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THE BUST                                                      


         banks would originate “a bad mortgage because they thought the government policy
         allowed it” unless the bank could sell off the mortgage to Fannie or Freddie, which
         had their own obligations in this arena. He said, “It’s hard for me to answer. If the rea-
         son the regulators didn’t jump up and down and yell at the low-doc, no-doc sub-
         prime mortgage was because they felt that they, Congress had sort of pushed in that
         direction, then I would say yes.” 
            “You know, CRA could be a pain in the neck,” the banker Lewis Ranieri told the
         FCIC. “But you know what? It always, in my view, it always did much more good
         than it did anything. You know, we did a lot. CRA made a big difference in communi-
         ties. . . . You were really putting money in the communities in ways that really stabi-
         lized the communities and made a difference.” But lenders including Countrywide
         used pro-homeownership policies as a “smokescreen” to do away with underwriting
         standards such as requiring down payments, he said. “The danger is that it gives air
         cover to all of this kind of madness that had nothing to do with the housing goal.” 

                        RATING DOWNGRADES: “NEVER BEFORE”

         Prior to , the ratings of mortgage-backed securities at Moody’s were monitored
         by the same analysts who had rated them in the first place. In , Nicolas Weill,
         Moody’s chief credit officer and team managing director, was charged with creating
         an independent surveillance team to monitor previously rated deals. 
            In November , the surveillance team began to see a rise in early payment de-
         faults in mortgages originated by Fremont Investment & Loan, and downgraded
                                                            
         several securities with underlying Fremont loans or put them on watch for future
         downgrades. “This was a very unusual situation as never before had we put on watch
         deals rated in the same calendar year,” Weill later wrote to Raymond McDaniel, the
         chairman and CEO of Moody’s Corporation, and Brian Clarkson, the president of
         Moody’s Investors Service. 
            In early , a Moody’s special report, overseen by Weill, about the sharp in-
         creases in early payment defaults stated that the foreclosures were concentrated in
         subprime mortgage pools. In addition, more than . of the subprime mortgages
         securitized in the second quarter of  were  days delinquent within six months,
         more than double the rate a year earlier (.). The exact cause of the trouble was
         still unclear to the ratings agency, though. “Moody’s is currently assessing whether
         this represents an overall worsening of collateral credit quality or merely a shifting
         forward of eventual defaults which may not significantly impact a pool’s overall ex-
         pected loss.” 
            For the next few months, the company published regular updates about the sub-
         prime mortgage market. Over the next three months, Moody’s took negative rating
         actions on . of the outstanding subprime mortgage securities rated Baa. Then, on
         July , , in an unprecedented move, Moody’s downgraded  subprime mort-
         gage-backed securities that had been issued in  and put an additional  securi-
         ties on watch. The . billion of securities that were affected, all rated Baa and lower,
         made up  of the subprime securities that Moody’s rated Baa in . For the time
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