Comments on Integrating Care for Dual Eligibles
May 1, 2012
Empire Justice Center co-authored comments on the NYS proposal to CMS for a demonstration program integrating care for dual eligibles (Medicaid recipients that are also eligible for Medicare). Read More
Empire Justice Comments on Revised Regulations regarding Fair Hearing Defaults
March 30, 2012
OTDA Revised Regulations regarding Fair Hearing Defaults: Empire Justice Center comments support expansion of time frames for reopening but urge removal of time limit entirely; and express concern about restrictions imposed on Appellants represented by lay advocates Read More
Incentives for Community Based Services within Managed Long Term Care: Consumer Comments
March 23, 2012
The Managed Long Term Care program as currently proposed should increase incentives and oversight to ensure access to community-based services. Read More
Comments to the US Department of Health on Charity Care
March 14, 2012
Empire Justice and the Commission on the Public's Health System submit joint comments on the federal regulations governing the distribution of Medicaid Disproportionate Share Hospital Payments. Read More
AFR Urges CFPB Scrutiny of Private Student Lenders
January 20, 2012
Americans for Financial Reform (AFR), of which Empire Justice Center is a member, submitted comments to the Consumer Financial Protection Bureau documenting concerns about the private student loan industry. Read More
Comments on the Dept. of Treasury’s Activities to Expand Access to Mainstream Financial Institutions
November 18, 2011
Treasury’s endeavors are critical in the current environment. The current economic crisis has strained the financial stability of many families and pushed them out of the middle class. Read More
Empire Justice Center and the Legal Aid Society's Comments on Proposed Federal Regulation on Establishment of Health Benefit Exchanges
November 3, 2011
The Legal Aid Society and Empire Justice Center write jointly to provide comments on the Proposed Rule entitled “Patient Protection and Affordable Care Act; Establishment of Exchanges and Qualified Health Plans.” Read More
Empire Justice & Legal Aid Society Comments on Proposed Federal Regulation on Medicaid Eligibility
November 1, 2011
Comments on the proposed rule entitled “Medicaid Program; Eligibility Changes Under the Affordable Care Act of 2010.” Read More
GRCRC Comments on First Niagara's Application to Purchase HSBC's Upstate New York Branches
October 20, 2011
HSBC is moving out of retail banking in upstate New York and First Niagara is seeking approval from federal regulators to purchase most of its branches. GRCRC met with First Niagara and submitted comments urging First Niagara to be a good steward in the Rochester community. Read More
Empire Justice Center's Comments on New York's TANF State Plan 2012 - 14
October 19, 2011
Our comments to OTDA urging them to take leadership on a number of issues which will improve the lives of low income New Yorkers. Read More
Empire Justice Center Comments on Changes to SNAP “Fleeing Felon” Rules
October 18, 2011
Empire Justice Center filed written comments in response to USDA’s proposed changes to the SNAP “fleeing felon” regulations. Read More
GRCRC Comments on Canandaigua National Bank's CRA Performance
October 7, 2011
The Greater Rochester Community Reinvestment Coalition sent these comments to federal regulators about Canandaigua National Bank's community reinvestment performance in the Rochester, NY area. Read More
Empire Justice Comments on USDA's Proposed SNAP Regulations Updating the Definition of Trafficking
August 18, 2011
The proposed rules change the definition of trafficking for SNAP (Supplemental Nutrition Assistance Program) purposes and also clarify disqualification procedures for recipients of FDPIR (Food Distribution Program on Indian Reservations). Read More
Empire Justice Center signs on to NYRL Letter Supporting a Strong Ability-to-Repay Standard
August 2, 2011
Fifty New Yorkers for Responsible Lending members urge federal regulators to implement the strongest, most robust regulations possible to protect consumers from abusive loans. Read More
Empire Justice Letter to HUD on Proposed Rules on Credit Risk Retention
August 1, 2011
To address abuses in mortgage lending and to ensure safe, quality mortgages for consumers, the interests of consumers, originators, securitizers and investors must be better aligned than in the past. Requiring risk retention by securitizers is one of the ways Dodd-Frank increases this alignment and incents higher quality lending. Read More
Empire Justice Comments on Proposed Federal Regulation on Methods for Assuring Access to Medicaid Services
July 6, 2011
Empire Justice strongly supports the overall thrust of the proposed regulation, which is to require states contemplating reducing Medicaid reimbursement rates to providers to review the potential impact the rate reductions would have on access to care for Medicaid recipients. Read More
Empire Justice Comments on Proposed SNAP Regulations: Eligibility, Certification and Employment & Training
July 5, 2011
Empire Justice's July 2011 comments on USDA's proposed rules, which were issued to implement 2008 federal reauthorization changes to the certification, eligibility and employment and training provisions of the Supplemental Nutrition Assistance Program (SNAP) Read More
GRCRC Comments on JPMorgan Chase's CRA Performance
June 29, 2011
The Greater Rochester Community Reinvestment Coalition sent these comments to federal regulators about JPMorgan Chase's community reinvestment performance in the Rochester NY area. Read More
Empire Justice Comments on Proposed Child Care Fraud Regulations
June 17, 2011
Comments on regulations that would amend Parts 414, 415, 416, 417 and Sub-parts 418-1 and 418-2 of Title 18 NYCRR, which were published in the May 4th New York State Register. Read More
State Budget Results: Funding for Legal Services - Cuts, Restorations and Hope for the Future
April 12, 2011
The legal services community has suffered significant losses over the past few years as state legislative funding has dropped from approximately $13 million in 2009, to $6 million in 2010 to less than $3.5 million in this year’s budget. Read More
Empire Justice Center’s Comments on Proposals on the Medicaid Redesign Website
February 16, 2011
Senior Health Attorney Trilby de Jung provides analysis of six proposals posted on the Medicaid Redesign website. Read More
Comments on the Revised Medical Criteria for Evaluating Mental Disorders
November 15, 2010
Revised Medical Criteria for Evaluating Mental Disorders, 75 Fed. Reg. 51336 (August 19, 2010); Docket No. SSA-2007-0101 Read More
Comments on New York’s Proposed Regulations for the Consumer Directed Care Program (CDPAP)
November 15, 2010
Empire Justice has signed on to comments prepared by Valerie Bogart at Selfhelp, Inc., on New York’s proposed regulations for CDPAP. The comments urge New York State to broaden the program by including more family members as qualified attendants, taking into account other available services, and eliminating overly restrictive task based assessments and medical stability requirements. The comments also urge New York to clarify crucial due process protections for processing CDPAP applications and reauthorizing services. Read More
GRCRC Wants Stronger CRA Regulations
August 27, 2010
The Greater Rochester Community Reinvestment Coalition, convened by Empire Justice Center, urges federal agencies to strengthen and expand regulations governing the Community Reinvestment Act. Read More
GRCRC Asks Federal Regulators to Strengthen Mortgage Lending Data Regulations
August 13, 2010
To coordinate with hearings being held across the country, the Greater Rochester Community Reinvestment Coalition submitted comments to federal banking regulators asking them to expand the disclosure of mortgage lending data under HMDA. Read More
GRCRC comments on proposed change to CRA
July 22, 2010
The Greater Rochester Community Reinvestment Coalition (convened by the Empire Justice Center) commented to federal regulators in support of their proposed change to the Community Reinvestment Act regulations to allow CRA credit for support of Neighborhood Stabilization Program (NSP) activities. Read More
GRCRC comments on RBS Citizens Bank's CRA performance
June 1, 2010
In June, the Greater Rochester Community Reinvestment Coalition, convened by the Empire Justice Center, submitted comments (and a follow-up letter) to the OCC on RBS Citizens' mortgage lending and community development performance for its CRA exam. Read More
Empire Justice and Legal Aid's Comments on use of Medicaid Health Information Technology Funds
May 28, 2010
Comments to the Department of Health on the planning, design and implementation of Medicaid Health Information Technology (HIT) incentive funds under the federal American Recovery and Reinvestment Act. Read More
Empire Justice Center Comments on the Early Childhood Advisory Committee’s Strategic Report and Plan
May 25, 2010
Empire Justice Center comments on the Early Childhood Advisory Committee’s Strategic Report and Plan focus on the need to work on addressing the inequities in the child care subsidy system. Read More
Empire Justice Center’s Statement on Chief Judge Jonathan Lippman’s Plan of Action for Access to Justice in Civil Courts
May 5, 2010
Empire Justice Center applauds New York’s Chief Judge Jonathan Lippman for his leadership. Read More
Empire Justice Joins the NYS Consumer Coalition on Part D to Highlight the Continuing Need for the EPIC and Medicaid Wraps
May 3, 2010
Part D plans continue to deny medically necessary prescription drugs. Read More
Comments on the Electronic Health Record Incentive Program
March 15, 2010
Comments from Consumer and Patient Organizations on the Proposed rule Detailing Incentive Payments for the Meaningful Use of Certified EHR Technology. Read More
GRCRC Comments on HSBC's CRA Performance
November 23, 2009
The Greater Rochester Community Reinvestment Coalition, and its convener, Empire Justice Center, submitted a letter to federal regulators on HSBC's performance in meeting the credit needs of the Rochester community. Read More
Empire Justice Center's Initial Reaction to Deficit Reduction Plan for 2009-10 State Budget
October 31, 2009
Reductions in services for those who have been most impacted by the recession will ultimately result in pushing more people over the edge into desperation. Read More
Empire Justice Comments on the Emergency Reduction of the Enhanced Market Rate for Legally Exempt Child Care Providers
July 21, 2009
This letter is regarding the emergency rulemaking amendment to 18 NYCRR 415.9 that reduces the reimbursement rate for legally-exempt in home and family child care providers. Read More
Empire Justice Comments on Bill to Change Medical Support Guidelines
April 24, 2009
This bill is a response to the federal medical support regulations promulgated by the United States Department of Health and Human Services on July 21, 2009 (73 FR 42416 (7/21/08). Read More
Empire Justice Comments on the Federal Reserve's Proposed Amendments to Regulation E
March 27, 2009
Financial institutions should provide consumers who do not affirmatively consent to the institution’s overdraft service for ATM withdrawals and one-time debit card transactions an account with the same terms, conditions and features, including interest rates paid and fees assessed, as it provides consumers who affirmatively consent to overdraft services. Read More
Empire Justice Comment on Proposed Amendments to 18 NYCRR §§385.6 and 385.7
January 29, 2009
We strongly support these proposed modifications to the extent that they enhance public assistance recipient access to education and training activities. We also discuss our concerns with certain aspects of the regulations which we fear may hinder progress toward this crucial objective. Read More
Empire Justice Comments on proposed OTDA regulations
January 29, 2009
Comments on proposed OTDA regulations concerning PA recipient access to educational activities Read More
Empire Justice Comments on New York State's TANF State Plan 2009-2011
November 14, 2008
Testimony focuses on the public assistance gross income eligibility test, the resource test as applied to automobiles, the implementation of the Family Violence Options and the education and training rules. Read More
GRCRC Comments on Oversight of Financial Sector Acquisitions
October 28, 2008
Our country is now being over-whelmed by a financial disaster created by a culture of greed in the financial services industry and ignored until too late by the federal financial regulators. GRCRC is extraordinarily concerned that these same regulatory agencies are making decisions that are reshaping our financial sector without public comment or full oversight. Read More
Empire Justice Comments on Republic Bancorp's Application for a Charter Conversion
September 12, 2008
Empire Justice Center requests that the Office of Thrift Supervision hold a formal, public meeting on Republic Bancorp’s (“Republic”) application for a charter conversion from a bank holding company to a savings and loan holding company. Read More
Empire Justice Comments on the Exempt Income Protection Act
September 11, 2008
The purpose of the bill is to close a loophole in New York’s debt collection law, which currently allows banks to restrain accounts containing income that is exempt from collection, including social security, disability benefits, public assistance, pensions, college tuition trusts, and veterans benefits. Read More
GRCRC Comments on KeyBank's 2008 CRA Exam
September 9, 2008
This comment letter will focus mainly on mortgage and small business lending with a small section on community development activities. Read More
Empire Justice Comments on Proposed Amendments to Regulation AA
August 4, 2008
Comment in support of the Federal Reserve Board of Governor’s proposed amendments to Regulation AA, which curbs unfair and deceptive credit card and overdraft practices. While Empire Justice supports many aspects of this rule, we feel there needs to be additional and stronger protections against these unfair and deceptive acts. Read More
Empire Justice Comments on Public Assistance and Child Care Laws
July 18, 2008
Empire Justice submits concerns and recommendations to the Office of Children and Family Services regarding current regulations. Read More
GRCRC Comments on M & T Bank's 2008 CRA Exam
July 3, 2008
These comments focus M&T Bank’s HMDA lending, small business and SBA lending, and its response to community investment and service needs. Read More
Empire Justice Comments on Proposed Changes to the Real Estate Procedures Act
June 12, 2008
This letter commends HUD for its efforts to simplify and improve the process of obtaining mortgages and to reduce settlement costs to consumers through proposed changes to the Real Estate Procedures Act (RESPA), and offers suggestions to improve the proposed changes. Read More
GRCRC Comments on Canandaigua National Bank & Trust CRA Exam
June 5, 2008
Greater Rochester Community Reinvestment Coalition comments regarding Canandaigua National Bank & Trust’s CRA Exam conducted by the Office of the Comptroller of the Currency. Read More
GRCRC Comments on Citizen Bank's CRA Exam
May 29, 2008
Citizens Bank is important to the Rochester metropolitan area. It is the fourth largest depository institution serving the area. As of June 20, 2007, Citizens had $1.65 billion in deposits at its 38 offices in the Rochester MSA and 13 percent of the market. Read More
GRCRC Comments on Bank of America's Application to Acquire Countrywide Financial Corp.
April 28, 2008
If the Federal Reserve attaches certain specific conditions to Bank of America’s acquisition of Countrywide Financial, as outlined in our testimony and detailed in this letter, the Greater Rochester Community Reinvestment Coalition would not oppose the acquisition. Read More
GRCRC Comments on Proposed Amendments to the Truth in Lending Act
April 8, 2008
The proposed Regulation Z changes would give consumers important added protections. It is our position, however, that the proposals should be strengthened to make sure that consumers are adequately protected from the abuses that have led to the current crisis in the subprime mortgage lending industry. Read More
Empire Justice Comments on the Implementation of the Truth in Lending Act
April 8, 2008
It is our position that the proposals should be strengthened to make sure that consumers are adequately protected from the abuses that have led to the current crisis in the subprime mortgage lending industry and to ensure compliance. Read More
Empire Justice Guidance on Marketing of Refund Anticipation Loans
April 7, 2008
Empire Justice urges the IRS to amend regulations and adopt a rule prohibiting paid tax preparers from sharing tax return information to make refund anticipation loans. Read More
National Consumer Law Center Comments on Proposed Interagency Guidance on Garnishment of Exempt Federal Benefit Funds
November 27, 2007
Comments of the National Consumer Law Center on behalf of its low-income clients. Read More
Empire Justice Comments on 2007-2008 New York State HEAP Plan
August 3, 2007
This letter constitutes the comments of the Empire Justice Center on the 2007-2008 New York State Home Energy Assistance (HEAP) state plan. Read More
Empire Justice Comments on Health and Safety Standards for Informal Child Care Providers
February 2, 2006
Comments on concerns as to how the timing of the enrollment process will intersect with the rights of public assistance recipients to guaranteed child care under Social Services Law § 410-w(3). Read More
Empire Justice Comments on Proposed Changes to Health & Safety Standards for Child Care Providers
February 17, 2005
Support of proposed changes to18 NYCRR 415.4 and 415.9, regarding health and safety standards for legally exempt informal child care providers Read More
Empire Justice Comments on Health & Safety Standards for Informal Child Care Providers
February 17, 2005
Children who receive subsidized child care in New York State should be assured that only quality child care is purchased with public dollars. Read More
Empire Justice Comments on Proposed Market Rate Regulations for Child Care Providers
March 24, 2004
Expresses concerns regarding the proposed market rate regulations for child care providers: 18 NYCRR 415.6 and 415.7 Read More
Empire Justice Comments on Proposed EITC Pre-Certification Process
July 14, 2003
Empire Justice comments on the IRS' proposed Earned Income Tax Credit pre-certification process. Read More
Empire Justice Comments on repealing 18 NYCRR 352.31(b)
July 3, 2002
This regulatory change will assist non-legally responsible relatives with limited means, who wish to care for relatives under the age of 18 when their parents are unable to do so. Read More
