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Empire Justice Comments to CFPB Concerning Small Business Lenders in Rochester, NY
September 7, 2017
While the public CRA lending data adds to our understanding of the CRA performance by banks in their communities, compared to the publicly available HMDA data, the current formulation of the data has severe limitations. Read More

Empire Justice Comments on Strengthening Consumer Protections in the Affordable Care Act
July 17, 2017
Read our comments to HHS, which were submitted in conjunction with several state and national partners, on how reducing regulatory burdens is a thin disguise for reducing much-needed consumer protections. Read More

Empire Jusitce Comments on Protecting the Mortgage Insurance Fund
June 14, 2017
Empire Justice Center's comments focus on how HUD’s current foreclosure alternatives program for FHA-insured loans avoids unnecessary payment of insurance claims, and thus protects the mortgage insurance fund (Fund) and our communities. Read More

Joint Comments on Sterling Bancorp's Acquisition of Astoria Financial
May 17, 2017
We joined with other advocacy organizations representing Long Island to submit comments on Sterling Bancorp’s Proposed Acquisition of Astoria Financial Corporation. Read More

Empire Justice Center Comments on SNAP Income Conversion Factors
May 15, 2017
Current income conversion standards permit states to select the most efficient methodology to help simplify procedures for state eligibility workers and limit barriers to participation for families in need. A shift in this will increase state agency costs, and county workload in our county administered benefits system. Read More

Empire Justice Comments on Updated SNAP Eligibility
January 30, 2017
Empire Justice Center is grateful for the addition of Perkins educational programs to the allowable SNAP employment and training offerings. Read More

Empire Justice Comments to DFS on Vacant and Abandoned Properties
November 25, 2016
The proposed regulations for vacant and abandoned properties are quite comprehensive and thoughtfully address most of what needs to be included in the final regulations. Read More

Empire Justice Center Comments on People's United Financial Bank Merger
October 7, 2016
We urge the Federal Reserve Bank of New York and the Office of the Comptroller of the Currency (OCC) to only approve this merger after People’s United creates a robust community benefits plan in conjunction with community advocates in the bank’s footprint that addresses the forward-looking goals and priorities of their expanding institution. Read More

Empire Justice Center Comments to CFPB on High Cost Installment Loans
October 7, 2016
If there is an unwillingness to ban high-cost payday lending outright on the federal level, then we call on the CFPB to act with great care to ensure that the rules only have the effect of regulating payday lending where it is legal, and not the unintended effect of opening the door to payday ending in states where it is illegal. Read More

Empire Justice Comments on Child Care for Children Experiencing Homelessness
August 1, 2016
The proposed regulations would make several positive changes to help children who are homeless access subsidized child care, but need to go farther to reduce barriers. Read More

Empire Justice Comments on Proposed Federal Student Loan Regulations
August 1, 2016
After the closing of Everest we were inundated with calls for help from former students who were struggling to navigate the student loan discharge process. We found ourselves immersed in learning all we could about this process, and were shocked to find how challenging it was to navigate for a lay person. Read More

Empire Justice Comments on NYS Child Care Market Rates
July 28, 2016
Empire Justice Center comments requesting the market rate survey be redone in order to reflect changes in the state's minimum wage. Read More

GRCRC Comments on JPMC 2011-2013 CRA Performance in Rochester
June 30, 2016
GRCRC about the Office of the Comptroller of the Currency'd examination of JPMorgan Chase. Read More

Empire Justice Comments on SNAP Employment and Training Program
May 24, 2016
Empire Justice Center comments addressing the lack of measurements for mandated participation and sanctions in SNAP interim rules. Read More

Joint Comments on Rural Mortgage Lending Exceptions
April 26, 2016
Empire Justice Center co-authors comments to the Consumer Financial Protection Bureau on interim rules that would exempt some lenders from many consumer protection rules. It's estimated that, if these rules go into effect without change, 6,000 lenders will be able to make 1.1 million loans under much weaker consumer protections. Read More

Empire Justice Comments on Key Bank - First Niagara Merger
January 30, 2016
Empire Justice comments on the proposed acquisition of First Niagara Financial Group, Inc. by KeyCorp. Read More

Empire Justice Comments on Vocational Factors in the Adult Disability Determination Process
December 14, 2015
Empire Justice Center comments to the Social Security Administration on proposed rulemaking on vocational factors of age, education, and work experience in the adult disability determination process. Read More

Empire Justice Comments on Immediate Needs for Personal Care Services and Consumer Directed Personal Assistance
December 14, 2015
The proposed regulations would amend New York Social Services Law to require expedited Medicaid eligibility determinations for people with an immediate need for personal care services (PCS) or consumer directed personal assistance (CDPA), as well as the provision of such services pending enrollment in managed care. Read More

Empire Justice Comments to the NYS Department of Labor on the use of Payroll Cards
November 25, 2015
As growing numbers of employers seek to steer workers to payroll cards, it is vital that New York State ensure that workers have fair and unobstructed access to their wages. We strongly support the proposed rules, which would prohibit employers in New York State from forcing workers to accept their wages on payroll cards; ban big banks and other payroll card issuers from charging workers high and hidden fees simply to access their own wages; and protect working New Yorkers from other payroll card abuses. Read More

Empire Justice Comments on the Nondiscrimination in Health Programs and Activities Proposed Rules
November 17, 2015
We strongly support the reforms introduced by the Affordable Care Act (ACA), particularly the application of essential nondiscrimination protections to the U.S. health system by ACA Section 1557. We applaud the work of the HHS Office for Civil Rights (OCR) to enforce these protections by actively investigating complaints and giving us the opportunity to provide comments that we hope will further strengthen the proposed rule. Read More

Empire Justice Comments on Consumer Complaint Narratives and Data Normalization
September 10, 2015
Empire Justice Center comments on the addition of consumer complaint narratives to the CFPB public database and how it is operating in practice. Read More

Empire Justice Comments on Immediate Needs for Personal Care Services
September 8, 2015
Empire Justice Center supports the overall goal of the proposed regulations to ensure that individuals are able to access needed personal care services to protect their health and safety while, among other things, awaiting the implementation of a care plan by a managed care organization. However, as drafted, the revised proposed regulations fail to fully implement the Konstantinov Order, fail to implement new statutory requirements related to immediate personal care, introduce unwarranted eligibility criteria, deny beneficiaries requisite due process rights, and fail to take into account the shift in the administration of long term care services from local districts to Managed Long Term Care and Medicaid Managed Care Organizations. Read More

Empire Justice Comments on Medicaid and Children's Health Insurance Program Proposed Rule Changes
July 28, 2015
We support HHS’s move to modernize and clarify the regulations governing Medicaid managed care programs. Nevertheless, in light of the growing number of individuals who receive their Medicaid through managed care and the move, like New York’s, towards mandatory Medicaid managed care for all, we believe the regulations can be further strengthened in a number of ways as set forth below and in the comments of the National Health Law Program (NHeLP). Read More

Empire Justice Comments on Immediate Needs for Personal Care Services Proposed Regulations
April 1, 2015
Empire Justice Center supports the overall goal of the proposed regulations to ensure that individuals are able to access needed personal care services (PCS) to protect their health and safety while awaiting a Medicaid eligibility determination, or the implementation of a care plan by a managed care plan. Read More

Comments on NYSED Proposed Amendments Relating to Student Enrollment
February 26, 2015
Empire Justice Center strongly supports the New York State Education Department’s effort to protect the rights of new immigrant children to attend school, and believes that this amendment will aid that objective. Read More

Empire Justice Comments on Modernization of Child Support Enforcement Programs
January 16, 2015
The proposed regulations, which focus on actual earnings and income, are an important step toward realistic and affordable payments. Read More

Comments from HCFANY and MMNY on the Draft New York State Basic Health Program Blueprint
January 12, 2015
The Blueprint lays out a promising start to the full and successful implementation of a strong BHP in New York. Our comments highlight potential consumer concerns and areas where the Blueprint could be further clarified or strengthened. Read More

HCFANY Comments on Accountable Care Organizations Proposed Regulations
December 1, 2014
Health Care for All New York (HCFANY) comments on NYS Department of Health's proposed regulations for Accountable Care Organizations. Read More

Empire Justice Comments on Accountable Care Organizations Proposed Regulations
December 1, 2014
Our comments, submitted to the NYS Department of Health emphasizing the need to substantially improve upon, and add to, the patient protection provisions of the proposed regulations for Accountable Care Organizations. Read More

Comments on Proposed Regulation Amendments for Non-compliance with SNAP Work Requirements and Conciliation Processes
October 27, 2014
The proposed regulations will help bring New York State into compliance with federal SNAP requirements and the settlement agreement reached in Richard C. v. Proud (12-CV-5942, S.D.N.Y.), a federal class action lawsuit co-counseled by Empire Justice Center, National Center for Law and Economic Justice, Legal Aid Society and Cooley LLP. Read More

Empire Justice Comments on Proposed Rules for Immediate Needs for Personal Care Services
September 4, 2014
Empire Justice Center supports the overall goal of the proposed regulations to ensure that individuals are able to access needed personal care services (PCS) to protect their health and safety while awaiting a Medicaid eligibility determination, or the implementation of a care plan by a managed care plan. Read More

Empire Justice Comments to OTDA on the 2014 -15 HEAP State Plan
August 19, 2014
Our comments to the Office for Temporary and Disability Assistance on the proposed New York State plan for the 2014 - 2015 Home Energy Assistance Program. Read More

Empire Justice Comments on the Request for Information on SNAP High Performance Bonuses
July 21, 2014
Here in New York, there are ongoing, rampant due process violations in the fraud investigations/disqualification process. Many counties are extremely aggressive in pursuing fraud, yet it appears that the fraud and/or SNAP staff do not seem to understand SNAP eligibility rules. Read More

Empire Justice Comments on Proposed Reforms Relating to Consumer Credit Collection Cases
May 30, 2014
Our comments in support of the Unified Court System proposed rules governing consumer credit collection cases and suggesting minor improvements to make them more effective. Read More

Empire Justice Comments to OTDA on Proposed Regulations regarding the State Supplement Program
May 23, 2014
Comments on the proposed regulations regarding the State Supplement Program (SSP), part of the monthly benefit paid to most Supplemental Security Income (SSI) recipients, which will add a new Part 398 to 18 NYCRR and which also includes an amendment to 18 NYCRR 358-5.12. Read More

Empire Justice Comments to OTDA on Needs Assessment for 2014-2015 state Home Energy Assistance Program (HEAP) plan
April 8, 2014
Our comments to OTDA on the HEAP 2014-15 Needs Assessment. Read More

Empire Justice Comments on Proposed Abolition of Local Advisory Councils
January 29, 2014
This proposed abolition would conflict with existing law and cut off local social services districts from the communities they serve. Read More

Advocates praised CFPB for user-friendly Home Mortgage Disclosure Act data page...
October 2, 2013
...And made suggestions for improvements. Empire Justice and other consumer advocates from across the country also urged the Consumer Financial Protection Bureau to quickly update the rules pertaining to HMDA. Read More

Empire Justice Center's Reopening Comments to SSA
September 30, 2013
Empire Justice Center's comments relating to proposed changes to the existing reopening regulations. Read More

Recommendations for next steps in mental health screening
September 18, 2013
This document sets forth recommendations a group of advocates presented to OTDA concerning the use of a mental health screen tool that OTDA has recently tested and validated. Read More

Empire Justice Supports "Affirmatively Furthering Fair Housing"
September 18, 2013
Empire Justice strongly supports HUD's efforts to increase accountability under the "Affirmatively Furthering Fair Housing" mandate of the Fair Housing Act (78 Fed. Reg 43710). Read More

Comments on Proposed Child Care and Development Block Grant Regulations: 78 Fed. Reg. 29442
August 7, 2013
Comments of the Empire Justice Center, the Child Care Council of Suffolk and the Child Care Council of Nassau on Proposed Child Care and Development Block Grant Regulations: 78 Fed. Reg. 29442 Read More

Empire Justice and other NYRL members applaud OCC and FDIC for their strong guidance on deposit advance products
May 30, 2013
More than 40 members of New Yorkers for Responsible Lending signed onto a joint comment letter applauding federal regulators for issuing strong guidance to curb deposit advance products and payday lending. Read More

Comments from the Coalition to Protect Dual Eligibles on the Expansion of New York's FIDA Demonstration
May 21, 2013
Comments on New York's proposed addendum to the demonstration for dually eligible beneficiaries. Read More

Empire Justice Comments to Regulators: Make Needed Comprehensive Changes to CRA Rules
May 16, 2013
Empire Justice's response to proposed changes to the Interagency Question and Answer (Q&A) document. Read More

New York’s 2012 Managed Long Term Care Report: An Incomplete Picture
April 8, 2013
This paper scrutinizes the NYSDOH report on the Managed Long Term Care program for elderly and disabled Medicaid recipients and calls for more data and analysis of the program going forward. The paper was authored by three members of the steering committee of the Coalition to Protect New York Dual Eligibles. Read More

"Unfit" for NPR - Let's Get the Facts Straight on Disability
March 29, 2013
Members of the Consortium for Citizens with Disabilities and the SSI Coalition for Children and Families, joined by the Coalition on Human Needs, the Children's Leadership Council, and other organizations, are concerned that a series recently aired on National Public Radio ("Unfit for Work: The Startling Rise of Disability in America and accompanying The American Life episode "Trends With Benefits," both reported by Chana Joffe-Walt) paints a misleading and inaccurate picture of the Social Security programs that serve as a vital lifeline for millions of Americans with severe disabilities. Read More

ACA & Medicaid Issues in the Senate Budget Proposal
March 18, 2013
State Budget: Empire Justice and Schuyler Center enumerate concerns with Senate health budget proposal. Read More

Empire Justice Comments to CMS on Medicaid, Children’s Health Insurance Programs, and Exchanges
February 20, 2013
In states like New York that envision integration of Medicaid and Exchange eligibility appeals, it will be important to ensure that the format and procedural rights afforded Exchange appellants do not compromise the due process rights afforded Medicaid recipients who are currently using the state’s fair hearing process. Read More

Concerns Over CFPB's Changes to Remittance Protections
January 31, 2013
National Consumer Law Center and Empire Justice Center, along with other consumer advocacy organizations and law professors, sent joint comments to the Consumer Financial Protection Bureau, expressing concerns over reduced protections for consumers sending remittances. Read More

Empire Justice Comments on Patient Protection & the Affordable Care Act
December 21, 2012
Empire Justice filed comments with the Center for Medicare and Medicaid Services on the federal definition of Essential Health Benefits to be provided by qualified health plans in New York State’s Health Benefit Exchange. Read More

Empire Justice and Organizations Want Consumers Protected When Shopping for a Mortgage
December 12, 2012
Empire Justice Center was one of several organizations that sent a letter to the Consumer Financial Protection Bureau last month urging the CFPB to strengthen its proposed regulations around mortgage pricing and real estate closings so that consumers are better informed. Read More

Empire Justice Center and Other NY Groups Say Wells Fargo Should "Fail" Its CRA Exam
December 12, 2012
In their comment letter to the Office of the Comptroller of the Currency, Empire Justice Center and other New York organizations cite Wells Fargo's foreclosure practices and discriminatory mortgage lending patterns and urge the OCC to give Wells Fargo a "Substantial Noncompliance" on its Community Reinvestment Act (CRA) Exam. Read More

NYRL Members Oppose FHFA Proposal to Raise New York's Guarantee Fee
November 28, 2012
Empire Justice Center and Greater Rochester Community Reinvestment Coalition, along with other NYRL members, oppose Acting Director DeMarco's proposal to raise the Federal Housing Finance Agency's guarantee fee for New York and other judicial foreclosure states. Read More

Empire Justice Comments: Performance Standards and Quality Measures for the FIDA Program
October 24, 2012
Empire Justice Center is participating on several work groups providing input to the New York State Department of Health on the design of a demonstration proposal to provide integrated services to elderly or disabled Medicaid recipients who are also eligible for Medicare. We recently submitted a detailed memo on performance standards and quality measures for the demonstration, with sign on from the HCFANY (Health Care for All New Yorkers) task force on dual eligibles. Read More

GRCRC and other NCRC members urge federal regulators to strengthen CRA exams
September 27, 2012
The Greater Rochester Community Reinvestment Coalition, convened by Empire Justice Center, and dozens of other members of the National Community Reinvestment Coalition, signed onto a letter asking the four federal agencies that examine banks to assure they are meeting their Community Reinvestment Act obligations to improve and strengthen these exams. Read More

Empire Justice Comments to the Consumer Financial Protection Bureau on Reverse Mortgages
August 31, 2012
Our experience with reverse mortgages provides a unique yet critical viewpoint in understanding how valuable reverse mortgages can be when used responsibly as a tool to prevent seniors from losing their homes to foreclosures in Upstate New York. Read More

Comments to CFPB on Inclusion of a Public Database in Complaint Process
July 27, 2012
Consumer and other groups applaud the Consumer Financial Protection Bureau for including a public database in the CFPB complaint process, with recommendations for strengthening it. Read More

Empire Justice comments on proposed regulations to end food stamp finger imaging in New York State
July 4, 2012
Empire Justice Center strongly supports the proposal to eliminate all finger imaging requirements from the Food Stamp Program in New York State, and to rely on more efficient and effective methods to detect and prevent and detect duplicate participation. Read More

Empire Justice Center & Other NYRL Members Want Consumer Bureau to Broadly Define Who They Regulate in Certain Markets
May 24, 2012
Thirty-two members of NYRL urge the CFPB to define larger participants as broadly and as flexibly as possible, to ensure that the Bureau has maximum ability to directly supervise a wide array of institutions. Read More

Empire Justice Center Comments on CFPB's Proposal to Survey Consumers
May 23, 2012
Rather than create a general survey, Empire Justice recommends that the Bureau identify one or two key issues of focus by utilizing research and data already available on consumer attitudes, understanding and behaviors about consumer finance issues. Read More

Empire Justice Submits Comments on Revised New York State Duals Proposal
May 18, 2012
On May 17, 2012, the Empire Justice Center submitted comments to the New York State Department of Health on the state’s revised demonstration proposal to integrate care for dually eligible individuals—people with both Medicaid and Medicare. Read More

NYRL Members Urge NY Courts to Go Further to Protect Homeowners in Foreclosure
May 15, 2012
In their comments on the Office of Court Administration's (OCA) amendment addressing problems with the current foreclosure process, members of New Yorkers for Responsible Lending ask the OCA to take additional steps to give homeowners a fair chance in the foreclosure process. Read More

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 29, 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 Comments on proposed OTDA regulations
January 29, 2009
Comments on proposed OTDA regulations concerning PA recipient access to educational activities 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 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 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 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 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