.

Comment letter submitted to the Federal Reserve Board opposing the proposed changes to the disclosure requirements for open-ended credit oppose the proposed changes to the disclosure requirements for open-ended credit.

Comment letter submitted in support of the Federal Reserve Board’s proposal to improve disclosure and prohibit yield spread premiums and to encourage the Board to strengthen the proposal by including loan amount in the definition of loan terms, and improve its anti-steering proposal.

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.

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.