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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
Comments opposing the FRB proposed changes to the disclosure requirements for open-ended credit
02/04/2010
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. Woodstock Institute's comments in response to the
request for comments by the Board of Governors of the Federal Reserve
System on proposed changes to Regulation C: Home Mortgage Disclosure
Act data regulations. The letter supports the proposed changes to
require the collection of the annual percentage rate, HOEPA status, and
manufactured home status. Additionally, the letter suggests that
additional fields should be adding including points and fees, the age
of the applicant, and an indicator of credit history. 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 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.
Comment letter in support of the proposed FDIC Guidelines for Affordable Small Dollar Lending announced in early December to assist banks in responsibly meeting the small loan needs of their customers. The letter also supports the proposal to reward banks through the Community Reinvestment Act for developing appropriate loan products as well as the proposal to limit interest rates on these types of products to 36 percent.
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. Woodstock Institute submitted this comment letter in support of the USDA proposed rule to no longer counting tax-preferred retirement accounts and education accounts toward the SNAP eligibility resource limit and request several clarifications. Because there is a wide variety of education savings instruments, with different account statements, Woodstock Institute believes that it may be difficult to identify the tax status of a particular type of account. The Department should issue guidance outlining the process by which eligibility workers may identify an education savings or retirement account that must be excluded under this provision.
Woodstock Institute comments to federal banking regulators regarding the proposed Questions and Answers for the implementation of the Community Reinvestment Act regulations adopted by the Office of Thrift Supervision. Comments support a common, interagency definition of "community development" and encourage the OTS to adopt the "intermediate small bank" test currently in use by the remaining three bank regulators.
Comment letter on 2006 Office of Thrift Supervision proposal to make its Community Reinvestment Act examination procedures consistent with the other federal bank regulatory agencies.
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. |
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