History

The original Act was passed in 1977, several legislative applications and regulatory revisions have been enacted since then.

[edit] Original Act

The CRA was passed by the 95th United States Congress and signed into law by President Jimmy Carter in 1977 as a result of national pressure to address the deteriorating conditions of American cities – particularly lower-income and minority neighborhoods.[7] It followed similar laws passed to reduce discrimination in the credit and housing markets including the Fair Housing Act (1968), the Home Mortgage Disclosure Act of 1975 (HMDA) and the Equal Credit Opportunity Act (1974). The Equal Credit Opportunity Act and the Fair Housing Act prohibit discrimination on the basis of race, sex, or other personal characteristics. The Home Mortgage Disclosure Act requires that financial institutions publicly disclose mortgage lending and application data. In contrast with those acts, the CRA seeks to ensure the equal provision of credit to various parts of a community – regardless of the relative wealth or poverty of an neighborhood.[13][4]

Before the Act was passed, there were severe shortages of credit available to low- and moderate-income neighborhoods. In their 1961 report, the U.S. Commission on Civil Rights found that African-American borrowers were often required to make higher down payments and adopt faster repayment schedules. The commission also documented blanket refusals to lend in particular areas (redlining).[16] Contributory factors in the shortage of direct lending in low- and moderate-income communities were a limited secondary market for mortgages, informational problems to do with the lack of credit evaluations for lower-income borrowers, and lack of coordination among credit agencies.[4][7][13]

In Congressional debate on the Act, critics charged that the law would “distort credit markets, create unnecessary regulatory burden, lead to unsound lending, and cause the governmental agencies charged with implementing the law to allocate credit.” Partly in response to these concerns, Congress included little prescriptive detail and simply directs the banking regulatory agencies to ensure that banks and savings associations serve the credit needs of their local communities in a safe and sound manner.[13][7] Community groups only slowly organized to take advantage of their right under the Act to complain about law enforcement of the regulations.[17]

Speaking in 2007, the 30th anniversary of the CRA, Ben Bernanke, Chair of the Federal Reserve System since 2006, stated that the high costs of gathering information, “may have created a ‘first-mover’ problem, in which each financial institution has an incentive to let one of its competitors be the first to enter an underserved market.” Bernanke notes that at least in some instances, “the CRA has served as a catalyst, inducing banks to enter underserved markets that they might otherwise have ignored”.[7]

[edit] Legislative changes 1989–1994

The Financial Institutions Reform Recovery and Enforcement Act of 1989 (FIRREA) was enacted by the 101st Congress and signed into law by President George H. W. Bush in the wake of the savings and loan crisis of the 1980s. As part of a general reform of the banking industry, it increased public oversight of the process of issuing CRA ratings to banks. It required the agencies to issue CRA ratings publicly and written performance evaluations using facts and data to support the agencies’ conclusions. It also required a four-tiered CRA examination rating system with performance levels of ‘Outstanding’, ‘Satisfactory’, ‘Needs to Improve’, or ‘Substantial Noncompliance’.[13]

According to Ben Bernanke, this law greatly increased the ability of advocacy groups, researchers, and other analysts to “perform more-sophisticated, quantitative analyses of banks’ records,” thereby influencing the lending policies of banks. Over time, community groups and nonprofit organizations established “more-formalized and more-productive partnerships with banks.”[7]

In 1997, First Union Capital Markets and Bear, Stearns & Co launched the first publicly available securitization of CRA loans, issuing $384.6 million of such securities.[18] These public offerings had so much appeal they were several times oversubscribed by money managers and insurance companies who were not buying them for CRA credit.[19] Between 2000 and 2002 the government sponsored enterprise the Federal National Mortgage Association, commonly known as Fannie Mae, securitized $394 billion in CRA loans with $20 billion going to securitized mortgages.”[20] In 2000, in order to expand the secondary market for affordable community-based mortgages and to increase liquidity for CRA-eligible loans, Fannie Mae committed to purchase and securitize $2 billion of “MyCommunityMortgage” loans.[21][22] In 2007 Ben Bernanke suggested further increasing the presence of Sallie Mae and Freddie Mac (the Federal Home Loan Mortgage Corporation which increases secondary markets) in the affordable housing market to help banks fulfill their CRA obligations by providing them with more opportunities to securitize CRA-related loans.[23]

The Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994 which repealed restrictions on interstate banking, listed the CRA ratings received by the out-of-State bank as a consideration when determining whether to allow interstate branches.[24] Bernanke explains that because of the subsequent surge in bank mergers and acquisitions activities, advocacy groups increasingly protested such bank applications on CRA grounds. Agencies began to hold public hearings to allow such comment. In response many institutions established separate business units and corporations to facilitate CRA-related lending. To expand and manage such CRA-related local and regional public-private partnerships and multibank loan consortia were formed and gained more prominence.[7]

[edit] Regulatory changes 1995

In July 1993, President Clinton asked regulators to reform the CRA in order to reduce paperwork and reward performance. Robert Rubin, the Assistant to the President for Economic Policy, under President Clinton, explained that this was in line with President Clinton’s strategy to “deal with the problems of the inner city and distressed rural communities”. Discussing the reasons for the Clinton administration’s proposal to strengthen the CRA and further reduce red-lining, Lloyd Bentsen, Secretary of the Treasury at that time, affirmed his belief that availability of credit should not depend on where a person lives, “The only thing that ought to matter on a loan application is whether or not you can pay it back, not where you live.” Bentsen said that the proposed changes would “make it easier for lenders to show how they’re complying with the Community Reinvestment Act”, and “cut back a lot of the paperwork and the cost on small business loans”.[11]

The CRA regulations were substantially revised – using federal home-loan data broken down by neighborhood, income group, and race; encouraging community groups to complain to banks and regulators when banks did not meet their CRA obligations; allowing community groups that marketed loans to targeted groups to collect a fee from the banks just like other loan product marketers.[13] Information about banking institutions CRA ratings were made available via web page for public comment.[11]In May 1995, the Office of the Comptroller of the Currency also revised its regulations concerning CRA implementation. The new regulations allowed lenders subject to the CRA to claim community development loan credits for loans made to help finance the environmental cleanup or redevelopment of industrial sites when part of an effort to revitalize the low- and moderate-income community in which the site is located.[25]

During March 1995 congressional hearings William A. Niskanen, chair of the Cato Institute, criticized the proposals for political favoritism in allocating credit and micromanagement by regulators, and that there was no assurance that banks would not be expected to operate at a loss. He predicted they would be very costly to the economy and banking system, and that the primary long term effect would be to contract the banking system. He recommended Congress repeal the Act.[26]

Responding to concerns that the CRA would lower bank profitability, a 1997 research paper by economists at the Federal Reserve found that “[CRA] lenders active in lower-income neighborhoods and with lower-income borrowers appear to be as profitable as other mortgage-oriented commercial banks”.[27] Speaking in 2007, Federal Reserve Chair Ben Bernanke noted that, “managers of financial institutions found that these loan portfolios, if properly underwritten and managed, could be profitable” and that the loans “usually did not involve disproportionately higher levels of default”.[7]

According to a 2000 United States Department of the Treasury study of lending trends in 305 U.S. cities between 1993 and 1998, $467 billion in mortgage credit flowed from CRA-covered lenders to low- and medium-income borrowers. In that period, the total number of loans to poorer Americans by CRA-eligible institutions rose by 39% while loans to wealthier individuals by CRA-covered institutions rose by 17%. The share of total US lending to low and meduim income borrowers rose from 25% in 1993 to 28% in 1998 as a consequence. [28]

[edit] Legislative changes 1999

In 1999 the Congress enacted and President Clinton signed into law the Gramm-Leach-Bliley Act, also known as the “Financial Services Modernization Act,” which repealed the part of the Glass-Steagall Act prohibiting a bank from offering a full range of investment, commercial banking, and insurance services. The bill was killed in 1998 because Senator Phil Gramm wanted the bill to expand the number of banks which no longer would be covered by the CRA. He also demanded full disclosure of any financial deals which community groups had with banks, accusing such groups of “extortion.” In 1999 Senators Christopher Dodd and Charles E. Schumer broke another deadlock by forcing a compromise between Gramm and the Clinton administration which wanted to prevent banks from expanding into insurance or securities unless they were compliant with the CRA. In the final compromise, the CRA would cover bank expansions into new lines of business, community groups would have to disclose certain kinds of financial deals with banks, and smaller banks would be reviewed less frequently for CRA compliance.[29][30][31] On signing the Gramm-Leach-Bliley Act, President Clinton said that it, “establishes the principles that, as we expand the powers of banks, we will expand the reach of the [Community Reinvestment] Act”.[32]

[edit] Regulatory changes 2005–2008

In 2002 there was an inter-agency review of the effectiveness of the 1995 regulatory changes to the Community Reinvestment Act and new proposals were considered.[13] In 2003, researchers at the Federal Reserve Bank of New York noted that dramatic changes in the financial services landscape had weakened the CRA, and that [in 2003] less than 30 percent of all home purchase loans were subject to intensive review under the CRA.[33]

In early 2005, the Office of Thrift Supervision (OTS) implemented new rules that – among other changes – allowed thrifts with over $1 billion in assets to meet their CRA obligations without regard to services for, or investments in, their communities. In April 2005, a contingent of Democratic Congressmen issued a letter protesting these changes, saying they undercut the ability of the CRA to “meet the needs of low and moderate-income persons and communities”.[34]

The Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System, and the Office of the Controller of the Currency put a new set of regulations into effect in September 2005.[35] The regulations included less restrictive new definitions of “small” and “intermediate small” banks.[7] “Intermediate small banks” were defined as banks with assets of less than $1 billion, which allows these banks to opt for examination as either a small bank or a large bank.[35] Currently banks with assets greater than $1.061 billion have their CRA performance evaluated according to lending, investment and service tests. The agencies use the Consumer Price Index to adjust the asset size thresholds for small and large institutions annually.[13]

On February 13, 2008 the United States House Committee on Financial Services held a hearing on the Community Reinvestment Act’s impact on the provision of loans, investments and services to under-served communities and its effectiveness. There were 15 witnesses from government and the private sector.[36]

On April 15, 2008 an FDIC official told the committee that the FDIC was exploring offering incentives for banks to offer low-cost alternatives to payday loans. Doing so would allow them favorable consideration under their Community Reinvestment Act responsibilities. It had recently begun a two-year pilot project with an initial group of 31 banks.[37]

[edit] Controversies

The effects of the Community Reinvestment Act on the housing markets are controversial for a variety of reasons.

[edit] Effectiveness

Economists and financial people writing a Federal Reserve report, including Jeffrey W. Gunther, who also wrote a report on CRA for the Cato Institute, have wondered if the CRA was – or at least had become – irrelevant, because it was not needed to force banks to make profitable loans to a variety of lenders.[38][39] In a 2003 research paper, economists at the Federal Reserve could not find clear evidence that the CRA increased lending and home ownership more in low income neighborhoods than in higher income ones.[40] A 2008 Competitive Enterprise Institute study resulted in a similar finding.[41] Federal Reserve chair Ben Bernanke has stated that an underlying assumption of the CRA – that more lending equals better outcomes for local communities – may not always be true. However, he also notes that at least in some instances, “the CRA has served as a catalyst, inducing banks to enter under-served markets that they might otherwise have ignored”.[7]

The Woodstock Institute, a Chicago-based policy and advocacy nonprofit, found in an analysis of 1996 Chicago-area survey data that low income areas still lagged behind in access to commercial loans. Most small business loans made by CRA regulated banks went to higher income areas; 16.6% in low-income areas, 18.4% in low- and moderate-income tracts; 21.8% in middle-income areas and 23.1% in upper-income areas.[42]

In a 1998 paper, Alex Schwartz of the Fannie Mae Foundation found that CRA agreements were “consistently successful in meeting their goals for mortgages, investments in low-income housing tax credits, grant giving to community-based organizations, and in opening (and keeping open) inner-city bank branches.”[43]

In a 2005 paper for the New York University Law Review, University of Michigan law professor Michael S. Barr uses empirical evidence to demonstrate that the CRA had overcome market failures to increase access to credit for low-income, moderate-income, and minority borrowers at relatively low cost. He contends that the CRA is justified, has resulted in progress, and should be continued.[44]

Speaking to the February 2008 United States House Committee on Financial Services hearing on the Community Reinvestment Act, Sandra L. Thompson, Director of the Division of Supervision and Consumer Protection at the FDIC, lauded the positive impact of CRA, noting that, “studies have pointed to increases in lending to low- and moderate-income customers and minorities in the decades since the CRA’s passage.” She cited a study by the Joint Center for Housing Studies at Harvard University, that found that “data for 1993 through 2000 show home purchase lending to low- and moderate-income people living in low- and moderate-income neighborhoods grew by 94 percent – more than in any of the other income categories”.[4]

In his statement before the same hearing, New York University Professor of Economics Larry White stated that regulator efforts to “lean on “ banks in vauge and subjective ways to make loans is an “inappropriate instrument for achieving those goals.” In a world of national banking enterprises, these policies are more likely to drive institutions out of neighborhoods. He stated that better ways to accomplish the goals would be vigorous enforcement of anti-discrimination laws, of antitrust laws to promote competition, and federal funding of worthy projects directly through an “on-budget and transparent process” like the Community Development Financial Institutions Fund.[45]

[edit] Housing advocacy groups

In an article for the New York Post, economist Stan Liebowitz wrote that community activists intervention at yearly bank reviews resulted in their obtaining large amounts of money from banks, since poor reviews could lead to frustrated merger plans and even legal challenges by the Justice Department.[46] Michelle Minton noted that Chase Manhattan and J.P. Morgan donated hundred of thousands of dollars to ACORN at about the same time they had were to apply for permission to merge and needed to comply with CRA regulations.[41]

According to the New York Times, some of these housing advocacy groups provided early warnings about the potential impact of lowered credit standards and the resulting unsupportable increase in real estate values they were causing in low to moderate income communities. Ballooning mortgages on rental properties threatened to require large rent increases from low and moderate income tenants that could ill afford them. [47]

Housing advocacy groups were also leaders in the fight against subprime lending in low- and moderate-income communities, “In fact, community advocates had been telling the Federal Reserve about the dangers of subprime lending since the 1990s”, according to Inner City Press. “For example, Bronx-based Fair Finance Watch commented to the Federal Reserve about the practices of now-defunct non-bank subprime lender New Century, when U.S. Bancorp bought warrants for 24% of New Century’s stock. The Fed, rather than take any action on New Century, merely waited until U.S. Bancorp sold off some of the warrants, and then said the issue was moot.” However, subprime loans were so profitable, that they were aggressively marketed in low-and moderate-income communities, even over the objections and warnings of housing advocacy groups like ACORN.[48]

[edit] Predatory Housing Lending

In 2002 Kathleen C. Engel and Patricia A. McCoy published a study of the predatory lending implications of the CRA, noting that by the late 1990s, predatory high cost mortgages to “gullible borrowers” were leading to foreclosures against low-income people of color and the elderly. They found evidence of such lending practices by CRA covered banks, both directly in their own lending and indirectly in buying other parties’ predatory loans as investments or to help them obtain CRA compliance credit. They criticized CRA regulators for not punishing such predatory lending and recommended changes to make it do so.[49] Other analysts and community groups also complained about this problem in the early 1990s.[50][51]

The FDIC has tried to address this issue by “stopping abusive practices through the examination process and supervisory actions; encouraging banks to serve all members and areas of their communities fairly; and providing information and financial education to help consumers make informed choices”. FDIC policy currently states that “predatory lending can have a negative effect on a bank’s CRA performance.”[52]

[edit] Relation to 2008 financial crisis

See also: Subprime mortgage crisis

Some comentators have charged that the CRA contributed in part to the 2008 financial crisis as it encouraged banks to make unsafe loans. For example, economist Stan Liebowitz wrote in the New York Post that a strengthening of the CRA in the 1990s encouraged a loosening of lending standards throughout the banking industry.[46] In a commentary for CNN, Congressman Ron Paul, who serves on the United States House Committee on Financial Services, charged that the CRA with “forcing banks to lend to people who normally would be rejected as bad credit risks.”[53] A Christian Science Monitor editorial also mentions the Community Reinvestment Act and the government-backed Fannie Mae as being laws responsible for pushing banks and mortgage brokers into granting easy credit and subprime loans to those who could not afford them.[54] In a Wall Street Journal opinion piece, Austrian school economist Russell Roberts wrote that the CRA subsidized low-income housing by pressuring banks to serve poor borrowers and poor regions of the country.

Libertarian Jeffrey A. Miron, a senior lecturer in economics at Harvard University, in an opinion piece for CNN, goes so far as to call for “getting rid” of Fannie Mae and Freddie Mac, as well as policies like the Community Reinvestment Act that “pressure banks into subprime lending.”[55]

However, others dispute the involvement of the CRA in the crisis. In a Bank for International Settlements (“BIS”) working paper, economist Luci Ellis concluded that “there is no evidence that the Community Reinvestment Act was responsible for encouraging the subprime lending boom and subsequent housing bust.”[56] Ellen Seidman, former director of the US Office of Thrift Supervision during the Clinton administration, who works at the New America Foundation,[57] has stated that the CRA did not have an effect on the United States housing bubble.[58][59][unreliable source?]

Some commentators note that CRA regulated loans tended to be safe and profitable, and that subprime excesses came mainly from institutions not regulated by the CRA. In the February 2008 House hearing, law professor Michael S. Barr, a Treasury Department official under President Clinton,[60][32] stated that a Federal Reserve survey showed that affected institutions considered CRA loans profitable and not overly risky. He noted that approximately 50% of the subprime loans were made by independent mortgage companies that were not regulated by the CRA. Another 25% to 30% came from only partially CRA regulated bank subsidiaries and affiliates. He stated that institutions fully regulated by CRA made “perhaps” one in four sub-prime loans. Referring to CRA and abuses in the subprime market, Michael Barr stated that in his judgment “the worst and most widespread abuses occurred in the institutions with the least federal oversight”. [61] According to Janet L. Yellen, President of the Federal Reserve Bank of San Francisco, independent mortgage companies made “high-priced loans” at more than twice the rate of the banks and thrifts; most CRA loans were responsibly made, and were not the higher-priced loans that have contributed to the current crisis.[62] A 2008 study by Traiger & Hinckley LLP, a law firm that counsels financial institutions on CRA compliance, found that CRA regulated institutions were less likely to make subprime loans, and when they did the interest rates were lower. CRA banks were also half as likely to resell the loans.[63]

Assistant Professor of Law Alan M. White[64] notes that some abuses blamed on CRA actually occurred under the George W. Bush administration, because the Housing and Urban Development and Office of Federal Housing Enterprise Oversight allowed Fannie Mae and Freddie Mac to fulfill their affordable housing goals – which are not technically part of the CRA – by buying subprime mortgage-backed securities.[65]

[edit] References

  1. ^ Text of Housing and Community Development Act of 1977—title Viii (Community Reinvestment).
  2. ^ a b c dCommunity Reinvestment Act“. Federal Reserve. Retrieved on 200810-05.
  3. ^ Avery, Robert B.; Raphael W. Bostic, Glenn B. Canner (November, 2000). “The Performance and Profitability of CRA-Related Lending“. Economic Commentary. Federal Reserve Bank of Cleveland. Retrieved on 200810-05.
  4. ^ a b c d Thompson, Sandra L (2008-2-13). “Statement of Sandra L. Thompson, Director, Division of Supervision and Consumer Protection“. FDIC. Retrieved on 200810-05.
  5. ^ Text of Housing and Community Development Act of 1977—title Viii (Community Reinvestment).
  6. ^ a b cThe Community Reinvestment Act“. Federal Reserve Bank of St. Louis. Retrieved on 200810-06.
  7. ^ a b c d e f g h i j k Ben S. Bernanke, Chair of Federal Reserve System, The Community Reinvestment Act: Its Evolution and New Challenges, speech at the Community Affairs Research Conference, Washington, D.C., Federal Reserve System website, March 30, 2007.
  8. ^Community Reinvestment Act: Background & Purpose“. FFIEC. Retrieved on 200810-06.
  9. ^ CRA Statute
  10. ^ FFIEC INTERAGENCY CRA RATING SEARCH
  11. ^ a b cWhite House Press Briefing, December 8 1993“. The White House.
  12. ^ Schwartz, A., From confrontation to collaboration? Banks, community groups, and the implementation of community reinvestment agreements, Fannie Mae, 3, pp. 631-662, 1998.
  13. ^ a b c d e f g h Sandra F. Braunstein, Director, Division of Consumer and Community Affairs, The Community Reinvestment Act, Testimony Before the Committee on Financial Services, U.S. House of Representatives, 13 February 2008.
  14. ^ [Testimony of Ellen Seidman, Director, Financial Services and Education Project of New America Project before the United States House Committee on Financial Services, February 13, 2008.
  15. ^ [Testimony of Ellen Seidman, Director, Financial Services and Education Project of New America Project before the United States House Committee on Financial Services, February 13, 2008.
  16. ^ United States Commission on Civil Rights. 1961 U.S. Commission on Civil Rights Report 4. United States Commission on Civil Rights. Retrieved on 200810-06.
  17. ^ Schwartz, A., From confrontation to collaboration? Banks, community groups, and the implementation of community reinvestment agreements, Fannie Mae, 3, pp. 631-662, 1998.
  18. ^FIRST UNION CAPITAL MARKETS CORP., BEAR, STEARNS & CO. PRICE SECURITIES OFFERING BACKED BY AFFORDABLE MORTGAGES“. First Union Corporation (Wachovia).
  19. ^ Westhoff, Dale (1998-05-01). “Packaging CRA loans into securities.“. Mortgage Banking 29 (May 1998): 315. doi:10.1016/j.jhsb.2004.02.009.
  20. ^ Russell Roberts, “How Government Stoked the Mania”, Wall Street Journal, October 3, 2008].
  21. ^ Fannie Mae Announces Pilot to Purchase $2 Billion of “MyCommunityMortgage” Loans; Pilot Lenders to Customize Affordable Products For Low- and Moderate-Income Borrowers, Corporate Responsibility News, October 30, 2000.
  22. ^ Fannie Mae “MyCommunityMortgage” homepage.
  23. ^ Chairman Ben S. Bernanke, GSE Portfolios, Systemic Risk, and Affordable Housing, Speech before the Independent Community Bankers of America’s Annual Convention and Techworld, Honolulu, Hawaii (via satellite), March 6, 2007.
  24. ^ FDIC page on Riegle-neal Interstate Banking and Branching Efficiency Act of 1994, SEC. 109. 2 D
  25. ^Community Reinvestment Act (CRA) Fact Sheet“. EPA. Retrieved on 200810-06.
  26. ^ William A. Niskanen, Repeal the Community Reinvestment Act, Testimony of William A. Niskanen, Chairman Cato Institute before the Subcommittee on Financial Institutions and Consumer Credit, Committee on Banking and Financial Services United States Senate, March 8, 1995.
  27. ^ Canner, Glenn; Wayne Passmore (1997). “The Community Reinvestment Act and the profitability of mortgage-oriented banks“. Finance and Economics Discussion Series (1997-7). Board of Governors of the Federal Reserve System. Retrieved on 200810-01.
  28. ^The Community Reinvestment Act After Financial Modernization“. United States Department of the Treasury (April 2000, pgs 16-17).
  29. ^ Stephen Labaton, Issue in Depth: Leading Up to the Decision on Banking Reform, Washington Post, October 23, 1999.
  30. ^ Findlaw.com, attorneys describe the 1999 Gramm-Leach-Bliley “Financial Services Modernization Act”.
  31. ^ Financial Services Modernization Act, Community Reinvestment Act Amendments in the Gramm-Leach Act, United States Senate Committee on Banking, Housing, and Urban Affairs, 1999.
  32. ^ a b Statement by President Bill Clinton at the Signing of the Financial Modernization Bill, U.S. Treasury Department Office of Public Affairs, November 12, 1999.
  33. ^ Apgar, William C.; Mark Duda (June 2003). “The Twenty-Fifth Anniversary of the Community Reinvestment Act: Past Accomplishments and Future Regulatory Challenges“. FRBNY Economic Policy Review (June 2003). Federal Reserve Bank of New York.
  34. ^ Press release and letter released by a contingent of “House Democrats”, April 13, 2005.
  35. ^ a b FDIC Financial Institution Letters: Community Reinvestment Act Interagency Examination Procedures, April 10, 2006
  36. ^ The Community Reinvestment Act: Thirty Years of Accomplishments, but Challenges Remain, United States House Committee on Financial Services, February 13, 2008.
  37. ^ [http://www.fdic.gov/news/news/speeches/chairman/spapr1508.html Statement of Robert W. Mooney, Deputy Director, Division of Supervision and Consumer Protection, Federal Deposit Insurance Corporation on Financial Literacy and Education: The Effectiveness of Governmental and Private Sector Initiatives before the United States House Committee on Financial Services, April 15, 2008.
  38. ^ Jeffrey W. Gunther, Should CRA Stand for “Community Redundancy Act”?, Cato Institute’s “Regulation Magazine”, Fall 2000.
  39. ^ Jeffery W. Gunther, Kelly Klemme, and Kenneth J. Robinson, “Redlining or Red Herring?”, Federal Reserve Bank of Dallas, “Southwest Economy, May/June 1999: 8.