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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.
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Suggests several methods for screening loans in such a way as to reduce the number of loans covered by the law and more effectively focus the act and the resources of couseling agencies on borrowers seeking higher cost loans with potentially risky features.
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 sent in support of recent proposed interagency questions and answers regarding community reinvestment. The proposal includes several changes to the list of qualified CRA activities including 1) stablishing a loan program to provide relief for low- and moderate-income homeowners facing foreclosure is an example of a type of program that is responsive to community credit needs, 2) assisting in foreclosure prevention counseling will be considered under community development services, 3)investing in a community development venture capital fund, or 4) participating in a SBA 504 loan over $1 million.
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 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 the FDIC’s Interim Final Rule to permit state non-member banks to participate or assist in financial education programs conducted on school premises, including the receipt of deposits, payment of checks, or lending of money.
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.
Written testimony outlining the five key principles of the Monsignor Egan Campaign for Payday Loan Reform presented to a working group on Short-Term Installment Lending sponsored by State Representative Julie Hamos.
Woodstock Institute supports the OCC rule implementing the Housing and Economic Recovery Act of 2008 which permits national banks to make qualified direct or indirect investments in community development projects totaling 15 percent of their combined tier one and tier two capital, so long as 51 percent of the portfolio benefits low- and moderate-income communities or families.
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