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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 to Federal Reserve Board in support of changes to regulation of stored value cards
11/18/2004
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 to CDFI Fund requesting that certification and funding criteria be expanded to include de novo financial institutions planning to organize as CDFIs. 
Comment letter supporting the FRB proposal to improve disclosure and prohibit yield spread premiums
02/04/2010
Comment letter submitted in support of the Federal Reserve Board’s proposal to improve disclosure and prohibit yield spread premiums and to encourage the Board to strengthen the proposal by including loan amount in the definition of loan terms, and improve its anti-steering proposal. 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.
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 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. In this comment letter submitted to the OCC regarding the implementation of te Dodd-Frank, Woodstock Institute urges the agency to repeal its existing preemption orders, make public its process for the preemption of existing state consumer protections and to apply the reformulated preemption standard with the intent of expanding, rather than reducing, consumer protections.
Comment letter submitted to the House Financial Services Committee requesting that all activities of auto dealers related to the financing of cars are fully included under the jurisdiction of the Consumer Financial Protection Agency.
Woodstock Institute comments to the FDIC's Advisory Committee on Economic Inclusion regarding the proposed templates for safe, low-cost transactional and basic savings account products for lower-wealth consumers. This comment letter was submitted by Woodstock and a coalition of community reinvestment and consumer groups to the Office of the Comptroller of the Currency requesting that the agency immediately implement their tax refund anticipation loan (RAL) guidance. Additionally, it asks that no new banks be allowed into the RAL market and that a discussion is convened to plan the exit of banks from the RAL market in 2011. |
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