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SUMMARY



              Although there were many contributing factors, the housing bubble of 1997-
         2007 would not have reached its dizzying heights or lasted as long, nor would
         the fi nancial crisis of 2008 have ensued, but for the role played by the housing
         policies of the United States government over the course of two administrations.
         As a result of these policies, by the middle of 2007, there were approximately 27
         million subprime and Alt-A mortgages in the U.S. fi nancial system—half of all
                                                                 4
         mortgages outstanding—with an aggregate value of over $4.5 trillion.  Th ese were
         unprecedented numbers, far higher than at any time in the past, and the losses
         associated with the delinquency and default of these mortgages fully account for
         the weakness and disruption of the fi nancial system that has become known as the
         fi nancial crisis.
              Most subprime and Alt-A mortgages are high risk loans. A subprime
         mortgage is a loan to a borrower who has blemished credit, usually signifi ed by
                                      5
         a FICO credit score lower than 660.  Typically, a subprime borrower has failed in
         4   Unless otherwise indicated, all estimates for the number of subprime and Alt-A mortgages outstanding,
         as well as the use of specifi c terms such as loan to value ratios and delinquency rates, come from research
         done by Edward Pinto, a resident fellow at the American Enterprise Institute. Pinto is also a consultant
         to the housing fi nance industry and a former chief credit offi  cer of Fannie Mae. Much of this work is
         posted on both my and Pinto’s scholar pages at AEI as follows: http://www.aei.org/docLib/Pinto-Sizing-
         Total-Exposure.pdf, which accounts for all 27 million high risk loans; http://www.aei.org/docLib/
         Pinto-Sizing-Total-Federal-Contributions.pdf, which covers the portion of these loans that were held or
         guaranteed by federal agencies and the four large banks that made these loans under CRA; and http://
         www.aei.org/docLib/Pinto-High-LTV-Subprime-Alt-A.pdf, which covers the acquisition of these loans
         by government agencies from the early 1990s. Th  e information in these memoranda is fully cited to
         original sources. Th  ese memoranda were the data exhibits to a Pinto memorandum submitted to the
         FCIC in January 2010, and revised and updated in March 2010 (collectively, the “Triggers memo”).
         5   One of the confusing elements of any study of the mortgage markets is the fact that the key defi nitions
         have never been fully agreed upon. For many years, Fannie Mae treated as subprime loans only those
         that it purchased from subprime originators. Inside Mortgage Finance, a common source of data on
         the mortgage market, treated and recorded as subprime only those loans reported as subprime by the
         originators or by Fannie and Freddie. Other loans were recorded as prime, even if they had credit scores
         that would have classifi ed them as subprime. However, a FICO credit score of less than 660 is generally
         regarded as a subprime loan, no matter how originated. Th  at is the standard, for example, used by the
         Offi  ce of the Comptroller of the Currency. In this statement and in Pinto’s work on this issue, loans that
         are classifi ed as subprime by their originators are called “self-denominated” subprime loans, and loans
         to borrowers with FICO scores of less than 660 are called subprime by characteristic. Fannie and Freddie
         reported only a very small percentage of their loans as subprime, so in eff ect the subprime loans acquired
         by Fannie and Freddie should be added to the self-denominated subprime loans originated by others in
         order to derive something closer to the number and principal amount of the subprime loans outstanding
         in the fi nancial system at any given time. One of the important elements of Edward Pinto’s work was to
         show that Fannie and Freddie, for many years prior to the fi nancial crisis, were buying loans that should
         have been classifi ed as subprime because of the borrowers’ credit scores and not simply because they were
         originated by subprime lenders. Fannie and Freddie did not do this until aft er they were taken over by
         the federal government. Th  is lack of disclosure on the part of the GSEs appears to have been a factor in
         the failure of many market observers to foresee the potential severity of the mortgage defaults when the
         housing bubble defl ated in 2007.
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