Comment letter submitted to House Financial Services Committee outlining concerns that educational services might inadvertently fall outside the jurisdiction of the proposed Consumer Financial Protection Agency's jurisdiction.

This comment letter was submitted by Woodstock Institute and members of Americans for Financial Reform and requests that the House Financial Services Committee include enforcement of the Community Reinvestment Act in the mandate of the Consumer Protection Agency.

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.

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 opposing the proposed CRA regulation would change the definition of “small bank” from any institution with less that $250 million in assets and not part of a holding company with over $1 billion in assets to include all institutions with less than $500 million in assets regardless of holding company size. This change will dramatically increase the number of banks considered “small” that, for CRA purposes, are not examined for their levels of community investment and services under the streamlined small bank CRA examination.

Woodstock Institute strongly urges  the IRS to not expand pre-certification beyond the initial group of 45,000 filers before a comprehensive evaluation demonstrating that pre-certification is effective in reducing overpayments and can be conducted without significant harm to eligible filers.

Comment letter opposing any changes to the Section 326 customer identification rules that would not allow financial institutions to accept certain types of foreign government-issued identification, such as the Matricula Consular card, to open bank accounts for immigrants.  The letter states that the use of the Matricula Consular card has allowed thousands of families of Mexican origin to access financial services in the traditional banking sector rather than pay exorbitant rates at check cashers and payday loan stores.