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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.

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Woodstock Institute submitted this comment letter in support of the USDA proposed rule to no longer counting tax-preferred retirement accounts and education accounts toward the SNAP eligibility resource limit and request several clarifications. Because there is a wide variety of education savings instruments, with different account statements, Woodstock Institute believes that it may be difficult to identify the tax status of a particular type of account. The Department should issue guidance outlining the process by which eligibility workers may identify an education savings or retirement account that must be excluded under this provision.

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.

 

This comment letter describes Woodstock Institute concerns with the application of automated overdraft consumer protections to deposit advance loan products or "bank-based payday loans." Woodstock argues that these types of product are fundamentally different from automated overdraft, has associated payment and reputational risks that exceed the scope of the proposed guidance, and requires substantially different consumer protections.

Comments submitted by Woodstock president Dory Rand to the Federal Reserve Board in response to a proposed rule for a Qualified Mortgage or QM. The comments support an obligation to verify, not just consider, the additional criteria. In addition, the comments request that underwriting be based on the maximum interest rate for the entire loan, not just the first five years.


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