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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 supports the Illinois Department of Financial and Professional Regulation proposed changes to the definition of a short-term title-secured loan under the Consumer Installment Loan Act and suggests eight additional protections necessary to eliminate other abuses common to the automobile title loan industry.
Comment letter in response to proposed Federal Reserve appraisal and evaluation guidelines
01/23/2009
Comment letter in response to proposed Federal Reserve appraisal and evaluation
guidelines suggesting necessary changes to eliminate the undue influence of
brokers on the appraisal and evaluation process, establish robust internal
controls for the appraisal process during the loan origination process.
Woodstock
recommends additional quality controls for institutions purchasing
mortgage-backed securities.
Woodstock Institute endorses the "Protecting Consumers from Unreasonable Credit Rates Act"
03/05/2009
Woodstock Institute endorses the “Protecting Consumers from Unreasonable Credit
Rates Act” as introduced by Senator Richard Durbin. The Act limits the total
cost of consumer credit to 36 percent.
Woodstock asks federal banking regulators to modify CRA regulations to ensure purchsed loans are not resold merely to inflate their value for CRA purposes, and pro rate CRA credit for mixed-income housing development.
Woodstock Institute submitted a comment letter to the Office of the Comptroller
of the Currency to request that the OCC take action to establish meaningful
third party supervision requirements for national banks that partner with tax
preparers to make refund anticipation loans (RALs) A recent ruling by the FDIC
establishes a new standard requiring banks to supervise and monitor their
partner tax preparers for compliance with safety and soundness and consumer
protection laws. The letter argues that the same standards should be adopted by
the OCC for the national banks engaged in RAL lending.
Woodstock comment letter submitted in support of the Illinois Department of Human Services proposed elimination of the asset test for the Food Stamp program. The proposed change would adopt the categorical eligibility rule and eliminate the asset test, allowing more Illinois individuals and families to qualify for federally-funded Food Stamp benefits. In addition, Illinois residents would be encouraged to build savings and assets that would assist them in maintaining self-sufficiency.
Woodstock comment letter submitted in support of the Illinois Department of Human Services proposed elimination of the asset test in TANF and GA, which would encourage families to build savings and assets.
Comment letter submitted in support of the proposed changes to the rules implementing the Community Reinvestment Act (CRA) as they apply to assessing an institution’s record of providing low-cost education loans. The comment letter also opposes a proposed rule change that would allow financial institutions to receive favorable consideration under the Community Reinvestment Act for investments in women- and minority-owned financial institutions or low-income credit unions outside of the communities in which the financial institutions does business. 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 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.
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