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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 submitted to the Internal Revenue Service regarding the disclosure and use of tax return information by tax preparers for the purpose of marketing products such as RALs.
Comment letter in support of proposed
predatory lending regulations to the Joint Committee on Administrative
Rules as introduced in December, 2000 by Gov. George Ryan.
The rules would prohibit lump-sum financed credit life insurance,
require lenders to document that the borrower can repay the loan, limit
prepayment penalties that can trap borrowers in high-cost debt, and
prohibit balloon payments of less than 15 years. These rules do
not impose an interest rate cap and would allow lenders to price loans
according to risk.
Comment letter submitted to the Federal Reserve recommending that, in addition to meaningful national predatory lending legislative, existing protections should cover loans originated by all lenders. It continues to state that the Board must use its rulemaking authority under HOEPA and adopt the above guidelines in order to protect consumers from mortgages with unfair and deceptive terms.
Comment letter proposing revisions to the Federal Reserve Boards disclosure requirements for credit card and other open end credit under the Truth in Lending Act (TILA). These comments strong support the requirement to disclose the Annual Percent Rate for these types of credit.
Comment Letter to the Federal Reserve Board Suggesting Improvements to HOEPA Consumer Protections
02/27/2001
Respond to the request for comments by the Board of Governors of the
Federal Reserve System on changes to Regulation Z under the Home
Ownership and Equity Protection Act (HOEPA). HOEPA gives the Board
broad regulatory authority over the predatory lending issue. The
comment letter suggests several improvements to the proposed consumer
protections such as monthly payment disclosure, APR triggers, and
counseling requirements. 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 on a Federal Reserve
proposal requesting that the Federal Reserve set
a maximum permissible default or penalty rate for credit cards and include
additional borrower protections, eliminate double-cycle billing, eliminate
universal default, forbid unfair payment cut-off times, and add additional
borrower protections.
Comment letter to Federal Reserve Board Suggesting Expansion of Small Business Data Disclosure
11/03/1999
Comment letter on proposed Regulation B rule stating that small
business loan disclosure should mirror the provisions in the Home
Mortgage Disclosure Act for home mortgage disclosure data and that disclosure provisions should be extended to pre-applications. Comment letter requesting the favorable consideration of NSP-related services to middle-income communities contingent on a sunset provision, investments, loans, and services to NSP target areas, and the donation of blighted REO property contingent on support for demolition costs.
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