Comment Letters and Testimony

* Most comment letters and testimony below are in PDF format.

• August 4, 2008  NEDAP comment letter urging Federal Reserve Board to strenthen proposed changes to Regulation AA: Unfair or Deceptive Acts or Practices that would curb abusive credit card and overdraft practices. NEDAP also submitted a joint comment letter with 14 other New York-based groups.

• August 4, 2008  Written testimony delivered to NYC Department of Consumer Affairs, on process server practices that harm low income New Yorkers and deprive them of due process.  The testimony was originally delivered at a public hearing, on June 13, 2008.

• May 12, 2008  Testimony delivered to the New York State Senate Banks Committee, at a hearing on "Evaluating the Governor's Program Bill to Address Mortgage Foreclosures and Subprime Lending in New York State."  NEDAP testimony, calling on the state legislature to pass strong legislation to curb lending abuses in the mortgage market.

• April 29, 2008  Testimony delivered to Federal Reserve Board at public hearing in Los Angeles on Bank of America's proposed acquisition of Countrywide.  NEDAP testimony, calling on Federal Reserve not to approve the acqusition unless Bank of America provides a detailed, concrete plan, in writing, for modifying or otherwise remediating Countrywide's abusive loans, among other steps.

• April 8, 2008  Comment Letter to Federal Reserve Board on proposed revisions to Regulation Z regarding unfair and deceptive mortgage lending practices.  NEDAP comment letter, submitted with South Brooklyn Legal Services, urging Federal Reserve Board to adopt strong, comprehensive mortgage lending regulations.

• April 4 , 2008  Comment Letter:  IRS Advanced Notice of Proposed Rulemaking - Regarding Marketing of Refund Anticipation Loans in Connection with the Preparation of a Tax Return  NEDAP comment letter to the IRS regarding the IRS's proposed rulemaking to prohibit tax preparers from disclosing taxpayers' information in order to make them a tax refund anticipation loans (RALs). 

• February 11 , 2008  Testimony: U.S. House of Representatives Financial Services Committee, Subcommittee on Financial Institutions and Consumer Credit               NEDAP testimony presented at hearing, "Effects of the Subprime Mortgage Crisis in New York City and Efforts to Help Struggling Homeowners." 

• September 14 , 2007  NEDAP signs on to New Yorkers for Responsible Lending comment letter to NYS Banking Department, supporting existing check casher regulations and the continued prohibition on payday lending in New York State.

• July 11 , 2007 Testimony: U.S. House of Representatives Financial Services Committee, Subcommittee on Financial Institutions and Consumer Credit
  NEDAP testimony presented at hearing, "Overdraft Protection: Fair Practices for Consumers."

• May 29, 2007 Testimony: NYS Assembly Hearing on Subprime Lending & Foreclosures
  NEDAP testimony presented at hearing before the NYS Assembly Standing Committees on Judiciary, Banks, Consumer Affairs and Protection, Housing, Oversight, and Analysis and Investigation.

• May 7, 2007 Federal Regulators' Proposal: Statement on Subprime Mortgage Lending
  NEDAP comment letter on the Federal Reserve, OCC, OTS, and FDIC's statement regarding subprime mortgage lending.

• April 16, 2007 Testimony before the NYS Senate Committee on Consumer Protection and NYS Assembly Committees on Consumer Affairs and Protection, and Banks

NEDAP delivered testimony on abusive credit card and debt collection practices, at the invitation of the NYS Senate and Assembly, which held a joint hearing on the issues, in Albany.

• April 9, 2007  Sign-On Letter: Provisions to Address Tax Refund Lending Abuses

NEDAP participated in the framing of this letter, which addresses abuses in the tax refund anticipation lending industry and suggests provisions to stem these abuses. The letter, signed by organizations nation-wide, was sent to federal legislators.

 

• January 26, 2007  Public Testimony on the Tax payer Bill of Rights, 1 and 2

Testimony submitted at a public hearing held by the New York City Council Committee on Consumer Affairs, regarding "Int. 81 - in Relation to the Consumer Bill of Rights Regarding Tax Payers." NEDAP testimony focused on Refund Anticipation Loans.

 

• October 20, 2006  Testimony: Insurance Fund and Data Disclosure Bills

Testimony submitted at a public hearing held by the NYS Assembly Standing Committee on Insurance and Subcommitee on Insurer Investments and Market Practices in Underserved Areas, regarding "Guarding Against Inequities in the Residential Insurance Market and Insurance Company Investments in Underserved Areas of New York State," or Assembly Bills 5737A and 11512.

 

• October 5, 2006 - Testimony: Financial Services for Low-Income Consumers

NEDAP submitted testimony at a public hearing held by the NYS Assembly Standing Committees on Consumer Affairs & Protection and Banks, regarding financial services for low-income consumers in New York.  NEDAP also delivered testimony at the hearing on behalf of New Yorkers for Responsible Lending.  for NYRL testimony.

• October 4, 2006  Testimony: Banks' Discontinuance of Money Service Business Accounts

Testimony submitted at a public hearing held by the NYS Assembly Standing Committees on Consumer Affairs & Protection and Banks, regarding the effect of banks' discontinuance of money service business accounts on low income immigrant New Yorkers.

• June 2006 Proposed Merger Comment Letter: JPMorgan Chase & The Bank of New York

Comment letter, submitted to the Office of the Comptroller of the Currency, in opposition to Chase's application to acquire 338 bank branches, $14.5 billion in deposits and $7.8 in loan balances from The Bank of New York.   NEDAP submitted the letter along with Empire Justice Center, the Foreclosure Prevention Project at South Brooklyn Legal Services, Good Jobs New York, and NYPIRG.

• March 8 , 2006 IRS Proposal: Privacy Protections for Taxpayers
  NEDAP comment letter urging the Internal Revenue Service to improve privacy protections for taxpayers utilizing pay-for-service tax preparers.

• November 21 , 2005 NYS Banking Dept: Overdraft "Bounce Protection"
  NYRL comment letter in opposition to NYS Banking Department proposal to allow state-chartered financial institutions to strip away existing consumer protections, and enable state-chartered financial insitutions to impose substantially higher charges in their overdraft bounce protection charges.

• September 23, 2005 Bank Charter Proposal: Wal-Mart FDIC Insurance
  NEDAP comment letter to the FDIC opposing Wal-Mart's application to receive insurance for its proposed industrial loan bank charter.

• August 19, 2005 Predatory Lending Proposal: 2005 "Ney-Kanjorski" Bill
  NYRL comment letter in opposition to Ney-Kanjorski bill (H.R. 1295) and in support of Miller-Watt-Frank bill (H.R. 1182).
  

• August 5, 2005 Amicus Brief: Enforce Fair Lending Laws
  "Friend of the court" brief filed in support of NYS Attorney General Spitzer's efforts to enforce fair lending laws.  Brief filed with 15 other national and New York State groups in the case of Office of the Comptroller of the Currency v. Eliot Spitzer; The Clearinghouse Association, L.L.C. v. Eliot Spitzer.

• May 10, 2005 Federal Regulators' Proposal: Changes to Community Reinvestment Act
  NEDAP comment letter on the Federal Reserve, OCC and FDIC's proposed changes to the Community Reinvestment Act.
  

• November 19, 2004 Federal Reserve Proposal: Payroll and Stored Value Cards
  RYSE comment letter asking the Federal Reserve Board of Governors to extend consumer protections to cover payroll cards and stored value cards.
  

• November 4, 2004 2004 NYC Consolidated Plan
  Comment letter in response to New York City's 2004 Proposed Consolidated Plan.
  

• October 20, 2004 FDIC Proposal: Changes to the Community Reinvestment Act
  Comment letter in opposition to the FDIC's proposed changes the definition of small banks in the Community Reinvestment Act (CRA).
  

• August 6, 2004 Federal Reserve Proposal: Overdraft "Bounce Protection"
  Comment letter in opposition to the Federal Reserve's proposed regulation of bounce protection under the Truth in Savings Act (TISA) instead of the Truth in Lending Act (TILA).
  

• April 6, 2004 Federal Regulators' Proposal: Changes to the Community Reinvestment Act
  Comment letter in opposition to the OCC, Federal Reserve, FDIC, and OTS's proposed changes to CRA.
  

• March 15, 2004 Proposed Merger Comment Letter: J.P. Morgan Chase & Bank One
  Comment letter to the Federal Reserve on the proposed merger of Chase and Bank One.
  

• October 6, 2003 OCC Proposal: Preemption of State Law
  Comment letter to the Office of the Comptroller of the Currency opposing rule that would preempt state consumer protections for nationally chartered banks.
  

• June 11, 2003 NYS OTDA Proposal: Electronic Benefits Transfer
  Comment letter to the Office of Temporary and Disability Assistance on Electronic Benefits Transfer (EBT) implementation.
  

• March 14, 2003 FDIC Proposal: Payday Lending
  Comment letter to the FDIC recommending that regulation of payday lending abuses be strengthened in its Draft Guidelines for Payday Lending.
  

• January 9, 2003 Proposed Merger Comment Letter: HSBC & Household
  Comment Letter in opposition to HSBC's proposed acquisition of Household International.
  

• July 5, 2002: Proposed Merger Comment Letter: Citigroup & CalFed
  Comment Letter in opposition to Citigroup's proposed acquisition of California Federal Bank (CalFed)
  

• December 6, 2000  Testimony: NYC Prohibition of ATM Surcharges

Testimony submitted at a public hearing held by the New York City Council, in relation to prohibiting surcharge fees on ATM transactions.

• October 24, 2000 Proposed Merger Comment Letter: Citigroup & Associates
  Comment Letter in opposition to Citigroup's proposed acquisition of Associates National Bank.