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584 Notes to Chapter 9

86. Dennis Voigt Crawford, testimony before the FCIC, First Public Hearing of the FCIC, day 2, ses-
sion 2: Current Investigation into the Financial Crisis—State and Local Officials, January 14, 2010,
p. 112.
87. Richard Breeden, interview by FCIC, October 14, 2010. See Public Law 104–290 (Oct. 11, 1996);
Rule 144A contained provisions that ensured it did not expand to the securities markets in which retail
investors did participate.
88. Federal Reserve Board, SR 9724, “Risk-Focused Framework for Supervision of Large Complex In-
stitutions,” October 27, 1997.
89. Alan Greenspan, “The Evolution of Bank Supervision,” speech before the American Bankers As-
sociation, Phoenix, Arizona, October 11, 1999.
90. Eugene Ludwig, interview by FCIC, September 2, 2010.
91. Federal Reserve Bank of New York, “Report on Systemic Risk and Supervision,” Draft of August 5,
2009, p. 2.
92. Rich Spillenkothen, “Notes on the performance of prudential supervision in the years preceding
the financial crisis by a former director of banking supervision and regulation at the Federal Reserve
Board (1991 to 2006),” May 31, 2010, 12.
93. Susan Bies, interview by FCIC, October 11, 2010.
94. Bernanke, letter to the FCIC, December 21, 2010.
95. John Snow, interview by FCIC, October 7, 2010.
96. Office of the Comptroller of the Currency, Board of Governors of the Federal Deposit Insurance
Corporation, Office of Thrift Supervision, and National Credit Union Administration, “Credit Risk
Management Guidance for Home Equity Lending,” May 16, 2005.
97. 2009 Mortgage Market Statistical Annual, 1:3; “Residential Mortgage Lenders Peer Group Survey:
Analysis and Implications for Guidance,” PowerPoint presentation, November 30, 2005, pp. 13, 3.
98. Sabeth Siddique, interview by the FCIC, September 9, 2010.
99. “Residential Mortgage Lenders Peer Group Survey: Analysis and Implications for Guidance,”
PowerPoint, November 30, 2005.
100. Bies, interview.
101. Office of the Comptroller of the Currency, Board of Governors of the Federal Deposit Insurance
Corporation, Office of Thrift Supervision, and National Credit Union Administration, “Interagency
Guidance on Nontraditional Mortgage Products,” Federal Register 70 (December 29, 2005): 77,249,
72,252, 72,253.
102. Paul Smith, American Bankers Association, letter to the Federal Deposit Insurance Corporation,
Board of Governors of the Federal Reserve System, Office of Thrift Supervision, and Office of the Comp-
troller of the Currency, March 29, 2006, p. 2.
103. Letter from American Financial Services Association to federal regulators 8, available at
http://www.ots.treas.gov/_files/comments/d1e85ce1–07ab-4acf-8db5–8d1747afba0a.pdf.
104. Letters to the Office of Thrift Supervision from the American Bankers Association (March 29,
2006), p. 2; the American Financial Services Association (March 28, 2006), p. 8; and Indymac Bank
(March 29, 2006), p. 4.
105. The Housing Policy Council of the Financial Services Roundtable, letter to the Office of Thrift
Supervision, March 29, 2006, p. 6.
106. Siddique, interview.
107. Binyamin Appelbaum and Ellen Nakashima, “Banking Regulator Played Advocate Over En-
forcer: Agency Let Lenders Grow Out of Control, Then Fail,” Washington Post, November 23, 2008.
108. Bies, interview.
109. See, e.g. “Countrywide Seeks to Become Savings Bank; The Mortgage Lender Says It Is Planning
to Apply to Convert Its Charter So It Will Be Regulated by One Federal Agency instead of Two,” Los An-
geles Times, November 11, 2006, based on Bloomberg, Reuters.
110. Kim Sherer, interview by FCIC, August 3 2003.
111. Countrywide, “Briefing Paper: Meeting with Office of Thrift Supervision, Thursday July 13,
2006.”