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Making Loan Mods Work

November 29, 2009

The New York Times this weekend reported that the Obama Administration is likely to announce new measures to help beleaguered homeowners stave off foreclosure. Although more than 600,000 owners are in trial modifications under the Making Home Affordable program announced last March, only a few thousand have received final modifications. Trial periods that were meant to last 3 months have been extended to 5 as a result. The performance of servicers varies widely among the 35 who signed up with the Treasury to use the program with the borrowers in their portfolios. Advocates for homeowners and Congress are frustrated with the slow pace and urging more action.

It’s unclear what new measures the Administration might take.  But the weekend’s report comes on the heel of another Times report describing how hedge funds and other investors are profiting from the ongoing crisis by buying distressed mortgages at a discount, refinancing them at a much lower principal amount made possible by their discounted purchase and splitting the difference with current borrowers.  The article details how Fortress Investment Group - ironically headed by former Fannie Mae CEO Daniel H. Mudd -  and other investors are managing to reduce borrower principal by significant amounts while still turning a profit.  There are only limited opportunities to reduce principal under Making Home Affordable; the interest reduction approach that is its chief tool can lower monthly payments but does nothing to reduce the outstanding debt.

The investors’ scheme is clever.  The Obama Administration was advised to follow a similar course in February, 2009, in a policy paper prepared for HUD Secretary Shaun S. Donovan under the auspices of the University of Pennsylvania’s Institute for Urban Research.  Bart Harvey and I co-lead the task force that produced the paper.  We urged the government to buy distressed mortgages directly at a steep discount and then centrally organize the restructuring or dissolution of these debts.  We argued that this would accelerate the process and allow the government to organize effective modifications designed for long-term stability.

But the Making Home Affordable plan instead relies on incentive payments to existing servicers to encourage them to effectively re-underwrite the loans.  It relies on a calculation of “net present value” of the current home that is not transparent and does not seem to adequately account for differences in current values within and between metropolitan areas.  It relies on 35 different servicers all designing new systems for accepting applications, reviewing them, tracking them, and evaluating them.  This has meant hiring thousands of processors who must be trained, and building technology systems that take time and money to design and execute.

Since its inception borrowers have had to put up with faxed applications, frequently lost documents and resubmissions, and opaque decisions.  Some owners even have found themselves facing foreclosure evictions while awaiting approval of their applications or while in trial modifications.  This is either because the servicers’ systems aren’t robust enough to connect the foreclosure and modification operations effectively or servicers stand to earn more through continuing foreclosures even though it is prohibited in their contracts under Making Home Affordable.  Whatever the reasons for these frustrations and failures, the result is anxiety for homeowners and failure to deliver on the program’s promise.

Despite the obstacles and start up delays, Treasury reports show that more than 600,000 trial modifications have been put in place.  Treasury Assistant Secretary Herbert M. Allison told a group of advocates last week that the pace of permanent modifications is lagging way behind expectations.  The department’s focus over the next six weeks will be on moving those numbers up, he said.  But he also reminded the group that servicers entered into the program voluntarily, and the government has only limited options to force action.

Meanwhile, the private investment schemes may end up leaving the government holding the bag in the end anyway, because virtually all new mortgage lending today is backed one way or another by Uncle Sam.  FHA today is the only route for low downpayment borrowers.  If the same borrowers get into trouble on their new loans, it will be FHA that has to pay off the lender and will be stuck with the loans.  If the borrowers have the scratch for a larger downpayment, their loans are likely to be bundled into securities by Fannie Mae and Freddie Mac, and the bonds purchased by the Fed.  If they go bad, taxpayers could end up footing at least part of the bill.

It would have been much simpler and more direct for the government to move aggressively to purchase distressed loans at steep discounts earlier this year.  It could have contracted for the servicing workouts under closer supervision.  It could have offered lenient terms to forestall foreclosures and the havoc they are wreaking in communities.  Making Home Affordable was an important step forward, but its limitations are becoming clearer with time.  The new initiatives anticipated on Monday (November 30, 2009) hopefully will accelerate success.

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Remembering Jack Kemp

August 03, 2009

Jack Kemp

In 1989, when I was President of the National Low Income Housing Coalition, I had the privilege to chair the national steering committee for Housing Now!, a mass mobilization on behalf of the homeless created and driven by the late Mitch Snyder.  Months of grassroots organizing cuminated in a two day program of meeting and demonstrations climaxing on October 7 with a huge rally on the National Mall.  Crowd estimates ranged as high as 250,000 and more.

The day before the rally, I led a group of participants to a meeting at HUD.  The decision to seek a meeting was controversial; one steering committee likened it to “Captain Ahab asking for a meeting with Moby Dick.”  But we did request a meeting with HUD Secretary Jack Kemp, and he agreed.

The HUD building was surrounded by police in riot gear.  It was ringed with security barriers and checkpoints.  I don’t know what they were expecting, but they were prepared for the worst.  My little group included some homeless advocates whose plans for the day included possibly occupying the HUD building.  Before we entered the building we huddled and got everyone to agree to leave when our meeting was over, but this illustrated the mood folks were in.  Homelessness had become a flashpoint issue in the Bush I presidency.  Snyder had skillfully enlisted media, entertainment figures, and politicos in support of his cause and Housing Now!  Hurricane Hugo had ripped through some of the convoys of homeless people walking and riding to the demonstration.  Folks were not in a forgiving mood.

We’d been scheduled for a half-hour.  We were escorted up to the tenth floor of HUD to the Secretary’s office.  The staff was keeping a close eye on us.  Our group included folks who had spent most of their recent nights sleeping in shelters or in the streets.  It was not your typical HUD visit.

When we arrived in his conference room, Jack Kemp got up and walked over to each of us, stuck out his hand and in his unmistakable gravelly voice said “Hi, my name is Jack Kemp, welcome to HUD.”  The Assistant Secretaries for Housing and for Community Planning and Development were there.  But it was clear from the start that Kemp was the star of HUD’s team.  He asked each of our group to tell him about themselves.  He engaged each of them in conversation about their lives, why they were homeless, and the reasons they had come.  He told them he thought homelessness was unacceptable and that he was committed to finding solutions. Our 30-minute meeting was turning into something much longer.  Staff came to the conference room and tried to signal Kemp that it was time to wrap it up.  He wasn’t interested.  “It’s getting late,” he observed, “and these people must be getting hungry.  Can I get you all some lunch?”  And sandwiches were delivered from the HUD cafeteria.

Before we were done,  2 hours or so after we’d arrived, the most hardened advocates in the group were engaged in deep conversations with Kemp, who treated each of them like a human being and showed them respect and consideration.  Our objective was to get a statement from Kemp supporting Housing Now!‘s demands.  None of the advocates expected to leave with anything but another club to beat the Bush Administration with.  Kemp first responded that “you can take my word…I’m going to do everything I can.”  He even turned to me, and said, “Zigas, you know me, tell them that my word is good.”  For some reason, he always called me Zigas, and in later years I took to calling him “Kemp.”  I demurred and said we were representing a lot of folks, and this group needed to come back with something tangible.  Kemp thought a minute, then said “you and Austin (Fitts, AS for Housing) and Anna (Kondratis, AS for Community Development) go off and draft something up.”  We did, while he remained with the others, telling and listening to stories.

I don’t know who was more reluctant to leave that conference room, Kemp or the homeless folks.  When we emerged on the plaza in front of HUD and read out Kemp’s letter, the assembled crowd was first stunned, then jubilant.

So I was saddened to hear of Jack Kemp’s death from cancer earlier this summer.  We had opportunities to meet and work together through the rest of his tenure, and after.  I didn’t agree with a lot of his views, and I thought he failed to make the kind of difference he aspired to while HUD Secretary.  He was marginalized by the President and Cabinet.  But I never got over his immediate ability to connect with those homeless people.  Or his vocal and energetic commitment to racial equality and a better life for all people.  We disagreed over the means, but not the end.

American politics have become so poisoned by unrelenting partisanship that it’s hard to remember when Republican Jack Kemp welcomed incoming Democrat Henry C. Cisneros to the HUD building in 1993.  He presented him with a bust of Lincoln in front of a town hall meeting of HUD employees, praising his background and credentials, and urging HUD employees to help him succeed.  Kemp and Cisneros teamed up then and later on a series of efforts, and Kemp stood out more and more as time went on and his party colleagues veered further and further from his generous stance.

I’ll miss his gravelly voice, his sometimes off-beat views on gold and other things.  But most of all I’ll miss how he represented many of the best qualities of a politician who came to Washington to serve.

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It Ain’t Necessarily So

August 03, 2009

In a recent Washington Post interview, Freddie Mac Chairman John Koskinen regrettably implied that the affordable housing goals that Fannie Mae and Freddie Mac were required by HUD to meet were a cause of the two companies’ financial troubles.  Responding to a question about how a revised model for the secondary market might better balance public purpose mission goals with duties to shareholders, Koskinen replied,

I’ve never thought that those were inconsistent goals or impossible to manage. The problem in the past was the increased requests for expanded affordable housing were made by the administration. No one ever balanced out exactly what that was going to cost.

One of the most significant things that’s happened is the setting of the affordable housing goals has now been moved to our regulator. So the regulator responsible for looking at safety and soundness is also the one looking at setting the housing goals, and therefore will be able to look at what the costs and risks are of expanding support for affordable home ownership in the context of running a for-profit corporation.

I agree that combining mission and safety and soundness regulation in one place is an improvement over the two regulator model that started in 1992.  And I agree that HUD set the goals in 2004 at unrealistically high levels.  But the implication that meeting them required jeopardizing the company’s safety and soundness is hooey.  If anything, the record shows that both companies succumbed to market pressures and fears of becoming irrelevant as unregulated mortgage lending surged in the mid-2000’s and sacrificed their most important mission imperatives in the market scramble that followed.

Freddie Mac especially did pursue a strategy of buying subprime mortgage bonds as a significant contributor to meeting its housing goals performance.  And it’s true that these bonds have cratered in value, causing some of the company’s losses.  But that was a business choice that Freddie Mac made in deciding how to fulfill the housing goals madate.  HUD’s report on the GSEs’ housing goals performance in 2004-2005 concludes that while no more than 72 percent of Freddie’s low mod home purchase loans were from “traditional sources” during those years, more than 90 percent of Fannie Mae’s were.  Freddie’s subprime bond purchases had much higher percentages of goals qualifying home purchase loans than their purchases from traditional sources (60.8 percent low mod in the securities vs. 40 percent in their traditional business.) This may have exacerbated their financial peril.  But they did not have to invest heavily in bonds backed by loans focused on weak credit borrowers, as Fannie’s alternative strategy shows.  Moreover, any analysis of the two companies’ financial reports since they melted down shows clearly that the immense portfolios of Alt-A loans they acquired from 2006 until the market imploded in 2008 have been the big drivers of their credit losses.  I analyzed these numbers in an earlier blog.  They haven’t changed significantly since then.

These Alt-A loans were typically made to borrowers with very good credit ratings and relatively high down payments.  They were not tailored to low mod borrowers, or to underserved communities.  Sometimes they met those goals, but on the whole they were not positive contributors to the GSEs’ housing goals scores.

Both companies pursued these risky and ultimately costly loans because they were afraid of giving up market share and profits.  They were both late to the market, and once in, stayed too long.  They wound up with big investments in loans that were the first to fail, and failed with bigger losses than their traditional books of business.  When loans that make up only about 10-15 percent of your total credit exposure account for nearly 50 percent of your credit losses, something is very, very wrong.

This isn’t just my view.  James B. Lockhart, Director of the Federal Housing Finance Agency (FHFA) said as much in a major speech last week at the National Press Club.

Neither Fannie, Freddie, nor FHFA has published any useful data about the performance of the loans that met their housing goals.  They also have not provided any useful information on the performance of their specialized loan products like My Community Mortgage ©, Community Home Buyers©, or Affordable Gold© that offered flexibilities to borrowers that met HUD’s housing goals.  Thus, it’s not possible to compare their performance with Alt-A or other loans.  Given the collapse in home prices across the country, the lower down payments and credit quality requirements of these products, they likely are suffering higher loss incidences than in the past.  With relatively smaller loan balances, they also likely are suffering lower loss severities than Alt-A loans that were more concentrated in high cost areas.  Evidence from the small sample of loans analyzed by UNC’s Center for Community Capital of the Community Advantage© loans packaged by Self Help for Fannie Mae suggests these specialized loans to goals-qualifying borrowers are not driving Fannie Mae’s losses, although they undoubtedly are contributing to them.

The deeper failure by both companies was their substitution of a broad view of their mission to provide stability in the marketplace for a narrow view that their mission obligations started and ended with meeting the housing goals.  They should have run their businesses from the foundational assumption that they were chartered to provide a more fundamental and long-view role in the market than the latter day buccanners from Wall Street who flooded the market with high risk mortgages.  Instead, they saw them as their direct competitors and tried to “bring it to them” by conmpeting for loans that were way outside of their own sweet spot.  This short term focus on market share and profits led them far astray from their core business and they—and taxpayers—are paying the price for that error.

Both Fannie Mae and Freddie Mac had multiple levers they could use to assure that their businesses produced results consistent with the mandated housing goals. In 2006, Fannie Mae did modify its automated underwriting engine to secure loans with overall weaker profiles, and this did boost its success in acquiring goals qualifying loans.  This probably has led to higher losses in these loans.  But in addition, after 2004, both could have chosen to moderate their financing of loans that were newly accessible through higher loan limits, for instance.  These higher balance loans seldom met any of the housing goals, and provided liquidity in markets where there was little evidence it was needed.  Similarly, a less aggressive push to compete with Wall Street firms by vacuuming up Alt-A loans at the top of the market would have helped both of them reach the HUD goals more easily and kept them truer to their chartered purpose.  But neither was willing to temper their overall business to meet the housing goals.  Instead, they chose to chase market share and revenue in competition with private label securitizers, who by then were neck deep in dangerous, unstable loans.

Koskinen may be right about the housing goals costing too much and contributing to Freddie Mac’s failure.  But he owes the public, Congress and his regulator a much better explanation of why this is so than has been offered so far.

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Chinatown

October 12, 2008

Evelyn Mulwray

In a climactic scene of 1974's noir classic "Chinatown,"  Jack Nicholson's character LA private eye Jake Gittes is confronting Faye Dunaway's character Evelyn Cross Mulwray.  Gittes demands that Mulwray explain the identity of the little girl she is trying to spirit out of town. 

"She's my daughter," Mulwray says.  Gittes slaps her hard.

She's my sister," Mulwray says, and Gittes slaps her again.

"She's my daughter."  Slap.  "She's my sister."  Slap.

And so on.  The horrible truth is that the girl is Mulwray's daughter and her sister through an incestuous relationship with her father.  It's the capstone image of the cesspool of corruption into which Gittes has fallen while investigating water deals in post-war Los Angeles.

My Sister

This is the image that's been running through my mind this week.   Fannie Mae's and Freddie Mac's new regulator announced that while both companies were adequately capitalized, they were not adequately capitalized and anyway, from now on FHFA won't worry about whether they're adequately capitalized or not.   According to the October 10, 2008 Washington Post,

"Fannie Mae and Freddie Mac had said at the end of June that they had billions of dollars more of a financial cushion than required by their regulator. The report by the Federal Housing Finance Agency yesterday reaffirmed that, saying Fannie Mae had $9.4 billion and Freddie Mac had $2.7 billion more capital than required.
"But, even though the companies were adequately capitalized, the regulator yesterday declared them undercapitalized.  How did it square that circle?
"The regulator, in essence, said capital wasn't a good enough barometer of the companies' financial footing. The law gives the regulator the authority to designate the companies undercapitalized even if they technically have enough capital. In its report, the FHFA said that the sharp downturn in the mortgage market over the summer ‘raised significant questions about the sufficiency of capital.'
"...Usually, being declared undercapitalized would subject the companies to modest penalties, but none will be exacted while they are under government control. The FHFA also has suspended the capital requirements, though the companies will continue to disclose capital figures in their quarterly reports. The government set up a program to lend money or inject capital if the companies falter. "

Note that although the conservatorship came with authority to inject up to $200 billion into the two companies to shore up their capital, to date not one dollar has been invested.  The companies continue to operate much as they did before the takeover, without any taxpayer money so far being spent.

That could change in a hurry, though, because FHFA also announced this week that it is wrenching them back into the portfolio lending business.  But this time, the regulator wants to make sure they buy junk.

My Daughter

Earlier this year FHFA Director James Lockhart said repeatedly that Fannie and Freddie's portfolios were not needed to help stabilize the markets or carry out their mission.  Both companies, he said, had ample opportunity to guarantee securities backed by mortgages and let other investors buy them.  GSE bashers from all sides opined that their portfolios were a prime source of the credit crisis, that they were unnecessary vestiges of a bygone era, and had permitted the two companies to borrow huge amounts at discounted rates to re-invest it to buy mortgage securities in a market that didn't need them.

Since then, Fannie and Freddie have been practically the only source of capital in the mortgage markets.  When Freddie announced it had shrunk its portfolio by more than $30 billion last month, shivers went through the markets because of the sudden prospect of even less liquidity for mortgage debt.

Secretary Hank Paulson said that they would increase their portfolios by a modest amount over the next 18 months when the US Treasury and FHFA forced the two companies into conservatorship in September.  After that, he expected them to be reduced over 10 years to around $250 billion each.  They are both presently at a about $760 billion.  At the time, I wrote that "The announced intention to force the companies' portfolios into an annual 10 percent reduction to $250B each begs the question of what sources will make up this difference, or why it is sensible, wise or necessary prior to determining the best future course for the system."

Now this week, Bloomberg's Dawn Kopecki reports that

"Federal regulators directed Fannie Mae and Freddie Mac to start purchasing $40 billion a month of underperforming mortgage bonds as the Bush administration expands its options to buy troubled financial assets and resuscitate the U.S. economy, according to three people briefed about the plan.
"Fannie and Freddie began notifying bond traders last week that each company needs to buy $20 billion a month in mostly subprime, Alt-A and non-performing prime mortgage securities, according to the people, who asked not to be identified because the plans are confidential. The purchases would be separate from the U.S. Treasury's $700 billion Troubled Asset Relief Program."

Now that the government owns them, it seems that their portfolios are not only useful tools in a credit-starved marketplace.  They are  handy tools to purchase junk. 

Some folks who ought to know tell me on Monday, October 13, 2008, that this report is unfounded.  I hope so.  But so far there has been no retraction on Bloomberg and no disclaimer from FHFA, Treasury or anywhere else that I could find.  If it's not true, someone please stand up and say so!

This news comes at the same time the Treasury is reported to be reconsidering the $700 Troubled Asset Recovery Program (TARP) it just got Congress to approve.  Treasury apparently won't be haggling with Wall Street banks and others holding this toxic crap to force a cramdown.  Instead, it seems that Treasury will buy shares in banks and Fannie and Freddie will lighten their debt load using their now-government guaranteed portfolios.

It's Chinatown, Jake

So, to recap: 

During most of 2007-08, Director Lockhart used his authority under settlement agreements with both companies to limit their portfolio growth through requiring both to hold penalty levels of capital.

When Congress pushed to allow their portfolios to expand, Lockhart and others responded that they could issue mortgage backed securities instead.

In September, Lockhart triggers new conservatorship powers asserting that they are in danger of being undercapitalized.

A month later Lockhart acknowledges that they actually both have sufficient capital according to the standards laid out in law and administered by Lockhart himself.  But he announces these measures are actually no good, so the companies had to be taken over anyway.  Lockhart questions whether certain assets claimed by the companies are really valid.  Although the companies are using the same generally acceptable accounting principles (GAAP) that everyone else does to value these assets, Lockhart decides these may not be good enough to rely on.  Footnote here:  can you remember what happened the last time someone suggested that GAAP accounting rules weren't being followed at the GSEs?  Can you say, "fired?"

In October, without having spent any of the funds set aside to shore up the two companies, Lockhart apparently has decided that both should dive back into the portfolio lending business big time, and start making a market for bad mortgage assets stuck on others' books. 

No wonder Fannie and Freddie must feel like poor Evelyn Mulwray.  Slapped this way, slapped that way.  What's a girl to do?

But as the man in the movie says, "forget it, Jake, it's Chinatown."

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Blame Game

October 09, 2008

The ongoing economic calamity has brought out plenty of bad attitude.  But it's hard to top this rubbish from Ann Coulter's blog with the subtle title, They Gave Your Money to a Less Qualified Minority:


"This crisis was caused by political correctness being forced on the mortgage lending industry in the Clinton era. "Before the Democrats' affirmative action lending policies became an embarrassment, the Los Angeles Times reported that, starting in 1992, a majority-Democratic Congress "mandated that Fannie and Freddie increase their purchases of mortgages for low-income and medium-income borrowers. Operating under that requirement, Fannie Mae, in particular, has been aggressive and creative in stimulating minority gains. "Under  Clinton, the entire federal government put massive pressure on banks to grant more mortgages to the poor and minorities. Clinton's secretary of Housing and Urban Development, Andrew Cuomo, investigated Fannie Mae for racial discrimination and proposed that 50 percent of Fannie Mae's and Freddie Mac's portfolio be made up of loans to low- to moderate-income borrowers by the year 2001... "Now, at a cost of hundreds of billions of dollars, middle-class taxpayers are going to be forced to bail out the Democrats' two most important constituent groups: rich Wall Street bankers and welfare recipients. "Political correctness had already ruined education, sportsscience and entertainment. But it took a Democratic president with a Democratic congress for political correctness to wreck the financial industry."

It's hard to imagine a baser, more racist approach to this crisis.  Never mind that minority homebuyers and the neighborhoods where they live are among the biggest victims in this mess.  Never mind that the Congress was firmly in Republican hands for much of the last 8 years, and that the Bush Administration has had control over the regulatory agencies for all of them.  In Coulter's world, Democrats and their handmaidens led the economy over the cliff by diverting "your" money to "those people."  Willie Horton, phone home.

There has been a steady chant across the conservative blogosphere blaming everything from CRA to Fannie Mae and Freddie Mae to low income and minority borrowers for the current crisis.  Apparently any participant in the market will do for these critics except the real culprits - unregulated, fee-crazed brokers, Wall Street securitizers, and the mortgage bankers who facilitated the transfer of the latter's money into the former's hands.  Why aren't we hearing about Ameriquest, Option One, New Century and all the other lenders who had to settle with various state attorneys general over their abusive lending practices before vanishing in a mushroom cloud of exploding subprime mortgages?

Why don't so-called conservatives focus on the real abuses in the originations market that ballooned into a repayment crisis?  Like:

  • Loans where you don't have to state your income?
  • Loans where you can't possibly qualify for the rate in Year 3, after the first two years' teaser rates vanish?
  • Loans for homes sold like loans for cars, as in "how much could you pay a month for this house? Okay, I can do that for you."
  • Loans with prepayment penalties that make it nearly impossible to refinance the loan if needed?
  • Loans that look like they have 20 percent down payments where there actually are other, even more expensive loans added on top to cover this?

Coulter, like many other conservative commentators, blithely ignores how bipartisan the push to increase homeownership was.  Increasing minority homeownership was a priority for the Clinton HUD.  And it also was one of the cornerstones of President Bush's "Ownership Society."  The housing goals Coulter references were hiked much higher by the Bush Administration in 2004 than in 2000. 

I happen to think that the broad intent of the efforts to increase minority and low-mod participation in homeownership was laudable.  Others may disagree. But it's absurd and misleading to assert, as Coulter does, that it was a partisan issue in the first place. 

She's also wrong about regulation.  Subprime lenders were not responding to regulatory pressure.  They weren't subject to any.  They were almost entirely outside of the banking regulatory structure.  Some of their business came from borrowers who could have qualified for much better terms with a prime, conventional mortgage.  But brokers could make a lot more in fees by selling subprime products.  So that's what they sold.  As house prices continued to escalate, these lenders began adding more and more layers of risk to qualify borrowers and keep their own paychecks coming.  Other borrowers were victimized by unscrupulous lenders who defrauded them and the investors who bought the mortgages. 

When states did try to impose regulatory constraints, subprime lenders fought back relentlessly.  When Congress considered a federal response, they did everything they could to stymie that, too.  Federal regulators belatedly imposed new guidance on banks in 2006, after many had acquired subprime subsidiaries or were themselves following the herd into these risky products to maintain market share. Among these new rules was a directive to lend only where there was a reasonable expectation that borrowers could repay the loan.  This seems like common sense.  But by then the bubble was almost fully inflated, and the damage had been done by lenders who had not followed that simple rule. 

There are plenty of good rebuttals to Coulter's and others' nonsense throughout the Web.  Here are some recommended samples:

The Big Picture

Ellen Seidman at New America Foundation

Business Week

David Abromowitz

Newsweek Online

McClatchy News Service

This cogent Atlantic Online piece documents the organized efforts by Republicans to try to pin this crisis on anyone but the Bush Administration. For a mordantly funny take on all this, download this cartoon.  It's a Word document, and will take a few moments to download.  But it's worth it.

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