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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
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 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 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.
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 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.
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 on the revised Federal Reserve Board CRA proposal affecting intermediate small banks
05/06/2005
Comments on the revised CRA proposal offered by the Federal Reserve Board for the regulation of intermediate small banks. Woodstock Institute finds that the proposal is an improvement over the one previously issued by the FDIC and a vast improvement over recent changes the OTS has made to its CRA regulation which eliminated several key provisions. The letter primarily addresses the elimination of the requirement to disclose small business data, regulation of bank branching, and the implementation of a community development test. 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 opposing the Office of Thrift Supervision’s proposed changes (No. 2004-53) to their regulation of the Community Reinvestment Act. The proposal would change the way that a “large” institution’s CRA rating is assigned, as well as broaden the definition of “community development” to include activities that do not benefit low- and moderate-income households and communities.
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. |
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