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Building Sustainable Homeownership:
Responsible Lending and Informed Consumer Choice

Federal Reserve Bank of Philadelphia
10 Independence Mall, Philadelphia, Pennsylvania 19106
June 9, 2006



Agenda | Transcript printable Printable version (249 KB PDF)

Pages 1-25 | 26-50 | 51-75 | 76-100 | 101-125 | 126-150 | 151-175 | 176-200 | 201-221

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that financial literacy is woefully inadequate. 126
Assuming that a written notice will overcome that, 226
no matter how plain language that is, is plainly 326
naive. 426
           Second, is my personal observation 526
based on interactions with borrowers, counselors, 626
sheriffs, and attorneys, that borrowers are not 726
all economically rational actors.  All due respect 826
to the economists in the room.  Borrowers in 926
financial difficulty are, oftentimes, in denial 1026
and they don't exercise all the options that are 1126
available to them.  They disregard or 1226
misunderstand notices sent by their lenders and 1326
servicers until too much time has passed to 1426
recover from their predicament. 1526
           On the other hand, we are invariably 1626
told by borrowers, counselors, and attorneys that 1726
servicers report having absolutely no latitude to 1826
make any modifications or forbearance available to 1926
borrowers, when they request such action in an 2026
effort to become current or remedy some other 2126
aspect of the transaction. 2226
           Again, resorting to the research of 2326
reports of Fitch, that's not true and I'll quote, 2426
"Fitch currently rates numerous residential 127
mortgage-backed securities transactions that allow 227
the underlying collateral to be modified if 327
borrowers are having difficulty making their 427
monthly payments.  A few transactions," and I 527
understand there are a few, "A few transactions 627
call for the full and immediate removal of 727
modified loans from the pool." 827
             Third, in the subprime market 927
especially, mortgages are sold to consumers 1027
through mortgage brokers.  In the mind of the 1127
borrower, there is no distinction between the 1227
broker and the lender.  Our experience suggests 1327
that it is highly unusual for borrowers to shop 1427
for mortgages.  Oftentimes, borrowers aren't out 1527
looking for money, but money's looking for them. 1627
           In Pennsylvania, although it's typical 1727
that the borrower pays for the broker's service, 1827
the broker does not have fiduciary duty to the 1927
borrower.  And that is a fact that's not 2027
understood by the borrower.  In the best case 2127
scenario, the broker is a true professional who 2227
helps the borrower understand and obtain a 2327
mortgage product that best fits their needs; in 2427
the worst case scenario, the broker sells the 128
product that is most advantageous to them. 228
           In a significant civil rights case 328
brought by the Pennsylvania Human Relations 428
Commission, under the Pennsylvania Human Relations 528
Act, against a local mortgage broker, we learned 628
that the African-American broker targeted 728
African-American borrowers and sold them 828
remarkably disadvantageous subprime loans that 928
yielded far greater benefits to him than to his 1028
customers. 1128
           Having testified as an expert in this 1228
case, I can tell that you the hearing examiners 1328
themselves needed help understanding the 1428
complexity of the complainant's HUD-1 settlement 1528
sheets and the borrowers seemed to comprehend even 1628
less.  What was salient to me, in speaking with 1728
the respondent broker's customers, was that's 1828
borrowers were especially susceptible to this 1928
broker's sales pitch because of their desire to 2028
help out a fellow African-American. 2128
           Fourth, although foreclosures have 2228
declined locally from their peak levels in 2328
2002/2003 time frame, there are clear signs in the 2428
90-day delinquency data that there will be an 129
upturn.  These foreclosures result in losses for 229
the borrowers and lenders/investors themselves. 329
Research conducted by TRF and EConsult 429
Corporation, commissioned by the Federal Reserve 529
Bank of Philadelphia, demonstrates that there is a 629
statistically demonstrable adverse effect of 729
mortgage foreclosures on local property markets. 829
In fact, after applying an appropriate set of 929
statistical controls, we found that each 1029
foreclosure within 1/8 of a mile of a sale and one 1129
to two years prior to that sale, reduces the value 1229
of the home by one percent.  In Philadelphia, the 1329
typical home sale has four to five foreclosures 1429
within the specified time and distance, and so it 1529
is reduced by well more than five percent. 1629
           The implication of this is that 1729
everyone in the area has lost some of the wealth 1829
that they might have otherwise accumulated as the 1929
value of real estate appreciates.  What's 2029
interesting to consider about this, is that even 2129
if the lender/investor and borrower agree that 2229
they want to compare the risk of the transaction 2329
it is borne by others. 2429
           GOVERNOR OLSON:  Ira, let me stop you 130
there.  We'll have plenty of opportunity.  I think 230
your experience is relevant, and we'll want to 330
hear more. 430
           Peter, I want to come back to the point 530
that you were making, if you can -- I'm sure you 630
can -- it's the difference, the unexplainable 730
difference, the APR differences that are 830
unexplainable based on risk, and Doug can amplify 930
his comments about the compression that's taking 1030
place, but the extent to which you can quantify or 1130
clarify how that distinction comes about, 1230
particularly in this context we're talking about, 1330
the different channels.  So it would be 1430
interesting to hear any further application you 1530
have on that issue. 1630
           MR. ZORN:  I'll just make a couple 1730
points.  So, if you look at the characteristics 1830
that, presumably, you would like to think as an 1930
economist, would explain differential pricing, 2030
above and beyond those characteristics that you 2130
see in the HMDA data.  As you add credit risk 2230
variables and loan product characteristics, which 2330
will affect prepayment and interest rate risk, 2430
then you do explain much of the difference between 131
-- again, on average we're talking about a 231
regression here -- between the APR that we see in 331
the subprime market and within the prime market, 431
but you're focusing within the subprime market. 531
It doesn't explain everything, and one of the 631
things that we haven't -- we looked at other data, 731
which -- these are -- that's the result of 831
analysis that we've done on 2005 origination.  So 931
it's fairly recent data. 1031
           The other data that we've looked at are 1131
older data in the earlier part of this decade, 1231
where we have additional information, more about 1331
people's financial education, financial knowledge, 1431
and actual propensities to shop, to pick up on 1531
Doug's point, and as you start to add those 1631
additional variables, you start to come close to 1731
eliminating, statistically, the differences you 1831
see in pricing and channel choice between 1931
minorities and non minorities. 2031
           So it gets to the point that Doug was 2131
raising, why do you see these differences? 2231
Certainly, part of it is, in my observation, 2331
having to do with how -- people's financial 2431
knowledge and sophistication; part of it has to do 132
with their shopping behaviors.  That is, I think, 232
generally speaking, subprime borrowers will shop 332
for a yes or a low payment; prime borrowers tend 432
to shop for a low rate or a lower price, which is 532
a different story. 632
           GOVERNOR OLSON:  Should we add a 732
behavioral economist to the group? 832
           MR. ZORN:  I think that is a 932
possibility.  The marketing behaviors as well, I 1032
mean, subprime lenders, there's much more push 1132
marketing on the subprime side.  And then the 1232
other part is, there's, I think, traditions, 1332
knowledge, exposures.  So I think you have people 1432
who -- subprime lenders are in certain 1532
neighborhoods and are the lenders that people are 1632
familiar with, and that creates a momentum and a 1732
tradition to follow that path, even if they're not 1832
certain it's the right path. 1932
           GOVERNOR OLSON:  Doug, a couple of 2032
points that you made, number one, the compression 2132
of the rates between the subprime and prime 2232
product, and I wonder how much of that is based on 2332
the fact that we're in an overall lower rate 2432
environment, but I'm also interested in, if you 133
could amplify if you would, on the explosion in 233
the numbers of applications, and some of the 333
implications of that seems to me that in a time, 433
or unquestionably, we are seeing an increase in 533
the number of products, and to come to a point 633
that Janice touched on a little bit, the 733
difference -- the enhancements that are available 833
because of the additional ways that we have of 933
approving, or at least evaluating, products. 1033
           And then, so, we have the two things 1133
that are happening simultaneously.  We have growth 1233
in the marketplace and additional complexity.  How 1333
do you see that impacting, either the need for 1433
education, or the results that we see in terms of 1533
foreclosures or delinquencies? 1633
           MR. DUNCAN:  Let me talk to the spread 1733
issue first.  The spread issue in the secondary 1833
market, those are pretty available publicly and 1933
pool differences, price differences have been 2033
narrowing.  To buttress that, we have a series of 2133
subprime companies that provide us with 2233
performance data, and over the last five years 2333
we've seen -- to use the way economists look at 2433
this to see if companies in different market 134
segments or infrastructures are being equally 234
compensated, the risk adjusted rate of return to 334
capital among the subprime lenders has declined 434
continually to where it's almost exactly the same 534
as prime borrowers. 634
           GOVERNOR OLSON:  Stick with that, 734
because the subprime and prime borrowers, the 834
rates, if you take the yields, not the yield 934
spread, the yield, and if you adjust for cost, the 1034
return on capital is about the same for the prime 1134
and non-prime markets. 1234
           MR. DUNCAN:  That's correct.  That was 1334
not true five years ago, but it is true today. 1434
           GOVERNOR OLSON:  Talk about the other 1534
side of that, the explosion of the market.  Could 1634
you repeat those statistics again, the number of 1734
applicants. 1834
           MR. DUNCAN:  We were just looking at 1934
the HMDA data for home purchase loans.  In 2000, I 2034
believe there were 8.3 million applications. 2134
These are HMDA data.  In 2004, there were 9.8 2234
million applications. 2334
           GOVERNOR OLSEN:  So you added about a 2434
million and a half applications in that time 135
frame. 235
           MR. DUNCAN:  Yeah.  At the same time, 335
as you point out, there's been a tremendous 435
expansion in the number of loan products.  Our 535
view of how this occurred is a couple of things. 635
One is, obviously, a declining interest rate 735
environment in general.  Although, in 2004 rates 835
were up from 2003; they were down from 2000. 935
           In the midst of that, there has 1035
undergone a tremendous technological change in the 1135
mortgage business.  Underwriting tools are 1235
available and cut out the most expensive piece of 1335
the credit assessment process.  The 1435
electronification of the entire mortgage process 1535
has reduced hurdle costs in the industry.  The 1635
ability to use sophisticated yield estimation 1735
tools by investors has brought in more capital. 1835
All of these things have lowered the hurdle cost 1935
rate, which would make a borrower who was credit 2035
constrained, a viable candidate for a loan. 2135
           As the cost structure has fallen within 2235
the industry, it's not as though there have never 2335
been credit constrained borrowers before; it's 2435
just that the cost hurdle to make them profitable 136
to lend to, has fallen, opening the door to those 236
households.  At the same time, you have those all 336
implicated products, which absolutely make more 436
critical that there be a high level of disclosure 536
of how loans behave, that is, how payments change. 636
If it is a loan that has payment change, and what 736
the different strengths and weaknesses of the 836
different loan products are for an individual 936
household. 1036
           Back on what Peter was saying, the 1136
strength of shopping among credit constrained 1236
borrowers is not the same as it is among the prime 1336
borrowers, so that heightens the need for 1436
financial literacy. 1536
           MR. COLLINS:  Could you tell us how 1636
you're defining subprime? 1736
           MR. DUNCAN:  That's always the 1836
question.  And there's not a generally accepted 1936
definition.  What we always do is, we require the 2036
respondents to sell to us, that is, the companies 2136
who provide us data, do you view yourself as a 2236
subprime lender or a prime lender, and then 2336
distribute the prime and subprime loans within 2436
your portfolio. 137
           GOVERNOR OLSON:  Janice, we, at the 237
Fed, have become increasingly conscious of the 337
difference in cost in clearing checks between 437
checks that can be cleared electronically and 537
checks that are cleared manually, and the cost 637
difference is significant, and, of course, you 737
take that and you apply it to mortgage processes, 837
which is back to the point you were making, a very 937
important point, the efficiencies available 1037
through the consolidation of credit data, such as 1137
a credit score, obviously improve the efficiency 1237
of that system; it gets passed down one way or 1337
another.  And yet, I think the market needs to be 1437
aware, not only of the Latino borrowers, but many 1537
other minority groups, whose pattern or habits or 1637
culture falls outside of the norm, and yet, the 1737
availability of homeownership and homeownership 1837
mortgage products ought to be available. 1937
           Talk more about that issue from your 2037
perspective, as to how we can bridge that gap and 2137
how we can deal with the borrowers that fall 2237
outside of the most efficient channels. 2337
           MS. BOWDLER:  I think the work on this 2437
has actually been done.  The products just aren't 138
used.  I know, for example, Fannie Mae and Freddie 238
Mac have products that allow for no credit scores 338
and the documenting of untraditional credit 438
history. 538
           Two other major underwriting barriers 638
are, not being able to verify income or assets 738
and/or not being able to verify employment.  For 838
example, it's really common for low wage workers 938
that you might have had consistent employment in 1038
two years, but there could be gaps in that if some 1138
of that was cash income, especially in the 1238
construction industry.  So there are products out 1338
there that account for that. 1438
           GOVERNOR OLSON:  We have this 1538
dichotomy.  On the one hand, you have products 1638
that are naturally suited, the stated income 1738
products, which fit that, but on the other hand, 1838
it's the stated income product which also allows 1938
for -- unlike the conforming product, Peter, 2038
Freddie and Fannie, that's always sold in the 2138
secondary market, you have a product that allows 2238
for it, but on the other hand, there's a wide 2338
range of -- there's opportunity for abuse with 2438
that product, to put it mildly. 139
           MS. BOWLDER:  Right.  And we see a lot 239
of abuse with that product.  I think one of the 339
important things for us is that the products are 439
available to answer the needs of those clients, 539
there's just not much incentive to use them and 639
they cost more.  So, our view of proprietary data, 739
through partner financial institutions, shows that 839
they're making this review of data from the 939
northeast, southeast, East Coast corridor.  They 1039
weren't making more than five loans a market that 1139
use nontraditional credit history or have zero 1239
credit scores.  They're very, very little.  When 1339
they held them in portfolio, they priced them 1439
higher.  When they sold them to Fannie or Freddie, 1539
they were priced more conventionally, but either 1639
way, it still took more work for them to do.  They 1739
just had no one to tell them to do that.  It's 1839
easier and more profitable to refer them to the 1939
subprime market where they'll get into a stated 2039
income loan, or they have somebody there that, 2139
maybe, is more willing to take the time to go 2239
through the manual process. 2339
           GOVERNOR OLSON:  Ira, you talked about 2439
the wide range of -- the growing, increasing 140
difficulty of understanding, and there again, 240
you've got multiple factors impacting that.  On 340
the one hand, you've got a much wider range of 440
products, which allows for more product and you 540
have a much more avaricious secondary market, 640
we'll want to come back to that with both Doug and 740
Peter, and on the other hand, a larger number of 840
borrowers, many of them first-time, and, perhaps, 940
lesser educated, a lot of societal value in that 1040
but also some real risks in that.  So could you 1140
talk about both sides of that and how you see 1240
that? 1340
           MR. GOLDSTEIN:  On the risk side, I 1440
think something that Mr. Duncan said, the cost 1540
turner would make cost experience more profitable 1640
to lend to has declined, and I think that the last 1740
piece of research that I mentioned in my comments 1840
is relevant to that, and that is, the costing 1940
trend to lend to that group has declined and that 2040
is something that, sort of, works out for the 2140
borrower and the lender, but that's a 2240
risk-adjusted cost, and that means that the 2340
lenders are being compensated for the risk of the 2440
daily return of that loan.  That's a deal between 141
the borrower and the lender.  That's not a deal 241
between me the neighbor of that borrower and that 341
lender. 441
           What our research shows is that there 541
is a substantial and statistically significant, if 641
properly done, controlled difference, an adverse 741
effect of when the borrower and lender get into 841
that risk adjusted agreement, assuming the 941
borrower even understands that agreement. 1041
           On the upside, definitely, if you look 1141
at homeownership rates, and they have increased, 1241
if you look at the demographic groups for whom 1341
homeownership has increased, there's certainly -- 1441
the rates, although not equal, have grown much 1541
faster among minority group members, and in local 1641
markets like Philadelphia, they're much greater 1741
among low-income markets.  So the benefits are 1841
clearly there.  However, the risks are great and, 1941
really, should be seen in tandem between those 2041
benefits. 2141
           MS. BRAUNSTEIN:  I'd like to get back 2241
to the channels and the shopping a little bit. 2341
One of the things that we saw, that everybody saw 2441
in the 2004 HMDA data, which was that minorities 142
are more likely to get loans from subprime 242
lenders.  And we talked a little bit about this 342
today, but it seemed like Doug, in particular, 442
was, it's the consumers who need to do better 542
about shopping and looking around, but I'd also 642
like to, also, explore the flip side of that.  I 742
mean, how good a job are the prime lenders doing, 842
in terms of reaching out to minority communities? 942
Is that part of the issue too?  Is it just that 1042
the consumers aren't educated enough to go to 1142
prime lenders, or are the prime lenders not trying 1242
to market those opportunities in minority 1342
neighborhoods as well as they should? 1442
           MR. DUNCAN:  We did a survey of a 1542
thousand people who bought homes.  This was in 1642
1999, so it's a little bit dated.  And in it, we 1742
asked a couple things.  We asked, "How did you 1842
start the process of information gathering?" 1942
Because that was a point in time when people were 2042
really starting to focus on outreach to minority 2142
borrowers, in particular.  When we ask companies 2242
anecdotally, "How do you market to different 2342
minority groups?"  They say, "Well, we spend a lot 2442
of money on marketing."  And so, we say, "But 143
where do you spend it?"  Whey say, "Well, we spend 243
a lot of money on marketing."  So then, we say, 343
"Well, do you know if anyone's listening?" 443
           So, when we conducted the survey, found 543
some very interesting things.  What we found was 643
that if you were speaking to Asians over the 743
television, they weren't listening.  If you were 843
speaking to the Hispanics through the newspapers, 943
they weren't reading it.  There was, within the 1043
Hispanic community, a dramatic difference that 1143
that relationship had, within family and church 1243
and things like that, on where they gathered their 1343
information on the mortgage process.  With the 1443
African-American community, things like housing 1543
fairs on television were more effective.  White 1643
population was, sort of, all over the mark. 1743
Asians very much gathered information through the 1843
newspaper. 1943
           So we took that back to the industry 2043
and said, you need to think about, in your 2143
outreach, that you are spending your resources and 2243
attempting to reach the customer in a way that the 2343
customer isn't listening.  So there's been change 2443
based on some early lack of investigation. 144
           MS. BRAUNSTEIN:  And Janice, can you 244
comment from your perspective.  Do you think 344
that's true; has there been change in that? 444
           MS. BOWDLER:  I think there has been 544
some change, but part of that is the qualitative 644
piece to what they are marketing.  I've been on a 744
little project lately, where I've been gathering 844
all the Spanish language newspapers that I can and 944
listening to the Spanish radio.  And for months 1044
now, the only thing that's advertised in the Casa 1144
Sections of the Spanish language press, are option 1244
mortgages, one hundred percent financing, and 1344
stated income loans, with your documents, without 1444
your documents, with proof of income, without 1544
proof of income. 1644
           Recently, I've seen several mainstream 1744
prime lender advertising -- two, I saw two, but 1844
they were advertising these same products.  They 1944
were not advertising the 30-year fixed products 2044
that they advertise in the Washington Post.  It's 2144
the same on Spanish language radio.  Although, 2244
it's much more broker focused. 2344
           That's anecdotal, but this is also what 2444
I hear from the counselors, whose great 145
competition are the brokers and the subprime 245
lenders, because counselors tell you, you've got 345
to wait six months, and somebody else will tell 445
you, if you want a loan, like other people have 545
said, you can find a loan.  What their experience 645
has been, is that they will market to the Latino 745
client, these products that have the lower initial 845
down payments that then rise later, and they're 945
not marketing the same kind of products as they're 1045
marketing to the other communities.  And they're 1145
certainly not marketing the conventional Fannie, 1245
Freddie, nontraditional credit history products 1345
that are available. 1445
           MR. CHANIN:  Let me follow something up 1545
with Peter.  How you view this issue dictates, to 1645
some extent, what you view the solution to this 1745
issue or problem is.  One of the things you 1845
mentioned is, the HMDA data clearly shows there's 1945
a disparity, in terms of the percentage of 2045
minority versus non-minority borrowers and higher 2145
priced loans.  And you cautiously -- your lawyers 2245
must have advised you -- you cautiously said, much 2345
of this difference is explained by risk factors. 2445
My question is, can you quantify the percentage of 146
factors that are explained by credit score, loan 246
value, or other materials?  Is it 40 percent, or 346
80 percent, or 30 percent of that data that 446
explain those differences, in terms of rates 546
received? 646
           MR. ZORN:  Sure.  Let me put some 746
qualifiers in front of this.  What I will give 846
you, is on the basis of the data that we are 946
currently using, so this is an A sample, large 1046
sample, subprime lenders.  But for the data that 1146
we're looking at, we can get odds, ratios, APRs 1246
down to within, sort of, 1.2.  So, starting from 1346
the odds ratio of 3 to 1 for differential APRs in 1446
raw data, between minorities and non minorities, 1546
we can get it down to, sort of, a 1.2 kind of 1646
range.  Of course, we have ability plus 1746
observations, so any difference is statistically 1846
significant.  I'm not saying that that difference 1946
is not, also, economically significant, but it's 2046
substantially smaller. 2146
           MR. COLLINS:  Peter, if I could ask a 2246
question.  In your look at the higher APRs for 2346
minority borrowers, do they have an adequate 2446
understanding of their credit profile and credit 147
scores?  Do they know whether or not they can 247
qualify for prime credit?  If they come in through 347
the subprime channel, do they get to the prime 447
channel?  And secondly, getting back to the 547
marketing piece of it, do they approach lenders 647
with the higher rates based on advertising in the 747
market?  If they have sufficient understanding, is 847
their financial literacy around credit scores and 947
what they would actually qualify for? 1047
           MR. ZORN:  I guess the short answer is 1147
no, but I guess -- but it's more -- we have no one 1247
killer data source.  So we've got 2005 data where 1347
we've got a lot of detailed credit information, 1447
but not survey data where we know a lot about 1547
their financial knowledge.  We've got financial 1647
knowledge and survey data back from three or four 1747
years ago.  And this is a rapidly evolving market 1847
as everyone is describing. 1947
           But what's certainly true, is that when 2047
you ask people -- so in our survey data, which is 2147
several thousand borrowers, and you ask people -- 2247
we gave them a little financial quiz, essentially, 2347
and asked a bunch of questions that we thought 2447
would be relevant for someone who was financially 148
knowledgeable, and then also asked them to 248
self-assess their financial knowledge.  We asked 348
them to self-assess their credit, and we pulled 448
their credit.  So we had observable objective 548
credit, observable objective knowledge, and 648
subjective self-assessed credit and subjective 748
self-assessed knowledge.  What's true was that 848
there was definitely a large number of people who 948
did not have what we consider to be an accurate 1048
assessment of their knowledge and an accurate 1148
assessment of their credit, and disproportionately 1248
that tended to be true of minority borrowers. 1348
           We would like to believe that it is 1448
disproportionately people who poorly understand 1548
their credit, who end up -- so for example, people 1648
who believe they are worse creditors than they 1748
actually are, who end up in the subprime market. 1848
Despite the fact that we've portioned it out, we 1948
haven't got it to say that yet, but we haven't got 2048
it to reject that either.  So, I say that's my 2148
personal, maintained hypothesis.  I cannot give to 2248
you empirical evidence to suggest it.  I believe 2348
it must be true, but I don't know if it is true or 2448
not. 149
           MS. BRAUNSTEIN:  We've heard that 249
anecdotally before, that people often -- it's like 349
a self-fulfilling prophecy.  They think their 449
credit's worse than it is, and they go to a 549
subprime lender. 649
           MR. ZORN:  What we can't show is the 749
people who actually think they have better credit 849
than they do, are very effective in getting prime 949
loans.  I don't know what that means. 1049
           MS. BRAUNSTEIN:  They are very 1149
effective? 1249
           MR. ZORN:  Yes, they are. 1349
           GOVERNOR OLSON:  They are very 1449
effective? 1549
           MR. ZORN:  Yes, they are.  I think my 1649
observation on that one is, what it reflects is -- 1749
the -- getting back to Doug's point -- right now, 1849
you can still observe channels, and this is 1949
getting back to Michael's question, what's a 2049
subprime lender, what's a prime lender.  Like 2149
Doug, what we do is ask people to self-assess or 2249
we self-assess for them, but we don't do it loan 2349
by loan, we do it sub by sub, if you will, and I 2449
believe that distinction was greater in 2000 than 150
it is in 2005 and 2006 and is diminishing rapidly. 250
And so part of the story that explains this, is 350
that just because you get a loan from a prime 450
lender does not mean you're home free.  It doesn't 550
mean you can't pay a high rate and a rate that's 650
not necessarily, by some other people's standards, 750
the right rate.  Because that middle range of A 850
minus lending is increasingly an active and 950
competitive area for both, what we consider, to be 1050
prime lenders and subprime lenders. 1150
           So, I believe, I mean, it's still okay, 1250
in general, I believe, to talk about, isn't it 1350
better to get a prime loan than a subprime loan. 1450
Again, that's a central tendency.  I don't believe 1550
it's always true. 1650
           MR. DUNCAN:  If I could.  In looking -- 1750
to, kind of, take that point a little further, 1850
when we take credit scores from portfolios of 1950
lenders who classify themselves as prime lenders 2050
and from portfolios of subprime lenders, and 2150
there's an overlap in the center.  So you would 2250
say, gee, well, then, aren't there some of these 2350
people that have this credit score, should have 2450

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2006 Hearings