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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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TranscriptLinePage
              There has to be a suitability 1201
standard in our view.  There will always be an 2201
imbalance in knowledge between the typical consumer 3201
and a professional like a broker.  It's always 4201
going to be the case.  And we don't expect when one 5201
has a medical problem that you have to read the New 6201
England Journal of Medicine and get educated to 7201
that level to be able to hold your own when you go 8201
talk to a doctor.  We expect that there are rules 9201
and regulations that apply to a doctor so the 10201
doctor is going to do right by the consumer. 11201
              We have to have that in mortgage 12201
lending particularly.  And the reason we favor 13201
suitability standards is because the way the 14201
industry has changed so fast in recent years. 15201
              I mean, we recently were looking at 16201
the annual reports of large subprime lenders in New 17201
Century, which is now the second largest subprime 18201
lender in the country, now has 43 percent of all 19201
their loans are stated income loans.  Four years 20201
ago the last time these kinds of hearings were 21201
held, it was less than 10 percent.  We have seen 22201
subprime lender after subprime lender moving to 23201
stated income loans. 24201
              So it's a very fluid, fast 1202
environment where regulators have to have some 2202
ability to rein in that kind of practice.  You 3202
can't expect that consumers on their own are going 4202
to be able to hold their own against professionals. 5202
    GOVERNOR OLSON:  Bruce, keep going on the 6202
subject of the counseling you do for people facing 7202
foreclosure.  Because that was certainly 8202
illuminating to me to understand the reticence of 9202
people to come forward when they need help and the 10202
role that you and others can play.  Then we'll come 11202
back to the partnership that you have with 12202
financial institutions also. 13202
    MR. GOTTSCHALL:  I think one of the main areas 14202
is the whole getting people in contact with 15202
somebody.  So that is why I talk about the 16202
third-party advisor and the ability through 17202
relationships with the City of Chicago, 18202
relationships with churches, block clubs, it's a 19202
marketing kind of thing that we do to get people 20202
calling either to the 311 number, which is the 21202
City's service number and connecting them to the 22202
counseling, or coming directly to us.  And I think 23202
that third-party advisor in a non-threatening 24202
situation does, as we have seen, bring people in 1203
that would not contact the lender directly. 2203
              Then the situation is how do you 3203
provide the kind of understanding of their 4203
particular situation, what kind of resources NHS 5203
might have available in terms assistance in the 6203
counseling, the ongoing budget counseling, as well 7203
as other resources that the small loans, the 8203
catch-up kind of resources that the lender would 9203
not have. 10203
              And then also working with the loss 11203
mitigation people at the servicers so that they are 12203
proactively working on what resources, what kind of 13203
loss mitigation tools they have.  There has been a 14203
shift over the last few years in terms of that 15203
being a much more proactive effort on the loss 16203
mitigation side in order to find solutions early 17203
on. 18203
              We found earlier that there are so 19203
many changes out here, that if you're not 60 days 20203
past due, we can't really talk to you about any 21203
solution.  So the process then of the lender 22203
collecting, which is the hard-nose-kind of thing, 23203
then at 60 days and 90 days, well, now we can talk 24203
to you about what loss mitigation there might be. 1204
So tools that both the lenders and we are trying to 2204
figure out where it's most appropriate to do those 3204
loss mitigations resources and working through 4204
problems rather than just the, "Hey, you need to 5204
pay and this is what we need now." 6204
              So that is part of the process, then, 7204
where the lender can see the value of using a 8204
third-party resource referring somebody, if that's 9204
a broker, but also then the third-party resources 10204
to be able to contact people and get them into the 11204
loss mitigation system and going through the 12204
process.  So it is a combination. 13204
              Truly, there are a lot of people that 14204
we can't save.  I mean, there are just many, many 15204
situations, and part of that is just the lender 16204
underwriting process up front. 17204
              We haven't talked a lot about the 18204
fraud problem, but fraud is an increasing problem 19204
through that whole area of mortgage lending, and 20204
then the problem of now rescue fraud, where people 21204
are in difficulty, in default, and they're being 22204
approached with fraud around how to save their 23204
home, and it just enhances their loss.  So there is 24204
that kind of activity. 1205
              So all of these I think call for kind 2205
of both the public education, but then really also 3205
the continuing enforcement and strong reinforcement 4205
of what is on the books.  As well as figuring out 5205
how do you now, if it's not interest rate, what is 6205
the loan characteristics that you look at more 7205
closely and require disclosures or third-party 8205
advisors to assist?  Or something that creates the 9205
capacity of that borrower to have some additional 10205
reinforcement support to be able to counter what 11205
might be the push marketing, or if not, clearly 12205
incorrect advice that the mortgage broker may be 13205
providing to that credit borrower. 14205
    GOVERNOR OLSON:  Heidi, keep going on that 15205
theme, because you are the partner on that.  I'm 16205
interested in your experience, but could you 17205
elaborate on the 50 cents and the dollar loss that 18205
you -- because I think that there is some real 19205
savings available to financial institutions when 20205
they get involved in that process early.  And 21205
clearly, at least from what I hear, that there are 22205
some incentives all around to avoid the foreclosure 23205
experience. 24205
    MS. COPPOLA:  Well, I think the dollar amount 1206
varies, but the point is that there are a lot of 2206
different costs that get factored into it. 3206
Maintaining that -- well, the person in the home is 4206
not paying their bills, they are also not taking 5206
care of their home.  So there is a tremendous 6206
deterioration factor.  So if we do end up owning 7206
the home and we have to sell the home, it's not 8206
worth nearly what the home was worth when they took 9206
out the mortgage. 10206
              In addition, we're paying the costs 11206
once we get this home.  We have to pay the costs 12206
until the home is sold.  So we have the cost of 13206
maintaining this home.  All of this gets factored 14206
in, in addition to the fact that there are fixed 15206
costs like the foreclosure process and the delay 16206
that that, you know, legal costs and just all of 17206
these costs add up.  And I think that all of this 18206
gets factored into this.  And if we sell the home 19206
at a fraction of what the market value is, it 20206
doesn't reimburse us for these costs. 21206
              So that in addition to -- I have to 22206
say this is more and more becoming relevant, in 23206
addition to the reputational risk involved in 24206
foreclosing on homes, particularly where you have 1207
hot spots where there are multiple foreclosures 2207
from your institution.  It's just not only a 3207
financial consideration, but all around what is 4207
good for us financially is also good for the 5207
community and good for us from a reputational 6207
standpoint. 7207
    GOVERNOR OLSON:  Heidi, you had a point that I 8207
think the financial institutions are realizing, at 9207
least among the more credible financial 10207
institutions, is the importance of reputation 11207
risk.  And the reputation risk, I remember 15 years 12207
ago as a counselor to financial institutions, was 13207
very fuzzy, not very well understood or enforced -- 14207
enforced is the wrong word -- managed the risks 15207
exposures. 16207
              About three years ago a person came 17207
to me and said -- and identified the bank she had 18207
formally worked with, and said that bank would 19207
still be around today if it were not for the 20207
reputation risk exposures.  So I think that that is 21207
an important responsibility that management now 22207
focuses on and clearly supports a lot of things 23207
that ought to be happening in this field. 24207
              Loretta, come on back to your four 1208
points, and especially I'm interested in how you go 2208
about partnering.  Because as you pointed out and 3208
as we've seen, the community groups have access the 4208
financial institutions don't. 5208
    MS. ABRAMS:  Right.  Well, there isn't one 6208
way.  We have a number of programs.  One of our 7208
programs we will talk about is our financial 8208
education grant program.  There is a million 9208
dollars in grant funding every year that we provide 10208
to organizations to help support the financial 11208
education programs they're running in the 12208
community, and there are very few strings.  It's an 13208
open sort of grant.  RFP competitive bid process. 14208
              And what the community groups like 15208
about that, we look for well-established community 16208
groups who have existing programs, who have 17208
sustainability, who have strong management.  And we 18208
just look to support them and not to tell them to 19208
change the program or do anything differently. 20208
Just to help them to keep what they are already 21208
doing, which they decided is good for their 22208
community.  So that is one of the programs we 23208
have. 24208
              Another is the adult financial 1209
literacy workshop program, where we work with a 2209
national organization out of Washington DC, and 3209
they find grass roots, community-based 4209
organizations who don't necessarily have a program 5209
capacity or the capability or a curriculum, and we 6209
work with them to submit and to produce workshops 7209
using our curriculum.  And we then fund those 8209
workshops on a per-workshop basis with those 9209
smaller community groups.  And over time the 10209
process of working with us in this program helps 11209
them to develop capacity.  They apply for other 12209
grant funding, they get reputation, more 13209
credibility and sustainability within their 14209
communities.  So that is two ways that we are doing 15209
it. 16209
    MS. BRAUNSTEIN:  I'd like to ask some follow-up 17209
questions.  One is we hear a lot about teachable 18209
moments in financial education.  In particular I 19209
know -- and today we are focusing mainly on 20209
homeownership education. 21209
              But in financial education in 22209
general, there are a lot of programs out there that 23209
teach people and then they administer afterwards 24209
some type of test, and they usually score 1210
themselves on how well they did based on how people 2210
answer these tests.  But in fact that may not mean 3210
much, because really what we are looking for is 4210
behavior change.  And if six months later something 5210
happens and people don't remember what they learned 6210
six months earlier, what good was the financial 7210
education? 8210
              I was just wondering in terms of what 9210
you do, I guess particular the practitioners, 10210
Michael, David, what can you tell us about what 11210
you've learned about teachable moments, especially 12210
in light of, David, what you talked about when 13210
people get to the table and they are being 14210
bombarded by, you know, whether it be the brokers 15210
or the salespeople, how good is that education? 16210
How is that holding them in stead?  What have you 17210
learned about that? 18210
    MR. ROSE:  I think our approach may be a little 19210
bit different.  Because a lot of the groups we work 20210
with have bank partners that they will help those 21210
banks market their products, help them find 22210
customers.  And it's all part of the home buying 23210
education and process. 24210
              So in a sense, the lines get kind of 1211
fuzzy between who the broker is.  In a situation 2211
like that it may be that you can call it a 3211
community group type of broker in some situations, 4211
although they aren't a broker in any formal sense. 5211
They are simply putting the homeowner together with 6211
a loan officer at a bank. 7211
              So I don't have that kind of 8211
experience in terms of doing an education program 9211
that really withstands those kinds of pressures 10211
when you go to a broker who will say anything he or 11211
she can think of to originate the loan. 12211
              In 1999, just very quickly to follow 13211
up, when we started working on predatory lending in 14211
Chicago, you know, the conference.  One of the 15211
individuals we invited to speak at the conference 16211
identified himself as a recovering loan shark. 17211
What he was is a used cars salesman, from Minnesota 18211
I believe, who had been recruited by a lender to be 19211
a broker.  And he explained how he had been shipped 20211
off to California for a 30-day training program. 21211
How he was taught this script inside and out. 22211
              And he began his presentation by 23211
asking everybody in the room how many people would 24211
like an extra $500 a month.  And you can imagine 1212
there were city officials, church people and 2212
community groups and bankers, some housing 3212
counselors.  Everybody raised their hands.  And he 4212
said, "Would you agree that you want an extra $500 5212
a month, there isn't anything you can say that I 6212
don't have an answer for?" 7212
              And that kind of arrogance, really, 8212
but that kind of persistence in closing a deal is 9212
what you may be up against in some cases.  I don't 10212
think you can prepare any homeowner to stand up to 11212
somebody who has that kind of training. 12212
    MS. BRAUNSTEIN:  Mike. 13212
    MR. SHEA:  We have been looking at that 14212
question quite a bit the last few years and where 15212
we are zeroing in on are cash-out refi's.  And 16212
typically people get trapped in the subprime cash- 17212
out refi because and emergency comes up, and 18212
typically it's divorce, medical, the car breaks 19212
down, or debt consolidation. 20212
              For the emergencies, we have to 21212
deliver our message and our services almost in a 22212
just-in-time fashion.  When that emergency hits, 23212
people are desperate to get cash.  And that's when 24212
they are most susceptible to the messages of the 1213
predators. 2213
              We have tried a number of efforts to 3213
copy what the predators do.  We bought all sorts of 4213
lists.  You would be surprised what kinds of lists 5213
you can buy.  You can buy lists of recently 6213
divorced people, so we have done mailings to those 7213
folks.  We have use automated dialers to those 8213
folks to try to reach them and bring them in. 9213
Mixed results. 10213
              For one thing, it's very expensive. 11213
You have to keep doing this time after time, month 12213
after month.  And that's what the subprime lenders 13213
do.  We once had a subprime lender tell us they 14213
spend $1500 in marketing, if you take their total 15213
marketing and outreach and apportion to loans 16213
closed, it's about $1,500 a piece.  We can't 17213
compete with that. 18213
    MS. BRAUNSTEIN:  That's why they charge such 19213
high fees. 20213
    MR. SHEA:  I'm not sure that we can compete 21213
with it.  That's why as much as we do more consumer 22213
education, I think, to more people than anybody the 23213
country and it's invaluable, but we have to have 24213
better regulation to stop this. 1214
    MR. CHANIN:  Let me follow up on that, and 2214
Loretta mentioned one size doesn't fit all.  Are 3214
there different strategies -- I'm interested in 4214
your successes, but also your failures -- 5214
strategies you have employed for different groups? 6214
And if so, what is the demarcation among groups for 7214
different products? 8214
              You mentioned cash-out refinancing 9214
verse first time home buyers, different markets and 10214
so forth.  Have you gotten to the stage of learning 11214
that certain strategies or educational approaches 12214
work for some groups of consumers or certain 13214
individuals versus others and certain products and 14214
the like?  And for anyone here actually. 15214
    MR. GOTTSCHALL:  Well, if I can add just a 16214
little bit here.  One of the ideas of the 24/7 17214
counseling by phone was that if someone is thinking 18214
of a loan and in the middle of the night they see 19214
something, they have the brochure, that they can 20214
actually call and talk to somebody right then 21214
rather than folks getting the call back and the 22214
moment is gone.  So 24/7 counseling on the 23214
programming side is a benefit that we find useful 24214
for getting people into the system so then you can 1215
follow up. 2215
              So we found that the City is actually 3215
credible with a lot of people and that 311 number 4215
is a number that most people feel okay calling.  We 5215
found that some of our marketing through churches, 6215
we did a preservation Sunday and had churches doing 7215
their brochures and doing the 311 calling and do 8215
those kinds of things in those places. 9215
              I think the other piece in the 10215
refinance is a critical area, and you describe 72 11215
percent of the people that we are seeing are people 12215
that are in the loan that they are not in trouble 13215
with as a refinance.  I think typically in a 14215
refinance situation people probably don't have a 15215
lawyer, probably don't have a third party helping 16215
them in that situation.  Where with the first 17215
mortgage, they may more likely have it. 18215
              So maybe there is some way there at 19215
that closing moment to really have some requirement 20215
or some system where people are getting that advice 21215
and getting someone with them judging what can be 22215
done.  Because clearly that's a very teachable 23215
moment.  If at that time rather than at some 24215
clients you say, well, if you get an 8 percent 1216
loan, it will cost you this much, and you get a 11 2216
percent loan over 20 years you're going to save 3216
this much.  If they are at the closing table if you 4216
live here, it's going to cost you $40,000 more in 5216
payments.  So there is a way at that point. 6216
              And I think on refinances, and the 7216
cash-out is the place where people, they have a 8216
problem.  And they have someone got to them around 9216
that problem and they did something, and then 10216
later, as we see in the numbers, they regret having 11216
done that.  But they didn't have anybody to work 12216
with right then. 13216
              So we're looking at whether this 24/7 14216
phone thing is how if one is thinking of refinance, 15216
call here and describe your situation.  So I think 16216
there are those kinds of perhaps opportunities. 17216
              But then how do you market it?  How 18216
do you get it out enough?  As you said, $1500 per 19216
closed loan is a lot of money for marketing, and 20216
competing with that is very, very difficult. 21216
    MR. SHEA:   A couple of things we found don't 22216
work.  Direct mail, and actually a guy by the name 23216
of David Hill used to be a marketing director of 24216
Fannie Mae until recently, did some research on 1217
this.  And he found with statistics, what we found 2217
that in our experience direct mail typically is 3217
highly ineffective.  It's almost as effective with 4217
Latino families, more so than Mexican-American 5217
families, but recent immigrants from Central 6217
America in particular direct mail is a total 7217
waste. 8217
              Radio works in conjunction with 9217
events for African-Americans, particularly 10217
church-based events.  We found that that is a very 11217
highly effective way to get folks to come to the 12217
events, particularly if you're using radio ads to 13217
spur that.  Again, it's expensive and you can do 14217
that in the little run, but the radio ads in 15217
Chicago are very extensive, so it's very difficult 16217
to sustain that over time. 17217
    MS. WILLIAMS:  So as you talked about 18217
education, and, Bruce, I heard you mention that you 19217
have consumers that don't even talk to the lender 20217
when they have the problem and some that even if 21217
they talk to the lender, nothing will be done. 22217
              So what do you think fosters that 23217
belief, that the lenders are not approachable or 24217
they won't get the assistance that is needed to 1218
help them when they have a problem? 2218
    MR. GOTTSCHALL:  Well, I think, one, if you 3218
look at the situation that someone is in default, 4218
maybe they are stressed, what was their 5218
relationship with the broker?  The broker is the 6218
lender is the servicer.  So that relationship, 7218
although it's unclear, sometimes the troubled 8218
borrower is not going to a broker.  But there is a 9218
relationship there, and if they see the broker that 10218
maybe gave them a loan that they now regret. 11218
              I think another piece is the 12218
collection process is sometimes hard.  You want to 13218
make sure people are clear that you want to be paid 14218
for what you owe me.  So that that creates, then, a 15218
beginning relationship that if then 60 or 90 days 16218
later, they call you and say we really want to kind 17218
of help you, how do you get over that?  How do you 18218
get through that?  So it is a difficult kind of 19218
relationship that a lender servicer, how do you 20218
manage that needing to do both? 21218
    MS. BRAUNSTEIN:  Excuse me, Bruce.  I know that 22218
when we talked about these kinds of issues four or 23218
five years ago.  And since then what we hear over 24218
and over again is that the number one problem with 1219
getting people in trouble to contact anybody for 2219
help is that they are embarrassed.  Initially, that 3219
they are just ashamed that they are in this 4219
problem, and by the time they get around to 5219
contacting it's so late down the road. 6219
    MR. GOTTSCHALL:  After the surveys that they 7219
did with people who helped us, that was not as high 8219
as not realizing that there was some hope.  So if 9219
there is the embarrassment and people not wanting 10219
to -- and some people believe, well, I can solve it 11219
myself.  But we found actually it was more you have 12219
a feeling about if I talk to somebody, that there 13219
is nothing they can do for me.  So the lack of hope 14219
there was a bigger one than embarrassment. 15219
Although embarrassment was in there. 16219
              So I think that was slightly 17219
different.  You have to deal with both of them in 18219
thinking about how to approach it. 19219
    MS. COPPOLA:  That confirmed the Freddie-Mac 20219
survey in 2005.  There is a survey about why 21219
borrowers don't reach out to their lenders.  And I 22219
think the larger percentage is clearly that at this 23219
stage at that time this point in time. 24219
              But can I address this range of 1220
issues as well?  I think that while there is no 2220
silver bullet here, at City we are looking at this 3220
and making sure there is a consistent message that 4220
we get out in multiple ways.  So we are relying on 5220
the Ad Council, we're relying on our own financial 6220
education curriculum and we have about 10 or 12 7220
partners that we provide our curriculum to.  We 8220
amend the curriculum every year and a half to two 9220
years after a survey to find out what is relevant, 10220
what is being received well, what people don't 11220
understand, what needs to be done.  We just did a 12220
major revision on predatory lending and how to 13220
avoid predatory lending. 14220
              I think the message has to be find 15220
your own provider.  If somebody is knocking on your 16220
door, you should definitely shop around and you 17220
should always ask for them if you feel you're not 18220
in the best position to make a decision.  And I 19220
think those messages have to be communicated every 20220
which way we can think of. 21220
              And ultimately, it's like a shifting 22220
paradigm.  We have to make sure that this gets out 23220
there and public awareness is raised so that people 24220
understand and that it clicks.  When they see the 1221
800 number in their community, they say, "I do 2221
remember seeing something.  I do have to reach out 3221
and call for help, this is probably the right 4221
place." 5221
    MS. ABRAMS:  We are working on some of the same 6221
issues together, and educating the consumers just 7221
to be aware that there are options and there are 8221
certain places so that they know when that moment 9221
does happen for them, and it happens with all of 10221
us, we are going to hit that bump in the road.  And 11221
when the bump in the road happens, to know where to 12221
go. 13221
              It's very difficult to regulate human 14221
behavior.  People who are going to cheat are going 15221
to find a way to cheat.  And people who are 16221
behaving sort of in a certain manner that maybe 17221
isn't always in their own best interests, sometimes 18221
we don't know what we don't know. 19221
              And that's why education is so 20221
important.  Getting people in seminars and in 21221
workshops to say did you know this.  And we see 22221
that a lot.  We see it every day when just telling 23221
people about FICO scores and how it works and how 24221
certain behaviors are impacting FICO scores.  You 1222
hear people all the time about "I didn't pay that 2222
$12 phone bill, it's not mine."  So just telling 3222
people, "Pay it.  Still fight about it later, but 4222
pay it for right now because it's effecting your 5222
FICO scores."  Just those kinds of awareness and 6222
those kinds of "uh-huh" moments happen all the 7222
time.  And it might not be a problem for them 8222
today, but they find somebody else in the family 9222
who has a problem later on. 10222
              So as we spread the word, increase 11222
awareness of about all of these financial issues 12222
and everything that goes along sort of this 13222
financial landscape is going to be helpful. 14222
Because people will recall when they need it, they 15222
will know where to go and get it.  And it will be 16222
all of these places. 17222
    MR. SHEA:  Can I add one more thing on this? 18222
One of Nathan Hill's most significant points they 19222
found was the role of the trusted advisor and how 20222
the trusted advisor varies from population group to 21222
population group, particularly along racial lines. 22222
              So what he found and what we find in 23222
our experience in the African-American communities, 24222
the trusted advisor that the individuals go to 1223
first is the real estate agent.  When they need -- 2223
definitely when they're buying a house, but also 3223
when they're refinancing.  In the white community, 4223
it's parents and other family members, but 5223
particularly parents.  Latinos, his research I 6223
believe showed that it was church, and church I 7223
believe was the first place they would go. 8223
              So we've tried to gear our efforts, 9223
we try to take that into effect so that we spend a 10223
lot of time working with real estate agents.  So 11223
that when they get that call from a borrower that 12223
needs cash and is in danger, they are going to 13223
refer them to us or to another counseling agency. 14223
    MR. ROSE:  I have one more thing.  Partnerships 15223
with City and SPS and ACORN, the local community 16223
organizations that I think do the best work at 17223
outreach, have been the ones that incorporate the 18223
message into all of their meetings.  So they might 19223
be having an organizing meeting on crime and drugs 20223
or some other issue, but this will be the message 21223
that there is a place that they can call who will 22223
come in and talk about preparing their credit, 23223
repairing their loans is made a part of those 24223
meetings.  So it's another avenue of outreach. 1224
    GOVERNOR OLSON:  We have had a couple comments 2224
about the teachable moment, but also linking 3224
education or financial literacy with the mortgage 4224
process itself. 5224
              And, Mike, you started to talk about 6224
your programs with two institutions.  And I heard 7224
you say something like -- and I'm not sure if I got 8224
it right -- that these are loans that in a 9224
different environment would have been subprime but 10224
are not now. 11224
              Does that mean that the terms have 12224
not subprime, the performance is not subprime 13224
because of the additional application of 14224
counseling?  And I would be interesting in hearing 15224
the same thing from the two lenders. 16224
    MR. SHEA:  All of our partners -- the products 17224
made available through our partnerships all have 18224
several underwriting flexibility, but two in 19224
particular that make them unique and that makes 20224
them what I would call subprime if it was outside 21224
of our program. 22224
              One is undocumented income.  So with 23224
Bank of America and Citibank partnerships, they 24224
both accept undocumented income up to a certain 1225
percentage of the total income that an individual 2225
can have.  The reason they accepted it is because 3225
they know that our housing counseling will in fact 4225
go verify that income as best they can.  So if 5225
somebody coming to us, we find out what their 6225
undocumented income, we call the source or else we 7225
make the clients go back and bring us some evidence 8225
that that really is there.  Furthermore, we make an 9225
evaluation that it's going to continue before we 10225
then refer that individual to the lender. 11225
              The second is underwriting based on 12225
corrected information contained in the credit 13225
report, but not on the credit score.  We pull about 14225
30,000 credit reports a year, and we estimate that 15225
30 to 35 percent of them will contain significant 16225
errors in the information and in the credit score 17225
in particular.  And it's our experience African- 18225
American borrowers in particular are likely to have 19225
many more errors in their credit report. 20225
    GOVERNOR OLSON:  Is the source of the loans 21225
that have been paid or is it confusion of one 22225
borrower's experiences with an unrelated borrower? 23225
    MR. SHEA:  Both.  It's a whole gambit of 24225

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2006 Hearings