Comments in response to the 2002 interagency Advanced Notice of Proposed Rulemaking on the Community Reinvestment Act.  Woodstock Institute comments support the current regulations and primarily address Section 1 on large retail institutions, Section 2 on small banks, and Section 3, addressing the CRA examination of wholesale banks under the community development test.  Comments on the activities of affiliates, the strategic plan option, community contacts procedure, the definition of assessment areas, and the collection and distribution of public data files are also included.

Respond to the request for comments by the Board of Governors of the Federal Reserve System on changes to Regulation Z under the Home Ownership and Equity Protection Act (HOEPA). HOEPA gives the Board broad regulatory authority over the predatory lending issue.  The comment letter suggests several improvements to the proposed consumer protections such as monthly payment disclosure, APR triggers, and counseling requirements.

Woodstock Institute's comments in response to the request for comments by the Board of Governors of the Federal Reserve System on proposed changes to Regulation C: Home Mortgage Disclosure Act data regulations.  The letter supports the proposed changes to require the collection of the annual percentage rate, HOEPA status, and manufactured home status.  Additionally, the letter suggests that additional fields should be adding including points and fees, the age of the applicant, and an indicator of credit history.

Comment letter in support of  proposed predatory lending regulations to the Joint Committee on Administrative Rules as introduced in December, 2000 by Gov. George Ryan.  The rules would prohibit lump-sum financed credit life insurance, require lenders to document that the borrower can repay the loan, limit prepayment penalties that can trap borrowers in high-cost debt, and prohibit balloon payments of less than 15 years.  These rules do not impose an interest rate cap and would allow lenders to price loans according to risk.

Comment letter on proposed Regulation B rule stating that small business loan disclosure should mirror the provisions in the Home Mortgage Disclosure Act for home mortgage disclosure data and that disclosure provisions should be extended to pre-applications.