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.

Comment letter opposing the proposed CRA regulation would change the definition of “small bank” from any institution with less that $250 million in assets and not part of a holding company with over $1 billion in assets to include all institutions with less than $500 million in assets regardless of holding company size. This change will dramatically increase the number of banks considered “small” that, for CRA purposes, are not examined for their levels of community investment and services under the streamlined small bank CRA examination.

Comment letter on the proposed housing goals for Fannie Mae and Freddie Mac covering years 2005 to 2008.  The letter suggests that stronger goals are necessary  in the areas of increasing homeownership among minorities, fighting predatory refinance lending, and improving access to financing for affordable multi-family rental housing.

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.

Comments 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.

Comment letter in support of the proposed amendments to Regulation E which protects consumers using payroll cards from unauthorized transfers and undisclosed fees.  This amendment would also define a payroll card account directly or indirectly established by an employer to receive wages, salary, or other employee compensation on a recurring basis as an account which receives the consumer protections of the federal Electronic Funds Transfer Act.

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 advance notice of proposed rulemaking (ANPR) on the open-end credit rules of Regulation Z.  Finds that some of the policies examined in the ANPR – such as increasing interest rates and credit limits on short notice to those in debt – are particularly destructive.  Suggests changes to the regulation that would end unreasonable fees, deceptive payment allocation, cut-off times, and universal default.

Comments on the revised CRA proposal offered by the Federal Reserve Board for the regulation of intermediate small banks.  Woodstock Institute finds that the proposal is an improvement over the one previously issued by the FDIC and a vast improvement over recent changes the OTS has made to its CRA regulation which eliminated several key provisions.  The letter primarily addresses the elimination of the requirement to disclose small business data, regulation of bank branching, and the implementation of a community development test.