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Notes to Chapter 6 569

54. Robert B. Avery, Glenn B. Canner, and Robert E. Cook, “New Information Reported under
HMDA and Its Application in Fair Lending Enforcement,” Federal Reserve Bulletin 91 (Summer 2005):
372.
55. Alan Greenspan, interview by FCIC, March 31, 2010
56. Sheila Bair, testimony before the FCIC, Hearing on Too Big to Fail: Expectations and Impact of
Extraordinary Government Intervention and the Role of Systemic Risk in the Financial Crisis, day 2, ses-
sion 2: Federal Deposit Insurance Corporation, September 2, 2010, transcript, p. 191.
57. Dolores Smith and Glenn Loney, memorandum to Governor Edward Gramlich, “Compliance In-
spections of Nonbank Subsidiaries of Bank Holding Companies,” August 31, 2000.
58. GAO, “Consumer Protection: Federal and State Agencies Face Challenges in Combating Preda-
tory Lending,” GAO 04–280 (Report to the Chairman and Ranking Minority Member, Special Commit-
tee on Aging, U.S. Senate), January 2004, pp. 52–53.
59. Sandra Braunstein, interview by FCIC, April 1, 2010. Transcript pp. 32–33.
60. Greenspan, interview.
61. Ibid.
62. Edward M. Gramlich, “Booms and Busts: The Case of Subprime Mortgages,” Federal Reserve Bank
of Kansas City Economic Review (2007): 109.
63. Edward Gramlich, quoted in Greg Ip, “Did Greenspan Add to Subprime Woes? Gramlich Says Ex-
Colleague Blocked Crackdown On Predatory Lenders Despite Growing Concerns,” Wall Street Journal,
June 9, 2007. See also Edmund L. Andrews, “Fed Shrugged as Subprime Crisis Spread,” New York Times,
December 18, 2007.
64. Patricia McCoy and Margot Saunders, quoted in Binyamin Appelbaum, “Fed Held Back as Evi-
dence Mounted on Subprime Loan Abuses,” Washington Post, September 27, 2009.
65. GAO, “Large Bank Mergers: Fair Lending Review Could be Enhanced with Better Coordination,”
GAO/GDD-00-16 (Report to the Honorable Maxine Waters and Honorable Bernard Sanders, House of
Representatives), November 1999; GAO, “Consumer Protection: Federal and State Agencies Face Chal-
lenges in Combating Predatory Lending.”
66. “Federal and State Agencies Announce Pilot Project to Improve Supervision of Subprime Mort-
gage Lenders,” Joint press release (Fed Reserve Board, OTC, FTC, Conference of State Bank Supervisors,
American Association of Residential Mortgage Regulators), July 17, 2007.
67. “Truth in Lending,” pp. 44522–23. “Higher-priced mortgage loans” are defined in the 2008 regula-
tions to include mortgage loans whose annual percentage rate exceeds the “average prime offer rates for a
comparable transaction” (as published by the Fed) by at least 1.5% for first-lien loans or 3.5% for subordi-
nate-lien loans.
68. Alvarez, interview.
69. Raphael W. Bostic, Kathleen C. Engel, Patricia A. McCoy, Anthony Pennington-Cross, and Susan
M. Wachter, “State and Local Anti-Predatory Lending Laws: The Effect of Legal Enforcement Mecha-
nisms,” Journal of Economics and Business 60 (2008): 47–66.
70. “Lending and Investment,” Federal Register 61, no. 190 (September 30, 1996): 50965.
71. Joseph A. Smith, “Mortgage Market Turmoil: Causes and Consequences,” testimony before the
Senate Committee on Banking, Housing, and Urban Affairs, 110th Cong., 1st sess., March 22, 2007, p. 33
(Exhibit B), using data from the Mortgage Asset Research Institute.
72. Lisa Madigan, written testimony for the FCIC, First Public Hearing of the FCIC, day 2, panel 2:
Current Investigations into the Financial Crisis—State and Local Officials, January 14, 2010, p.12.
73. Commitments compiled at National Community Reinvestment Coalition, “CRA Commitments”
(2007).
74. Josh Silver, NCRC, interview by FCIC, June 16, 2010.
75. Data references based on Reginald Brown, counsel for Bank of America, letter to FCIC, June 16,
2010, p. 2; Jessica Carey, counsel for JPMorgan Chase, letter to FCIC, December 16, 2010; Brad Karp,
counsel for Citigroup, letter to FCIC, March 18, 2010, in response to FCIC request; Wells Fargo public
commitments 1990–2010, data provided by Wells Fargo to the FCIC.
76. Karp, letter to FCIC, March 18, 2010, in response to FCIC request.
77. Carey, letter to FCIC, December 16, 2010, p. 9; Brad Karp, counsel for JP Morgan, letter to FCIC,
May 26, 2010, p. 10.