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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
Comment Letter on Proposed Interagency Questions and Answers Regarding Community Reinvestment
01/06/2006
Woodstock Institute has submitted comment letters to federal banking regulators regarding the Proposed Interagency Questions and Answers regarding Community Reinvestment. During the 2002-2005 regulatory review process, and again in this Q & A, Woodstock Institute has sought to clarify that any activity for which a bank receives CRA credit should directly impact low- and moderate-income people. Under the current regulatory guidance, banks may receive CRA credit for investing in projects that benefit middle- and upper-income individuals if that project is located in a designated distressed or underserved middle-income non-metropolitan geography or disaster areas. The letter also addresses the key concerns Woodstock Institute has raised during the past year regarding the evaluation of banks under the new intermediate small bank test, how innovative financial services are considered, and how innovative long-term investments should be considered if they extend beyond a single evaluation period.
Comment Letter Supporting NCUA Survey of Credit Union's Service to Low- and Moderate-Income People
03/09/2006
Comment letter in support of the National Credit Union Administration’s proposal to conduct a one-time survey of a sample of credit unions on their penetration of low- and moderate-income communities. 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.
Comment letter opposing the proposed NCUA rule part 701.1 which would restrict the adoption of underserved areas to credit unions with a multiple common bond charter.
Comment letter submitted in support of recent rules proposed by the Illinois Department of Financial and Professional Regulations (ILDFPR) developed in cooperation with the Egan Campaign for Payday Loan Reform. The 2005 Payday Loan Reform Act applies to loans with terms of 120 or less, which the payday loan industry has circumvented by making loans with terms over 120 days. The proposed rules extended PLRA consumer protections to all payday loans, including those with terms over 120 days. Recent data documents that one-third of payday loans made to Illinois consumers in early February have terms over 120 days.
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.
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.
Suggests the regulation implementing the small loan limits passed by the Department of Defense for service members and their dependants be applied all types of lenders, covers all types of loans not excluded by the law, and does place the burden on Service members to opt into protections.
Suggests that the responsible underwriting guidelines and the disclosure of a mortgage's full cost proposed in the interagency statement be applied to all loans, not strictly subprime adjustable-rate loans.
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