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Building Sustainable Homeownership:
Responsible Lending and Informed Consumer Choice

Federal Reserve Bank of Chicago
230 South LaSalle Street, Chicago, Illinois  60604
June 7, 2006



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role.  Parties that have a financial interest in 1176
originating loans dominate the home finance 2176
process.  It is clear, however, that no one wins in 3176
a foreclosure except those investors who pick up 4176
foreclosed properties cheaply.  Borrowers and 5176
neighborhoods lose greatly. 6176
              But lenders and investors in those 7176
roles that hold the note also lose.  They lose 8176
financially and in reputation.  The industry's 9176
willingness to write off a certain number of valid 10176
homeowners to originate more loans faster is 11176
shortsighted and makes keeping people in their 12176
homes secondary. 13176
              Today too often the focus is not on 14176
finding an appropriate property, an affordable 15176
property, but on constructing a deal that reduces 16176
payments to what seems like affordable levels.  The 17176
borrower gets a surprise when the payments adjust 18176
or the tax bills rise. 19176
              In Chicago after two consecutive 20176
years, the reduction in foreclosures started. A 21176
preliminary analysis of the 2005 data shows some 22176
disturbing results.  New foreclosures, for 23176
instance, have rose 1 percent in 2005.  The number 24176
of foreclosures on newly-originated, low-cost 1177
conventional loans has increased dramatically, 2177
almost doubling from the 2004 number.  While new, 3177
high-cost loans have nearly disappeared from the 4177
data. 5177
              The number of ARM and balloon 6177
characteristics on these loans have nearly tripled 7177
since the 2004 levels.  These results raise 8177
concerns about the changing face of predatory 9177
lending. 10177
              A definition of predatory or abusive 11177
lending which is geared only to interest rates or 12177
fees charged will miss what is going on in the 13177
market now.  In order to get a small monthly 14177
payment, brokers may be encouraging borrowers to 15177
accept ARMs, interest-only payment option loans, 16177
without the borrower fully understanding the 17177
implications of terms. 18177
              In conclusion, I would like to 19177
reiterate these points.  Consumer education is only 20177
as successful as it is comprehensive and ongoing. 21177
Community groups bring commitment and expertise to 22177
keep families in their homes.  And industry 23177
accountability and regulation must keep pace and 24177
prevent the self-interest of the parties to 1178
override and prevent sound borrower constituents. 2178
    GOVERNOR OLSON:  David, thank you.  It sounds 3178
like you were pretty close to wrapping up. 4178
    MR. ROSE:  I had one sentence, so I was close. 5178
    GOVERNOR OLSON:  Whatever you've got left, 6178
we'll come back to you. 7178
              Mike Shea. 8178
    MR. SHEA:  Good afternoon.  On behalf of 9178
200,000 family members of our sister organization, 10178
ACORN, the 150 housing counselors and staff of 11178
ACORN Housing Corporation, as well as our board of 12178
directors, we would like to thank you for holding 13178
these hearings. 14178
              These hearings were last held -- I've 15178
actually done much more keeping of the trains 16178
running on time in policy work.  And so because of 17178
that, I think I'm fond of certain individuals such 18178
as Ben Wallace, the Center for the Detroit 19178
Pistons.  So I would like to start with some 20178
reflections about Ben.  Upon losing the NBA Eastern 21178
Conference finals to Miami Heat, Ben was asked, 22178
"Why, did you lose?  The Pistons were a 23178
prohibitive favorite, they should have won."  So 24178
Ben said, "It was not a matter of skill, it was not 1179
a matter of smarts, it was not coaching.  It boiled 2179
down to a matter of will.  We win when we impose 3179
our will on our opponent and we lost this series 4179
because the Heat imposed their will on us." 5179
              I think that is where we are at after 6179
six, seven years of battling predatory lending and 7179
disparate pricing that is racially based.  We know 8179
what works.  It's five, six elements in the 9179
package. 10179
              You need good laws.  You need laws 11179
like we have in New Mexico, New Jersey, 12179
Massachusetts.  You need very aggressive, tough 13179
enforcement, such as the enforcement that happens 14179
now in the state of Illinois with Lisa Madigan with 15179
her assistants such as Tom James as well as other 16179
states.  You need suitable products.  You need 17179
products that are offered to low and moderate 18179
income people and racial minorities that fit their 19179
needs.  And you need lenders who are committed to 20179
offering only those products and not unsuitable 21179
products. 22179
              You also need effective consumer 23179
education, combined with one-on-one housing 24179
counseling.  And finally, you need good 1180
post-purchase loan mitigation, such as the 2180
Household Foreclosure Avoidance Program. 3180
              I'd like to zero in on what we do, 4180
which is housing counseling.  Our partnership with 5180
Citibank and Bank of America, which we feel 6180
delivers very suitable products to low and moderate 7180
income and minority people and perform well. 8180
              Many of these products would in fact 9180
be considered subprime products were they out in 10180
the open market.  Starting with Bank of America, 11180
which is our oldest and most robust partnership, 12180
through the end of 2005 over 50,000 of our clients 13180
have taken out mortgages with Bank of America since 14180
we began in 1991 with the old NCNB.  Most of the 15180
mortgages have been for first time purchasers, but 16180
in recent years increasing numbers of refi's. 17180
              BMA retains most of our loans in 18180
their portfolios.  As of March 31, just 1.8 percent 19180
of BMA's ACORN portfolio was delinquent 60 days or 20180
more, and less than three-tenths of 1 percent were 21180
in foreclosure. 22180
              What do these loans look like?  They 23180
are CRA bridge loans qualifying for CRA credit. 24180
Virtually all of those loans come out of urban 1181
areas, with the majority of the borrowers being 2181
racial minorities.  We estimate 37 percent of the 3181
borrowers were African-American, 33 percent Latino, 4181
25 percent white, the remainder Asian and others. 5181
              Our newest multi-state partnership is 6181
Citigroup, and that's only about a year and a half 7181
old.  We've generated around a thousand loans, 8181
several in the pipeline.  A sizable portion of 9181
those loans are I-PIN loans under the innovative 10181
pilot program, and here is the performance. 11181
              It's too early to judge the 12181
performance, but here is what we have so far.  Just 13181
about 1.25 percent of the loans are 30 days or more 14181
delinquent and just under two-tenths of 1 percent 15181
of the loans are 90 days delinquent.  The I-TIN 16181
portion of the portfolio is performing even better, 17181
with just three-tenths of 1 percent being 18181
delinquent. 19181
              Now -- what does the yellow mean? 20181
    TIMEKEEPER:  You're under two minutes. 21181
    GOVERNOR OLSON:  We will get back to this 22181
subject.  I think that you're on a very interesting 23181
subject, how you take us.  I won't take any more of 24181
your time, but the differentiation between you can 1182
take a subprime borrower, bank them into a prime 2182
performer.  We would be very interested in how you 3182
do that. 4182
    MR. SHEA:  Then I won't brag on our 5182
partnerships until later. 6182
              So when it comes to curbing predatory 7182
lending on a national scale, we believe the real 8182
question is does the Federal Reserve and other 9182
federal banking agents and lenders have the will to 10182
do so.  We hope that coming out of this hearings we 11182
see a new resolve on behalf of the Fed.  If that's 12182
the case, then we'd ask you to consider three 13182
proposals. 14182
              First, we think the Fed needs to help 15182
create a massive housing counseling industry 16182
throughout the United States.  There is only $50 17182
million in housing counseling funds available from 18182
HUD.  At most, another 15 million is made available 19182
through state and local agencies.  That is not 20182
nearly enough. 21182
              Banking agencies should assess a fee 22182
to all lenders to help create a pool of funds to 23182
build a truly national nonprofit housing counseling 24182
industry. 1183
    GOVERNOR OLSON:  Give us the two topics so you 2183
have all three of them in front of us. 3183
    MR. SHEA:  The second is to amend HOEPA or bank 4183
regulations to include a suitability standard. 5183
    GOVERNOR OLSON:  Okay. 6183
    MR. SHEA:  And a third is to stop worrying 7183
about preemption and right of private action. 8183
    GOVERNOR OLSON:  Bruce. 9183
    MR. GOTTSCHALL:  My name is Bruce Gottschall, 10183
I'm executive director of Neighborhood Housing 11183
Services of Chicago. 12183
              What I would want to talk about is 13183
our partnership, actually including a couple of our 14183
later panelists and about 15 others other lenders 15183
and servicers, to prevent foreclosure to troubled 16183
borrowers. 17183
              The homeownership preservation issue 18183
here in Chicago has been operating for about three 19183
years, and we have assisted more than a thousand 20183
troubled borrowers to stem foreclosure and correct 21183
their situations and not be foreclosed on.  So over 22183
4,000 borrowers we have assisted in terms of 23183
individual counseling to work on preventing that. 24183
              We have a 24/7 hot line that people 1184
can call in conjunction with the City of Chicago 2184
where we counsel people in that regard, and our 3184
partner is nationwide through the neighborhood 4184
network in states like Ohio and other places.  So 5184
we have strong experience in that area. 6184
              I think I would just like to touch on 7184
a few things.  We have done some research and 8184
surveys with people that we have assisted, and 9184
there is some interesting comments around the 10184
marketplace and where we are at today. 11184
              We know that 50 percent of the 12184
borrowers that are foreclosed on never talk with 13184
their lender.  The lender calls them but they never 14184
call back.  It's a big problem.  We found out that 15184
more than 45 percent of the borrowers who contact 16184
us but have not contacted the borrower say they 17184
don't talk with the lender because they don't feel 18184
they can be helpful.  They don't understand that 19184
the lender has some ways that they can cure the 20184
faults and assist them.  And even some borrowers 21184
think if they call the lender they will foreclose 22184
faster.  There is a lot of misinformation out there 23184
about what is going on. 24184
              If you look even further, those who 1185
do contact the borrowers, 50 percent feel that the 2185
lender really does not have much that they can do 3185
for them.  So there is a disconnect in terms of 4185
that. 5185
              We find in our situation that more 6185
than 70 percent of the borrowers who are troubled 7185
and are in default and heading for foreclosure are 8185
due to refinanced loans, so it's the refinance 9185
marketplace that is really problematic. 10185
              We have also surveyed and looked at 11185
those borrowers who contact us and work with us and 12185
they find that the third party advisor, someone 13185
like NHS, a counselor, is really valuable because 14185
they can provide additional information.  They can 15185
provide the time to look through some solution. 16185
They have other resources available for solutions, 17185
and they don't have to cut through the various -- 18185
sometimes a lender in collection is hard-nosed and 19185
beats on the borrower.  How then does the borrower 20185
go back and talk to them about loss mitigation?  So 21185
we as counselors don't have that problem to deal 22185
with. 23185
              We also found that a third of the 24185
people that we work with, when they think about 1186
where they are at and why they are in trouble, a 2186
third of them thought they never should have been 3186
approved for a loan now.  They regret that they 4186
didn't shop around for a loan, and many regret they 5186
actually took out the loan.  So the lack of 6186
education in that situation I think really 7186
demonstrates that.  And 20 percent of those 8186
borrowers felt that the terms of that loan was some 9186
of the cause for that delinquency or default. 10186
              Looking at the future and where it's 11186
at, and you probably talked about this, but what 12186
you might call the boom in foreclosures upcoming. 13186
Someone said if 500 billion of subprime ARMs are 14186
out there and had been originated in the last few 15186
years, those will be coming due in the next year or 16186
two.  Subprime borrowers to begin with, then, on 17186
ARMs after that, rising interest rates, it's a 18186
huge, huge problem going forward. 19186
              We find that there is a concentration 20186
of that foreclosure and hot spots in certain 21186
neighborhoods, certain cities.  And that although 22186
broadly speaking there is foreclosure across the 23186
board, certain hot spots in Chicago and other 24186
places clearly are there.  So a concentration of 1187
work in the targeted neighborhoods is important. 2187
              Looking at stemming the foreclosure 3187
problem and things that need to be done.  We are 4187
looking at situations where you really need a 5187
longer term foreclosure solution.  People who have 6187
lost a job or had some health issues, they're not 7187
going to solve that in a month or two or a few 8187
months.  So finding new resources, new ways to 9187
attack the situation where those borrowers who 10187
could in a year or two be able to figure out how to 11187
sustain that homeownership, how do we find that 12187
kind of solution. 13187
              I think the other situation where we 14187
now have these exotic products with no 15187
documentation, ARMs, you know, interest-only, all 16187
those kinds of problem loans that we feel are 17187
problem loans out there, really also create a 18187
disincentive for borrowers to actually take 19187
advantages of counseling.  You get a yes now, why 20187
do you go through counseling?  Even though long 21187
term you're going to save money, you're going to be 22187
able to be in a better situation.  That whole 23187
product mix today in the marketplace is extremely 24187
problematic. 1188
              So that, again, I would reiterate the 2188
need for that counseling industry to be 3188
strengthened, the enforcement of both state and 4188
federal legislation, and then getting at that whole 5188
process of the new lending market place where 6188
securities and other investors who are so far 7188
removed from any negative impact of foreclosures, 8188
how do you get at that investor, that system.  That 9188
creates a lack of accountability for economic 10188
problems. 11188
    GOVERNOR OLSON:  Two things.  We will get back 12188
to you, but in the essence of full disclosure, I'm 13188
on the board of Neighbor Works, and I have a lot of 14188
familiarity with what Bruce is talking about. 15188
              I was very surprised to learn with 16188
the counseling support available to people facing 17188
foreclosure, that the difficult, the most difficult 18188
issue is finding the people who are facing 19188
foreclosure.  So that certainly points to the need 20188
for greater education. 21188
              Ms. Heidi Coppola. 22188
    MS. COPPOLA:  Yes, thank you very much.  Thank 23188
you for having a Citibank representative here 24188
today. 1189
              My role at Citigroup is to work with 2189
nonprofit and consumer groups to accomplish three 3189
things.  To understand the viewpoint and concerns 4189
of nonprofit groups and consumer services, to 5189
communicate their views and concerns with our 6189
consumer businesses so that we have an opportunity 7189
to assess our business practices in light of these 8189
concerns and views.  And to work with consumer 9189
groups and nonprofits on pilot programs that serve 10189
as a basis for gathering more information and 11189
trying new ideas to serve the traditionally 12189
underserved. 13189
              The partnership with Neighbor Works 14189
America, which is what I was asked to speak about 15189
today, is a great example of how this model works. 16189
After about almost a decade of expanding 17189
homeownership for low and moderate income 18189
individuals, it became clear in discussions with 19189
consumer groups and nonprofit partners, such as NHS 20189
of Chicago, that there was a lot of problems. 21189
While homeownership was readily attainable, its 22189
sustainability was by no means guaranteed. 23189
              NHS had the vision to go to data of 24189
those who study the problems in the mortgage market 1190
which were leading to unprecedented foreclosure 2190
rates with those of us originating and servicing 3190
the mortgages so that we could see the impact of 4190
the problem on particular neighborhoods. 5190
              And they did this in an amazingly 6190
objective way.  There was no finger pointing, there 7190
was no focus on matters outside the control of the 8190
servicing and loss mitigation teams.  We sat around 9190
the table and we focused on what the problem was 10190
and how we could solve the problem. 11190
              At the NHS table, you didn't have to 12190
be a researcher to see what the problem was. 13190
Foreclosures are devastating for homeowners and 14190
frequently result in loss for the lender or 15190
servicer.  This was the case, whatever the cause, 16190
for the foreclosures, and we were there to fix the 17190
problem. 18190
              If foreclosures individually are a 19190
problem, you can imagine the problem foreclosure 20190
clusters were having on whole neighborhoods.  Home 21190
appreciation declines generally, resale is 22190
difficult, that impacts homeowners and lenders. 23190
Basic community needs are challenged, small 24190
businesses and related infrastructure suffer. 1191
Local governments lose money by dedicated resources 2191
to problems associated with poorly maintained or 3191
abandoned homes.  And even the process of 4191
administration a foreclosure is costing the 5191
government money. 6191
              At a minimum, we all saw that there 7191
was an alignment of interest among the borrowers, 8191
the lenders, the servicers and the local 9191
governments.  On average, the industry is quoted as 10191
saying that there is a loss of about 50 cents on 11191
the dollar in every foreclosure.  With the servicer 12191
input at the table, NHS of Chicago capitalizes on 13191
this alignment of interest.  And it became very 14191
clear to many of us in the lending industry that 15191
they were on to something. 16191
              As Bruce said, they use the 311 hot 17191
line for the City, there is 24/7 counseling, there 18191
is local advertising.  The Mayor's committed to the 19191
program.  Lenders and servicers commit to pay for 20191
the counseling, and NHS stands as a back up for 21191
referrals for cases that are too difficult to be 22191
handled through the 311 and 24/7 counseling. 23191
              Our experience personally with this 24191
is that in the three years of the program we have 1192
had 56 callers that have gone through counseling. 2192
And out of that 56, we saved 26 homes.  While those 3192
numbers don't seem staggering, except if you look 4192
at it as a percentage.  These are customers who 5192
never would have spoken to us.  Before they called 6192
the NHS hot line, they never reached out to us.  So 7192
56 borrowers in the Chicago market actually reached 8192
out for help that otherwise wouldn't have, and out 9192
of that, over half were able to save their home. 10192
              Going forward, we continue to realize 11192
that focusing on the 36 or so homeowners having 12192
avoided foreclosure without ever having spoken to 13192
their lender or servicer is really what we need to 14192
focus on. 15192
              So we have been working with Neighbor 16192
Works America, Chicago's parent, to build what I 17192
call the national infrastructure.  Essentially it's 18192
this foreclosure avoidance programs looking at the 19192
specific components.  The idea is that it could be 20192
replicated in various hot spots, foreclosure hot 21192
spots around the country, either in whole or in 22192
part. 23192
              So we have broken it down into three 24192
different areas.  Outreach and education.  For this 1193
part we are planning on relying on the Ad Council 2193
of America in the hope that they can bring public 3193
service announcements across the country to 4193
foreclosure hot spots across the country with the 5193
message being essentially that homeownership is 6193
worth preserving and is not as hard as you think. 7193
Reach out for help to a lender, a servicer or a 8193
third party, there will be an 800 number to support 9193
this as well a website.  We hope that the Ad 10193
Council brings instance credibility, and what we 11193
are really hoping for a Smoky-the-Bear-type 12193
character that will be associated with this 13193
forevermore. 14193
    GOVERNOR OLSON:  None of those people are young 15193
enough to know what that means. 16193
    MR. SHEA:  Young enough? 17193
    GOVERNOR OLSON:  Old enough I mean. 18193
    MS. COPPOLA:  24/7 hot line counseling, again 19193
with an 800 number who will connect the caller to a 20193
trained credit counselor who will be prepared to 21193
assist with budgeting recommendations. 22193
    GOVERNOR OLSON:  Heidi, give me the last two 23193
points. 24193
    MS. COPPOLA:  24/7 telephonic counseling and 1194
community-based assistance, which is on the ground 2194
referrals to a nonprofit organization that can 3194
handle the more difficult situation. 4194
    GOVERNOR OLSON:  A critical approach.  We want 5194
to come back and hear more about. 6194
              Loretta Abrams. 7194
    MS. ABRAMS:  Thank you.  It's my pleasure to be 8194
here today.  I'm Loretto Abrams, vice-president of 9194
Consumer Affairs for HSBC North America.  We have 10194
60 million customers in the United States and we 11194
are doing business around five areas of business 12194
from banking to consumer finance.  And we are an 13194
avid member in the communities where we do business 14194
and we work hard to make a positive difference to 15194
our neighbors and our customers. 16194
              I appreciate the opportunity to be 17194
here today to share our views, experiences and 18194
learnings around financial education.  And I will 19194
start out by sharing a couple of statistics with 20194
you. 21194
              While we found that most Americans 22194
aspire to homeownership and they see homeownership 23194
as a sure path to financial stability and 24194
accumulating assets, the pathway is not always very 1195
clear.  In a survey, we commissioned this last 2195
March, one in four consumers told us that affording 3195
a home is among their top ten financial concerns. 4195
Of particular interest to me in this finding was 5195
the fact that 72 percent of the consumers surveyed 6195
stated that they understood how to become a 7195
homeowner, but only 22 percent said that they 8195
understood very well the process of applying for a 9195
mortgage loan. 10195
              Now, at the opposite end of this 11195
spectrum, 26 percent of the people who responded 12195
said they didn't know anything at all about how to 13195
apply for a mortgage loan.  So when we have 14195
statistics like that, is it any wonder that we hear 15195
people all the time who are in a mortgage product 16195
they don't understand or that isn't quite right for 17195
them? 18195
              So we believe that we can address 19195
that disparity through a combination of sound 20195
business practices and financial education.  And 21195
I'm a strong proponent of financial education.  We 22195
know from many conversations that we have with 23195
consumers that it's important that products be 24195
helpful and affordable, and that consumers 1196
understand the terms and features of their loan. 2196
              The good news is today there is more 3196
product choice than ever before.  The trade off is 4196
that consumers don't always have all the 5196
information they need to make the choices they need 6196
for the product choice that is the best for them. 7196
              So we have been educating consumers 8196
for over 75 years in one form or another on credit 9196
and budget matters, and we are continuing this 10196
tradition today.  We have a financial education 11196
platform called "Your Money Counts."  Refund 12196
programs for national and regional organizations 13196
across the country.  We conduct consumer surveys 14196
and, I'm sure some of these results are with you 15196
today, to make sure we understanding what consumers 16196
are feeling and how they feel that their knowledge 17196
level is and how we can impact it.  We also sponsor 18196
programs that focus on credit education, 19196
homeownership, pre- and post-homeownership 20196
counseling and foreclosure intervention. 21196
              Our programs reach kids in elementary 22196
schools, college, university students, working 23196
families, immigrants, elderly consumers, military 24196
families, et cetera. 1197
              And I can speak to you a lot today 2197
about the specifics of those programs and I will 3197
share that in my written statement.  But I wanted 4197
to get to the fact that share a really quick story 5197
about a family in Tucson.  Mom and dad, three young 6197
kids, all young boys below the age of five.  They 7197
were celebrating six months getting their first 8197
home.  She had gone through pre-homeownership 9197
counseling and she was very proud and she announced 10197
to the whole group of people who attended the fact 11197
that she knew her FICO score, she knew what was 12197
going to happen in the mortgage application process 13197
and at the closing table, and she was able to craft 14197
a loan that was right for her, saving money on her 15197
mortgage that she's putting into savings to send 16197
those boys to college.  And she was very proud and 17197
we had families in those rooms who were nodding 18197
around the table.  So they really do get it and 19197
they want it. 20197
              Four things we learned.  One size 21197
does not fit all.  The programs need to be 22197
customized.  Find a partner to work with.  Partners 23197
with community-based organization who understanding 24197
the community and the needs and who have 1198
credibility within the community. 2198
              Move the needle.  Don't just screen 3198
people.  When they live that room, they need to 4198
leave with a call to action.  We need to tell them 5198
what we want them to start doing differently so 6198
they can start doing it tomorrow and keep on doing 7198
it. 8198
              And finally, check back again.  See 9198
how they're doing.  Keep doing surveys like this, 10198
keep asking people what they need and how we can 11198
help so we can keep on customizing programs and 12198
keep on educating people so that they understand 13198
their products and choices. 14198
              And I made it.  Thank you very much. 15198
    GOVERNOR OLSON:  That was very well done. 16198
Thanks to everyone. 17198
              Let's come back, if we can, and I 18198
think, David, something immediately leaps out from 19198
your presentation is a fact that I absolutely agree 20198
with.  That when someone is emotionally involved in 21198
the purchase, something like a home, that it is 22198
very easy for a predator to prey on that emotion 23198
and sell somebody something that shouldn't get to 24198
them.  And that education will take you part of the 1199
way. 2199
              That emotional components is always 3199
going to be there.  So for the element of it that 4199
you don't address through education, how do you 5199
address it? 6199
    MR. ROSE:  Well, that's where it comes down to 7199
who is at the table when the decision is made.  I 8199
mean, it's a broker, it may be a contractor, if 9199
it's a home improvement loan, that is acting as a 10199
broker for the loan.  They are going to use all of 11199
those emotional buttons to get you to do the thing 12199
that is in their best financial interest in a worst 13199
case scenario. 14199
              So it's really a question of holding 15199
these individuals accountable to a standard that 16199
says, "Did you share the range of options with this 17199
homeowner?"  I mean, I had a heating and air 18199
conditioning contractor in my house who wanted to 19199
replace my air conditioner for $5000.  He was going 20199
to charge me 18 percent interest.  Now, I knew that 21199
I had credit cards at lower interest rates than 22199
that, and that I could have charged the services 23199
and not involve putting a lien on my house in order 24199
to do it.  Now, it turns out that another 1200
individual that had come in and looked at my 2200
heating and air conditioning told me it wasn't a 3200
problem.  He fixed it for about 50 bucks. 4200
              Now, those are the kinds of scams 5200
that are out there.  Those are the things that are 6200
very difficult to train somebody to withstand.  The 7200
argument he was giving me was, "It's winter, I can 8200
do this for you cheaply now.  But if you wait when 9200
it's hot and you're going to need this air 10200
conditioning, it's going to be a lot more money." 11200
Those were the kinds of arguments that are used. 12200
              So you're not going to be able to 13200
prepare the general public to withstand every 14200
variation of the scam that a predator is going to 15200
come out with. 16200
    GOVERNOR OLSON:  Mike, coming back to you, you 17200
started talking about the need for housing 18200
counseling, and we just had time to talk about your 19200
other two points.  So why don't you just complete 20200
what you wanted to touch on on those points. 21200
    MR. SHEA:  Sure.  I'd like to make a short 22200
comment, if I may, on the question you asked David 23200
as well. 24200

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2006 Hearings