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566 Notes to Chapter 6

27. 15 U.S.C. § 1639(h) 2006.
28. Loans were subject to HOEPA only if they hit the interest rate trigger or fee trigger: i.e., if the an-
nual percentage rate for the loan was more than 10 percentage points above the yield on Treasury securi-
ties having a comparable maturity or if the total charges paid by the borrower at or before closing
exceeded $400 or 8% of the loan amount, whichever was greater. See Senate Committee on Banking,
Housing, and Urban Affairs, S. Rep. 103–169, p. 54.
29. Ibid., p. 24.
30. Board of Governors of the Federal Reserve System and Department of Housing and Urban Devel-
opment, “Joint Report Concerning Reform to the Truth in Lending Act and the Real Estate Settlement
Procedures Act” (July 1998), p. 56.
31. Griffith L. Garwood, director, Division of Consumer and Community Affairs, Board of Gover-
nors of the Federal Reserve System, “To the Officers and Managers in Charge of Consumer Affairs Ex-
amination and Consumer Complaint Programs,” Consumer Affairs Letter CA 98–1, January 20, 1998
32. GAO, “Large Bank Mergers: Fair Lending Review Could Be Enhanced with Better Coordination,”
GAO/GGD-00–16 (Report to the Honorable Maxine Waters and the Honorable Bernard Sanders, House
of Representatives), November 1999, p. 20.
33. Fed and HUD, “Joint Report,” pp. I–XXVII.
34. Griffith L. Garwood, director, Division of Consumer and Community Affairs, Board of Gover-
nors of the Federal Reserve System, memorandum to the Committee on Consumer and Community Af-
fairs, “Memorandum concerning the Board’s Report to the Congress on the Truth in Lending and Real
Estate Settlement Procedures Acts,” April 8, 1998, p. 42.
35. Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office
of the Comptroller of the Currency, and Office of Thrift Supervision, “Interagency Guidance on Sub-
prime Lending” (March 1, 1999), p. 1
36. Ibid., pp. 1–7; quotation, p. 5.
37. U.S. Department of the Treasury and U.S. Department of Housing and Urban Development,
“Curbing Predatory Home Lending” (June 1, 2000), pp. 13–14, 1–2, 81 (quotations, 2, 1–2).
38. Gail Burks, president and chief executive officer, Nevada Fair Housing Center, Inc., testimony be-
fore the FCIC, Hearing on the Impact of the Financial Crisis—State of Nevada, session 3: The Impact of
the Financial Crisis on Nevada Real Estate, September 8, 2010, transcript, p. 242–43.See also Kevin Stein,
associate director, California Reinvestment Coalition, written testimony for the FCIC, Hearing on the
Impact of the Financial Crisis—Sacramento, session 2: Mortgage Origination, Mortgage Fraud and
Predatory Lending in the Sacramento Region, September 23, 2010, pp. 8–9. See also his testimony at the
same hearing, transcript, pp. 73–74. See Diane E. Thompson, of counsel, National Consumer Law Cen-
ter, Inc., and Margot F. Saunders, of counsel, National Consumer Law Center, Inc., interview by FCIC,
September 10, 2010.
39. Diane E. Thompson and Margot F. Saunders, both of counsel, National Consumer Law Center, in-
terview by FCIC, September 10, 2010.
40. Gary Gensler, interview by FCIC, May 14, 2010.
41. Sheila Bair, testimony before the FCIC, First Public Hearing of the FCIC, day 2, panel 1: Current
Investigations into the Financial Crisis—Federal Officials, January 14, 2010, transcript, p. 97.
42. Sheila Bair, interview by FCIC, March 29, 2010.
43. Sandra F. Braunstein, interview by FCIC, April 1, 2010, pp. 31–34.
44. Bair, interview.
45. Treasury and HUD, “Curbing Predatory Home Lending,” p. 31.

Chapter 6
1. Figures represented the compound average growth rate and FCIC staff calculations from CoreLogic
National Home Price Index, Single-Family Combined (SCF); CoreLogic Loan Performance HPI August
2010.
2. Inside Mortgage Finance, The 2009 Mortgage Market Statistical Annual, vol. 1, The Primary Market
(Bethesda, Md.: Inside Mortgage Finance, 2009), p. 4, “Mortgage Originations by Product.”
3. Federal Reserve Board press release, May 27, 2004.