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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 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.
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 on the proposed housing goals for
Fannie Mae and Freddie Mac covering years 2005 to 2008. The
letter suggests that stronger goals are necessary in the areas of
increasing homeownership among minorities, fighting predatory refinance
lending, and improving access to financing for affordable multi-family
rental housing.
Suggests that the responsible underwriting guidelines and the disclosure of a mortgage's full cost proposed in the interagency statement be applied to all loans, not strictly subprime adjustable-rate loans.
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.
Suggests the regulation implementing the small loan limits passed by the Department of Defense for service members and their dependants be applied all types of lenders, covers all types of loans not excluded by the law, and does place the burden on Service members to opt into protections.
Woodstock Institute comments to the Office of the
Comptroller of the Currency on National City’s request to the OCC to
pre-empt the Georgia Fair Lending Act. National City claims that
the National Bank Act authorizes the OCC to occupy the field of real
estate lending regulation thus suggesting that all the provisions of
GFLA are preempted.
Comment letter on Bank of America’s proposed 2003 acquisition of
Fleet. Woodstock Institute requests that the Federal Reserve Bank
of Richmond and the Federal Reserve Board hold multiple public hearings
on Bank of America’s acquisition of Fleet.
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.
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.
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