What you cite is the fact that second-order effects allowed abuse.
Look up the activities of ACORN. Not just what they say or what they are accused of, but what they actually do. If the CRA is not intended to work as I described, they sure did manage to turn it that way.
"Always get the data on your own kid."
Fuck off with your slur.
For data on default rates see http://www.huduser.org/publications/affhsg/FHASingleFamily.h...
For data on CRA dollars committed see http://www.community-wealth.org/_pdfs/articles-publications/... (4.2 TRILLION between '92 and '05)
<<"The problem is that if you don't lend enough money to minorities (who disproportionately can't afford it), the federal bank regulators can block you from acquiring/being acquired by other banks.">>
I'm confused as to which part of the act you are speaking about. Perhaps you could post the link to the relevant statute, and we can discuss this based on the data.
Regarding the links you provided, again, what is the relative default rate? This is the key piece of data we need. Even better, would be the absolute amounts of money that were defaulted on. That said, I would observe that it is interesting, wouldn't you say, that default rates on FHA HUD loans should be so public, and default rates on the Fannie and Freddy backed stuff so closed. Even more interesting that, as I said in response to your other post, Ginnie Mae should still be solvent considering Fannie and Freddy are basket cases.
Finally, I am uncertain as to how the links you provided support the assertion that CRA precludes banks who don't lend to minorities from acquiring or being acquired. If you would elaborate on the connection I could determine better whether or not I agree with you.
From the NCRC pdf linked above, "Since the passage of CRA in 1977, lenders and community organizations have signed over 428 CRA agreements totaling more than $4.2 trillion in reinvestment dollars flowing to minority and lower income neighborhoods."
From the CRA (http://www.fdic.gov/regulations/laws/rules/6500-2515.html)
802.a.1 - `"regulated financial institutions are required by law to demonstrate that their deposit facilities serve the convenience and needs of the communities in which they are chartered to do business;"`
803.3 - `the term "application for a deposit facility" means an application to the appropriate Federal financial supervisory agency otherwise required under Federal law or regulations thereunder for--`
803.3.E `the merger or consolidation with, or the acquisition of the assets, or the assumption of the liabilities of a regulated financial institution requiring approval`
804.a `SEC. 804. (a) IN GENERAL.--In connection with its examination of a financial institution, the appropriate Federal financial supervisory agency shall-- (1) assess the institution's record of meeting the credit needs of its entire community, including low- and moderate-income neighborhoods, consistent with the safe and sound operation of such institution; and (2) take such record into account in its evaluation of an application for a deposit facility by such institution.`
See also this WSJ article (entered into the Senate record) http://thomas.loc.gov/cgi-bin/query/R?r106:FLD001:S05028
"Last week the Senate passed a bill over-hauling the regulation of banks, including a provision sponsored by Sen. Phil Gramm (R., Texas), chairman of the Banking Committee, to reform the Community Reinvestment Act. Mr. Gramm's provision has stirred controversy, to say the least. Last month hundreds of ``community activists'' descended on his house, where they pounded on the windows, trampled the landscaping and left the yard covered with garbage."
"The 20-year-old CRA requires banks to serve their entire community. Regulators take banks' CRA compliance into account when deciding whether to approve applications for mergers or expanded services. In the recent wave of bank consolidation, banks have made billions of dollars of loan commitments and signed agreements with numerous community organizations in order to be seen as complying with CRA."
So you have submitted a set of clauses that say that banks must lend to economically disadvantaged neighborhoods. The clauses you reference do not say that banks must lend to economically disadvantaged people. This is my material point, and the pivot on which the majority of urban redevelopment turns.
Just as an aside, lending encompasses more than just mortgages. For example, I can also qualify for a lot of CRA, or TIF type help if I construct . . . say . . . a small business incubator in one of these economically disadvantaged neighborhoods. The only reason I say that is because I am starting to get the feeling that you believe the entire USD4.2 Trillion was given on mortgage loans for minorities.
Minorities could not walk into a bank and get a mortgage because they were a minority. That is patently false. However, in my neck of the woods, Atlanta, GA (in Fulton County one of the 35 worst), money was made by developers who "invested" in low income areas.
Areas like the West End and Lakewood saw tons of development during the real estate boom, and then developers disappeared, after they removed the equity from these homes. There are now streets in these neighborhoods where the average price of a home sold is under $35,000, but the foreclosed properties are listed at more than $300K.
@bilbo0s, I would LOVE to talk to you. I'm doing a foreclosure bus tour in a month, and I would love to be able to explain the CRA situation as eloquently as you did on this forum. You can email me at broderick at sktrealty dot com.
In this case however, I think I may have hit a nerve here, and that was not my intention. People seem to be getting really angry, so I thought it was best for me to stop commenting.
I'm out of real estate investing now, and currently do tech investing stuff. Mostly gaming like everyone else it seems, but it is keeping me very busy. I do wish you luck with the endeavor though.
Thanks again guys, it is good to know that there are at least a few people I did not offend.
It colors my thinking when I read something like this, talking about a $750 billion pledge for community development - http://www.housingfinance.com/ahf/articles/2004/March/Bank_m...
Or how about Phil Gramm speaking at the American Enterprise Institute (http://www.aei.org/events/eventID.1862,filter.all/transcript...): "We ended up when the bubble finally broke with three different quotas. One quota was for below-average-income borrowers and that was a requirement that 56 percent of the loans bought by Freddie and Fannie had to conform to that guideline. The second quota had to do with the low-income individuals. These were individuals with 60 percent of the income of the census tract in which they lived, and by the time the bubble broke, that quota was 27 percent of all mortgages held by Freddie and Fannie had to fit within that quota. And the final quota that was set in proportional terms was geographically targeted principally at inner cities and depressed areas, and that was a quota that said 35 percent of all the loans held by Freddie and Fannie or purchased by them had to fall into that category."
Then there's Countrywide (not a bank and hence not covered by CRA), which originated something like 20% of America's subprime mortgages (Countrywide did not hold on to these mortgages but sold them to banks). Here's a great 2007 NYTimes article about their wonderful lending practices: http://www.nytimes.com/2007/08/26/business/yourmoney/26count... And a great presentation at Harvard by their CEO talking about the 600 billion he's pledging for "previously underserved Americans" - http://www.jchs.harvard.edu/publications/homeownership/M03-1...
If you check the CRA what you will discover is that it is intended to increase lending in 'disadvantaged communities'. That's right, the loans are based on neighborhood, not individual disadvantages. For instance, an impoverished person from inner city Chicago finds a great deal on a house in Evanston, a suburb. CRA does NOT cover this situation, as you imply, because Evanston is not a 'disadvantaged community'. Same guy wants to buy a house in inner city Chicago and CRA DOES cover his situation.
That's where the fun starts!
It's at that point that people like me were helping large development firms come in and buy up property in the 'disadvantaged communities'. You keep just enough poor people to keep the disadvantaged designation and you build condos that sell like hot cakes. Usually you set aside a few units in every building for 'disadvantaged' people to buy. But here's the beauty of it. Most municipalities classify 'economically disadvantaged' as 'at or below the median income' for that municipality.
By way of example, in Madison, WI, at the time, I believe it was $50000 per year that made you 'economically disadvantaged'. Make below $50000 per year, and you would qualify for one of the set aside units. The developer still made a killing, the cities looked like they were helping regular folks, and crime in the downtown areas dropped dramatically.
Of course, now we see the mortgage crisis and the unintended consequences, but it all seemed like a good idea at the time. And parts of it were a good idea.
Now, I don't know who explained CRA to you. But I can tell you unequivocally that for developers tools like this were VITAL. TIF as well. Downtown redevelopment rarely works without them.
IF it is the case that politicians wanted to help these people, then they should have written the law so that it centered on the people and not the neighborhoods. My own opinion is that the real estate development industry probably lobbied hard to have CRA center on the idea of disadvantaged neighborhood. Because the whole thing was just too easy to not have been planned.
In summary, take my word for it, I am VERY well versed with urban real estate development. CRA was not, indeed cannot, be used in the fashion you intimate. If someone told you that CRA obliged a bank to loan to people who could not afford it, then I'm afraid you've been misinformed. CRA obliges banks to lend in NEIGHBORHOODS that are disadvantaged.
It is not by accident that many luxury condo developments are in formerly sketch areas. Nor is it a happenstance that the 'downtown condo' rose to prominence with the expansion of CRA. Go to any major city in the US and find a long time resident to walk around downtown with you. The story s/he will tell you will go something like this:
"Boy, I can remember when this was a really dangerous area. But they really have fixed it up haven't they! When my kid goes off to college, we're thinking of moving down here!"
And finally, as always, don't take my word for it. That was your mistake before, when you took the word of someone else that CRA obliged banks to lend to people who could not afford it. What I would encourage you to do is read through the act your self. Start here, http://www.ffiec.gov/cra/. You will see that 'communities' and 'neighborhoods' are the units of interest.
Always get the data on your own kid. There are a lot of people out there trying to manipulate right now. Left wing socialists, right wing corporatists. Trust no one! Go read it for yourself.