More Irrefutable Proof Of The Democratic Complicity In The Mortgage Meltdown…In Their Own Words.
Posted on | September 29, 2008
In their own words, we have the evidence that the Democrats, fiddled while Freddie Mac and Fannie Mae were on fire. The fire at these organizations were doused with the gasoline of the Community Reinvestment Act - passed under the control of Bill Clinton and a Democratically controlled House and Senate.
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When will we wake up and lay the responsibility where it belongs. Nancy Pelosi has no shame in doing so.
Everywhere you look, Democrats lay the blame for our current situation. Lets see, Democrats controlled the Congress for all by 8 of the last 45 years and they controlled the Presidency for 8 years before Bush arrived. Do they think this occurred in the span of a just 7 years. They really must think that you are stupid. You had better rub that off your forehead.
I am clear that they are using this situation and their failure to deliver the votes of Democrats to pass this bill to try to advance a greater Political agenda. The problem is that this could wipe out everything that you and I own. If you are still unsure about the evils of the Community Reinvestment Act, read this post from the LRC Blog.
September 29, 2008
A Banker on the Evils of the Community Reinvestment Act
Posted by Thomas DiLorenzo at September 29, 2008 09:28 AM
Another banker has written me to explain why the CRA Scam is even worse than we imagined. My words are in brackets. L.S. writes:
I am an expert in the Community Reinvestment Act and the Home Mortgage Disclosure Act and related Fair Lending laws. I have been consulting in this specialized compliance area for 14 years and have worked with hundreds of banks and some community organizations as well. There is a good deal of truth to the allegation that the CRA did contribute to the current financial crisis . . . . There is much good to be said about the CRA, but as the old saying goes, “The road to hell can be paved with good intentions.” While the CRA has been around for more than 30 years, it was the changes made in 1995 under the Clinton administration that set the ball in motion for the pressures that created market premiums for LMI ["low- to moderate-income, or sub-prime] mortgages. In 1995 for the first time, the CRA specified quantitative performance standards specifically related to LMI mortgages. It took 7 or 8 years for the cumulative effect to become too big to ignore.
About 50% of the sub-prime mortgages originated can be ascribed to banks and their affiliates (which itself is still very substantial). Under CRA banks receive credit [by the Fed and other regulators, for making bad loans] not only for loans they originated, but loans they purchase as well. This resulted in a premium value for mortgages to low- and moderate-income [i.e., sub-prime] borrowers . . . . The premium was reflected in the secondary market for these loans [i.e., Fannie and Freddie's operations] I personally saw transactions between banks in which these mortgages were sold and purchased at huge premiums that were driven by the “CRA value” of the credits [i.e., brownie points with Fed regulators] for the loan purchaser. I vividly remember one portfolio transaction in which the purchasing bank paid a premium of $15000 per mortgage to effect a transaction just before year end. Some unscrupulous firms went around marketing “CRA mortgages” . . . touting the mortgages to borrowers as highly attractive because of the CRA-angle. Lehman Bros. was one of the most active players in the secondary market purchasing these loans. The reality is that the regulatory pressure exerted by CRA was a factor that should not be ignored. Ironically, at the same time, many banks did offer discounted rates to LMI borrowers that did benefit them. Not all sub-prime loans took advantage of borrower ignorance.
In other words, they set up a giant Roulette game, with penalties for those did not play….with our money. If you do not believe me, see this “Interpretive Letter” that I pulled from the an official Federal Government website that is available here.
Correspondence Date: October 2, 1996
Dear [ ]: This letter responds to your correspondence dated July 4, 1996, to Ms. Julia Brown of the Comptroller of the Currency’s (OCC’s) Western District Office concerning how participation in your CASA Home Loan Program (CASA program) will be considered under the revised Community Reinvestment Act (CRA) regulations. As you know, the CRA regulations establish the framework and criteria by which the regulatory agencies assess an institution’s record of helping to meet the credit needs of its community.
You have asked whether participation in the CASA program could be treated as either a loan or as an investment for purposes of the CRA regulations and whether and under what circumstances participation in CAS A program would receive favorable consideration under the CRA regulations.
As explained in your initial letter, a subsequent letter sent by facsimile transmission on September 26, and several telephone conversations, [ ] ( ) has established the CASA program to provide affordable housing to qualified purchasers in the City of [ ], [ state ] ( ). Under the CASA Program a borrower makes a 5% down payment on a home and obtains a conventional mortgage in the amount an additional 75% of the cost of the home. The remaining cost of the home is financed through: (1) a second mortgage from [ ]; and, (2) if necessary, a third mortgage from the [ ]. The second mortgage will be financed through a funding request from [ ] to a participating institution (either the institution that extended the conventional mortgage or another institution). Upon acceptance of the funding request, the institution makes either a loan to, or an investment in, [ ] in the amount of the second mortgage. [ ] then will use the proceeds of the loan to make the second mortgage to the borrower. The borrower does not make payments on the second mortgage nor does the second mortgage have a set interest rate. The principal on the second mortgage is paid only if and when the home is sold, and interest is contingent upon there being an appreciation in the value of the home. If the value of the home has appreciated when it is sold, the amount of the appreciation, the contingent interest, is distributed as follows: 40% to the borrower and 60% to be split between [ ] and the second mortgage lender.
You state in your letter that you believe a CASA program second mortgage “has characteristics which should allow it to be classified as either an investment or a loan.” You further state that you believe a policy allowing institutions to categorize CASA program second mortgages “based upon the accounting method selected[,] or other internal criteria[,] is appropriate . . .” We agree that generally accepted accounting principles will control whether a financial institution’s participation in CASA program second mortgages is a “loan” or an “investment.” As a general matter, therefore, the CRA treatment of the participation will differ depending upon whether the participation is accounted for as a loan or an investment.1
We addressed issues similar to those you raised in an inter agency letter, signed by Matthew Roberts and published as OCC Interpretive Letter No. 708, dated February 16, 1996 (enclosed).2 In that letter the agencies concluded that participation in a housing fund that would provide funding for affordable housing loans for low- and moderate-income persons would be considered as either “qualified investments” or “community development loans” under the CRA regulations depending upon how the institutions chose to structure the transaction. The analysis in this interpretive letter would be applicable to the activity you described in your letters and telephone correspondence.
I trust this letter is responsible to your inquiry. If you have any further questions, feel free to contact me or Yvonne McIntire, an attorney on my staff, at (202)874-5750.
Sincerely,
/s/
Michael Bylsma
Acting Director
Community and Consumer Law Division
Office of the Comptroller of the Currency
And in case you are still unsure, I quote the following from the section of the same website that outlines the “Scope and Purpose” of the Community Reinvestment Act.
The CRA requires that each insured depository institution’s record in helping meet the credit needs of its entire community be evaluated periodically. That record is taken into account in considering an institution’s application for deposit facilities, including mergers and acquisitions. (See CRA Ratings) CRA examinations (see Exam Schedules) are conducted by the federal agencies that are responsible for supervising depository institutions: the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the Office of Thrift Supervision (OTS).
In other words, if you, as a banker want any consideration of your plans to grow your bank or merge or take other steps to become more successful, you had better play along, or the regulators will block those plans if you have not accumulated enough “brownie points” under the CRA.
So back to the core issue, this problem did not create itself, it did not emerge overnight. The biggest problem now is that those that obstructed any effort to reign in the crisis early on……are now the very ones in control of putting together a solution.
We also need to look very carefully at the issue of corruption. Senator Chris Dodd (D. CT), Chairman of The Senate Banking Committee. He received sweetheart mortgages from Country Wide Lending. As recently as July 11th, he was denying that there was any problems at Freddie Mac or Fannie Mae.
At this time, Country Wide was desparate to keep Fannie Mae open and available to buy their crap, loans. Maybe DoDd was giving them a sweetheart deal back.
So….be very afraid….and be very angry. The reality is that only cooler heads can head off a complete catastrophe. We need statesmen to emerge to lead a calm and reasoned and bipartisan dialogue to resolve this. The problem we face here is that the Democrats are in control and they have devolved into an existence dependent on dependency and victim hood. We must assert our voices to make sure they do not use this as an opportunity to expand their constituency of “victims”.
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