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EconomicLetter

Vol. 2, No. 11
NOVEMBER 2007­­

Insights from the


F e d e r al R e s e r v e B a n k o f Dallas

The Rise and Fall of Subprime Mortgages


by Danielle DiMartino and John V. Duca

After booming the first half of this decade, U.S. housing activity has retrenched

Past behavior suggests sharply. Single-family building permits have plunged 52 percent and existing-home sales

that housing markets’ have declined 30 percent since their September 2005 peaks (Chart 1).

adjustment to more A rise in mortgage interest rates that began in the summer of 2005 contributed

realistic lending to the housing market’s initial weakness. By late 2006, though, some signs pointed to

standards is likely renewed stability. They proved short-lived as loan-quality problems sparked a tightening

to be prolonged. of credit standards on mortgages, particularly for newer and riskier products. As lenders

cut back, housing activity began to falter again in spring 2007, accompanied by addi-

tional rises in delinquencies and foreclosures. Late-summer financial-market turmoil

prompted further toughening of mortgage credit standards.

The recent boom-to-bust housing cycle raises important questions. Why did

it occur, and what role did subprime lending play? How is the retrenchment in lending
activity affecting housing markets, and which reflect the highest default risk skip payments by reducing equity or,
will it end soon? Is the housing slow- and warrant the highest interest rates. in some cases, obtain a mortgage that
down spilling over into the broader Near-prime mortgages, which are exceeded the home’s value.
economy? smaller than jumbos, are made to bor- These new practices opened
rowers who qualify for credit a notch the housing market to millions of
Rise of Nontraditional Mortgages above subprime but may not be able Americans, pushing the homeowner-
Monitoring housing today entails to fully document their income or pro- ship rate from 63.8 percent in 1994
tracking an array of mortgage prod- vide traditional down payments. Most to a record 69.2 percent in 2004.
ucts. In the past few years, a fast- mortgages in the near-prime category Although low interest rates bolstered
growing market seized upon such are securitized in so-called Alternative- homebuying early in the decade, the
arrangements as “option ARMs,” “no- A, or Alt-A, pools. expansion of nonprime mortgages
doc interest-onlys” and “zero-downs Some 80 percent of outstanding clearly played a role in the surge of
with a piggyback.” For our purposes, U.S. mortgages are prime, while 14 homeownership.
it’s sufficient to distinguish among percent are subprime and 6 percent Two crucial developments
prime, jumbo, subprime and near- fall into the near-prime category. spurred nonprime mortgages’ rapid
prime mortgages. These numbers, however, mask the growth. First, mortgage lenders adopt-
Prime mortgages are the tradi- explosive growth of nonprime mort- ed the credit-scoring techniques first
tional — and still most prevalent — type gages. Subprime and near-prime loans used in making subprime auto loans.
of loan. These go to borrowers with shot up from 9 percent of newly origi- With these tools, lenders could better
good credit, who make traditional nated securitized mortgages in 2001 to sort applicants by creditworthiness and
down payments and fully document 40 percent in 2006.1 offer them appropriately risk-based
their income. Jumbo loans are gener- The nonprime boom introduced loan rates.
ally of prime quality, but they exceed practices that made it easier to obtain By itself, credit scoring couldn’t
the $417,000 ceiling for mortgages loans. Some mortgages required have fostered the rapid growth of
that can be bought and guaranteed by little or no proof of income; others nonprime lending. Banks lack the
government-sponsored enterprises. needed little or no down payment. equity capital needed to hold large
Subprime mortgages are extended Homebuyers could take out a simulta- volumes of these risky loans in their
to applicants deemed the least credit- neous second, or piggyback, mortgage portfolios. And lenders of all types
worthy because of low credit scores at the time of purchase, make inter- couldn’t originate and then sell these
or uncertain income prospects, both of est-only payments for up to 15 years, loans to investors in the form of resi-
dential mortgage-backed securities,
or RMBS —at least not without added
protection against defaults.
The spread of new products offer-
Chart 1
ing default protection was the second
Housing Activity Drops Off crucial development that fostered sub-
prime lending growth. Traditionally,
Millions of units Millions of units
banks made prime mortgages funded
2 8 with deposits from savers. By the
Mortgage
rates start rising 1980s and 1990s, the need for deposits
1.8
had eased as mortgage lenders created
7
a new way for funds to flow from sav-
1.6
ers and investors to prime borrowers
through government-sponsored enter-
prises (GSEs) (Chart 2, upper panel).
1.4 6
Subprime Fannie Mae and Freddie Mac are
woes hit
the largest GSEs, with Ginnie Mae
1.2
Total existing-home sales Single-family being smaller. These enterprises guar-
building permits 5
antee the loans and pool large groups
1
of them into RMBS. They’re then sold
to investors, who receive a share of
.8 4
’00 ’01 ’02 ’03 ’04 ’05 ’06 ’07
the payments on the underlying mort-
SOURCES: National Association of Realtors; Census Bureau; authors’ calculations. gages. Because the GSEs are feder-
ally chartered, investors perceive an

EconomicLetter  Feder al Reserve Bank of Dallas


implicit government guarantee of them.
Fannie Mae and Freddie Mac, however,
haven’t packaged many nonprime Chart 2
mortgages into RMBS.
Lacking the same perceived status,
Mortgage Financial Flows
nonagency RMBS—those not issued by
Fannie Mae, Freddie Mac and Ginnie
Mae—faced the hurdle of paying
investors extremely large premiums to
1980s–90s Banks
compensate them for high default risk.
These high costs would have pushed

Pr tgag
m
nonprime interest rates to levels out-

im e
or

e s
s
sit
side the reach of targeted borrowers.

po
De
This is where financial innova-
tions came into play. Some — like col- Savers Prime
lateralized debt obligations (CDOs), and mortgage
a common RMBS derivative — were investors borrowers
designed to protect investors in
nonagency securities against default Bu MB
yG S

s
losses. Such CDOs divide the streams
R

mo rime
age
SE
of income that flow from the under-

rtg
P
lying mortgages into tranches that
Mortgage
absorb default losses according to a
originators
preset priority.
The lowest-rated tranche absorbs
the first defaults on the pool of
underlying mortgages, with succes-
sively higher ranked and rated tranches
absorbing any additional defaults. If .
2000–06 Banks
defaults turn out to be low, there may
be no losses for higher-ranked tranches
Pr tgag
m

im e
or

to absorb. But if defaults are much


e s
s
sit

greater than expected, even higher-


po
De

rated tranches may face losses.


Having confidence in the ability Savers Prime
of quantitative models to accurately and mortgage
measure nonprime default risk, a brisk investors borrowers
Bu MB

market emerged for securities backed


yG S
R

SE

by nonprime loans. The combination of


s
mo rime
no RM

age
Bu gen

new credit-scoring techniques and new


na BS
y cy

rtg
P

nonagency RMBS products enabled


nonprime-rated applicants to qualify Mortgage
for mortgages, opening a new chan- originators
nel for funds to flow from savers to a
new class of borrowers in this decade
(Chart 2, lower panel).
Su ar- gag
ne ort
bp pri es
rim me
m

Nonprime Boom Unravels


e/

As problems began to emerge in Nonprime


late 2006, investors realized they had mortgage
purchased nonprime RMBS with overly borrowers
optimistic expectations of loan quality.2
Much of their misjudgment plausibly
stemmed from the difficulty of forecast-

Feder al Reserve Bank of Dallas  EconomicLetter


ing default losses based on the short ployment as a driver of problem loans
history of nonprime loans. to underestimate the risk of nonprime
Subprime loan problems had mortgages. Indeed, swings in home-
surfaced just before and at the start price appreciation and interest rates
of the 2001 recession but then rapidly may also explain why prime and
Failure to appreciate the retreated from 2002 to 2005 as the subprime loan quality have trended
economy recovered (Chart 3). This together in the 2000s. This can be
risks of nonprime loans pre-2006 pattern suggested that as seen once we account for the fact
long as unemployment remained low, that past-due rates—the percentage
prompted lenders to overly so, too, would default and delinquen- of mortgages delinquent or in some
cy rates. stage of foreclosure—typically run five
ease credit standards. This interpretation ignored two times higher on subprime loans (Chart
other factors that had helped alleviate 3). When the favorable home-price
The result was a huge subprime loan problems earlier in the and interest rate factors reversed, the
decade. First, this was a period of rap- past-due rate rose markedly, despite
jump in origination idly escalating home prices. Subprime continued low unemployment.
borrowers who encountered financial Failure to appreciate the risks
shares for subprime and problems could either borrow against of nonprime loans prompted lenders
their equity to make house payments to overly ease credit standards.3 The
near-prime mortgages. or sell their homes to settle their result was a huge jump in origination
debts. Second, interest rates declined shares for subprime and near-prime
significantly in the early 2000s. This mortgages.
helped lower the base rate to which Compared with conventional
adjustable mortgage rates were prime loans in 2006, average down
indexed, thereby limiting the increase payments were lower, at 6 percent for
when initial, teaser rates ended. subprime mortgages and 12 percent
Favorable home-price and interest for near-prime loans.4 The relatively
rate developments likely led models small down payments often entailed
that were overly focused on unem- borrowers’ taking out piggyback loans
to pay the portion of their home
prices above the 80 percent covered
by first-lien mortgages.
Chart 3 Another form of easing facilitated
the rapid rise of mortgages that didn’t
Quality of Prime and Subprime Mortgages Deteriorates require borrowers to fully document
their incomes. In 2006, these low- or
Percent Percent no-doc loans comprised 81 percent of
3 16 near-prime, 55 percent of jumbo, 50
Share of conventional subprime percent of subprime and 36 percent of
15
2.8
mortgages past due prime securitized mortgages.
Share of conventional prime
14
The easier lending standards
mortgages past due
coincided with a sizeable rise in
2.6
13 adjustable-rate mortgages (ARMs). Of
the mortgages originated in 2006 that
2.4
12 were later securitized, 92 percent of
subprime, 68 percent of near-prime,
11
43 percent of jumbo and 23 percent
2.2
10
of prime mortgages had adjustable
rates. Now, with rates on one-year
2 9 adjustable and 30-year fixed mort-
’98 ’99 ’00 ’01 ’02 ’03 ’04 ’05 ’06 ’07 gages close, ARMs’ market share has
NOTES: Conventional mortgages are those not insured by the Federal Housing Administration or guaranteed by the dwindled to 15 percent, less than
U.S. Department of Veterans Affairs. Data are seasonally adjusted. Shaded area indicates recession.
SOURCE: Mortgage Bankers Association. half its recent peak of 35 percent in
2004.

EconomicLetter  Feder al Reserve Bank of Dallas


In early 2007, investors and lend- survey the share of banks tightening
ers began to realize the ramifications standards on prime mortgages jumped In the absence of home-
of credit-standard easing. Delinquency to 41 percent, while 56 percent did
rates for 6-month-old subprime and so for subprime loans. Many nonbank price appreciation, many
near-prime loans underwritten in 2006 lenders have also imposed tougher
were far higher than those of the same standards or simply exited the busi- households are finding it
age originated in 2004. ness altogether. This likely reflects
Other signs of deterioration also lenders’ response to the financial dis- difficult to refinance their
surfaced. The past-due rate for out- ruptions seen since last summer.
standing subprime mortgages rose The stricter standards meant fewer way out of adjustable-rate
sharply and neared the peak reached buyers could bid on homes, affecting
in 2002, with the deterioration much prices for prime and subprime bor- mortgages.
worse for adjustable- than fixed-rate rowers alike. Foreclosures added to
mortgages. In first quarter 2007, the downward pressures on home prices
rate at which residential mortgages by raising the supply of houses on
entered foreclosure rose to its fast- the market. And after peaking in
est pace since tracking of these data September 2005, single-family home
began in 1970. sales fell in September 2007 to their These high inventories will likely
Lenders reacted to these signs lowest level since January 1998. weigh on construction and home prices
by initially tightening credit standards The number of unsold homes for months to come. After peaking in
more on riskier mortgages. In the on the market has risen, sharply early 2005, the Standard & Poor’s/Case-
Federal Reserve’s April 2007 survey pushing up the inventory-to-sales Shiller index of year-over-year home-
of senior loan officers, 15 percent of ratio for existing single-family price appreciation in 10 large U.S. cities
banks indicated they had raised stan- homes from their low in January was down 5 percent in August—its big-
dards for mortgages to prime borrow- 2005 to their highest level since the gest drop since 1991. While a Freddie
ers in the prior three months, but a start of this series in 1989 (Chart Mac gauge of home prices posted a
much higher 56 percent had done so 4). Condominium supply, which is small year-over-year gain in the second
for subprime mortgages. Responses to reflected in the all-home numbers, has quarter, the pace was dramatically off
the July 2007 survey were similar. experienced an even sharper increase its highest rate, reported in third quar-
However, in the October 2007 since early 2005. ter 2005 (Chart 5).
In the absence of home-price
appreciation, many households are
finding it difficult to refinance their
Chart 4
way out of adjustable-rate mortgages
Existing-Home Inventories Rise from Late-2004 Lows obtained at the height of the hous-
ing boom. Larger mortgage payments
Months supply of unsold homes could exacerbate delinquencies and
11 foreclosures, especially with interest
rate resets expected to remain high for
10
the next year (Chart 6). This suggests
9 mortgage quality will likely continue
to fall off for some time.
8

7
Single-family homes Financial Turmoil
By August 2007, the housing
6
market’s weaknesses were apparent:
5
loan-quality problems, uncertainty
about inventories, interest rate resets
4 and spillovers from weaker home pric-
3
All homes es. These, coupled with ratings agen-
’89 ’90 ’91 ’92 ’93 ’94 ’95 ’96 ’97 ’98 ’99 ’00 ’01 ’02 ’03 ’04 ’05 ’06 ’07 cies’ downgrading of many subprime
NOTE: The all-homes category covers single-family homes, condominiums and nonrental apartments. Shaded areas RMBS, led to a dramatic thinning in
indicate recession.
SOURCE: National Association of Realtors.
trading for subprime credit instru-
ments, many of which carried synthet-

Feder al Reserve Bank of Dallas  EconomicLetter


ic, rather than market, values based
on models because of the instruments’
Chart 5
illiquidity.
Home-Price Appreciation Plunges On Aug. 14, the paralysis in the
into Negative Territory capital markets led three investment
funds to halt redemptions because
they couldn’t reasonably calculate the
Percent (year-over-year)
prices at which their shares could be
18 valued. This event triggered wide-
S&P/Case-Shiller
16 U.S. index spread concern about the pricing of
14 many new instruments, calling into
12 question many financial firms’ mar-
10
ket values and disrupting the normal
workings of the financial markets.
8
Freddie Mac Investors sought liquidity, putting
6 repeat-sales index
upward pressure on overnight inter-
4
est rates and sparking a sharp upward
2 repricing of risk premiums on assets,
0 particularly those linked to nonprime
–2 mortgages. One outcome was an
–4
interest rate spike for both mortgage-
’87 ’88 ’89 ’90 ’91 ’92 ’93 ’94 ’95 ’96 ’97 ’98 ’99 ’00 ’01 ’02 ’03 ’04 ’05 ’06 ’07 backed commercial paper and jumbo
NOTE: Shaded areas indicate recession. mortgages, which heightened financial
SOURCES: Freddie Mac; Standard & Poor’s/Case-Shiller.
market uncertainty. In this environ-
ment, nonagency RMBS were viewed
as posing more liquidity and default
risk than those packaged by Fannie
Chart 6 Mae and Freddie Mac.
Facing greater perceived default
Scheduled Resets on Adjustable-Rate Mortgages risk, investors began demanding much
Remain High higher risk premiums on jumbo mort-
gage securities, pushing up the cost
Billions of dollars in loans
of funding such loans via securitiza-
60 tion and encouraging lenders to incur
Subprime Jumbo
the extra cost of holding more of
Near prime GSE
50 these loans in their portfolios. This
contributed to a 1 percentage point
40 jump in jumbo interest rates between
June and late August, an especially
30 important increase given that jumbos
accounted for about 12 percent of
20 mortgage originations last year.
Although spreads between jumbo
10 and conforming loan rates have fallen
off their late-summer highs, they’re
0 still elevated. The higher rates have
July
2007
Nov. March
2008
July Nov. dampened the demand for more
expensive homes, just as tighter credit
SOURCE: Bank of America estimates based on LoanPerformance data.
standards reduced the number of buy-
ers for lower-end homes.

Macroeconomic Effects
A housing slowdown mainly affects
gross domestic product by curtailing

EconomicLetter  Feder al Reserve Bank of Dallas


housing construction and home-related appreciation since a 1986 law granted reversed by the 2007 retrenchment in
spending. It also reins in spending a federal income tax deduction for mortgage availability.
by consumers who have less housing home equity loans (Chart 7).
wealth against which to borrow.5 Compounding the uncertain out- Looking Ahead
Residential construction likely look for consumption is the likely The rise and fall of nonprime
exerted its largest negative effect in reversal of the early 2000s’ mort- mortgages has taken us into largely
third quarter 2006, when it subtracted gage credit liberalization.8 This will uncharted territory. Past behavior,
1.3 percentage points from the annual put further downward pressure on however, suggests that housing mar-
pace of real GDP growth. Last year, home prices and housing wealth and kets’ adjustment to more realistic
many forecasts predicted home con- may curtail home equity loans and lending standards is likely to be pro-
struction would stop restraining GDP cash-out refinancings. Finally, the longed.9
growth by the end of 2007 and the homebuying enabled by the easing of One manifestation of the slow
industry would start recovering in credit standards in recent years may downward adjustment of home prices
2008. These predictions were made have been at the expense of later and construction activity is the mount-
before the tightening of nonprime sales, further dampening the market ing level of unsold homes. The muted
credit standards began in late 2006. going forward. outlook for home-price appreciation,
The change in standards will likely The timing of housing wealth’s coupled with the resetting of many
prolong the housing downturn and impact on consumption may have nonprime interest rates, suggests fore-
delay the recovery, although it’s hard also changed. For example, before closures will increase for some time.
to tell precisely for how long. Since the advent of equity lines and cash- The sharp reversal of trends in
single-family permits have already out refinancings, housing wealth home-price appreciation will also
fallen 52 percent from their September increases may have affected U.S. con- dampen consumer spending growth, an
2005 peak, however, the worst of the sumption mainly by reducing home- effect that may worsen if the pullback
homebuilding drag may be behind us. owners’ need to save for retirement. in mortgage availability limits people’s
The same may not be true for Since then, such financial innovations ability to borrow against their homes.
housing’s indirect effect on consump- have enabled households to spend Although recent financial market
tion. Since the late 1990s, many their equity gains before retirement. turmoil will likely add to the housing
homeowners have borrowed against It’s unclear how much this may be slowdown, there are mitigating factors.
housing wealth, using home equity
lines of credit or cash-out refinancing
or not fully rolling over capital gains
on one house into a down payment or
Chart 7
improvements on the next one. These
mortgage equity withdrawals gave Mortgage Equity Withdrawals Increasingly Move
people access to lower cost, collateral- with Housing Inflation and Mortgage Refinancings
ized loans, which bolstered spending
on consumer goods. By one measure,
Percent (2-quarter moving average) Percent (year-over-year)
these withdrawals were as large as
12 20
6 to 7 percent of labor and transfer
Interest-rate-driven
income in the early to mid-2000s. 10 surge in cash-out and
other mortgage refinancing 16
The magnitude and timing of
8
{

these withdrawals may have changed


12
in hard-to-gauge ways. New research 6
suggests housing wealth’s impact on
4 8
consumer spending grew as recent
financial innovations expanded the 2
Housing inflation
4
ability to tap housing equity.6 This
0
is consistent with prior research on
housing’s connection to U.S. consumer –2 Mortgage equity withdrawal
0

spending.7 Aside from the interest- labor + transfer income

rate-related refinancing surge of 2002 –4 –4


’77 ’79 ’81 ’83 ’85 ’87 ’89 ’91 ’93 ’95 ’97 ’99 ’01 ’03 ’05 ’07
and 2003, mortgage equity-withdrawal
NOTE: Shaded areas indicate recession.
movements have become increasingly SOURCES: Freddie Mac; Bureau of Economic Analysis; Federal Reserve, flow of funds data; authors’ calculations.
sensitive to swings in home-price

Feder al Reserve Bank of Dallas  EconomicLetter


EconomicLetter is published monthly
by the Federal Reserve Bank of Dallas. The views
expressed are those of the authors and should not be
attributed to the Federal Reserve Bank of Dallas or the
First, the effect of slower home- are originated with the intent to fully sell them to Federal Reserve System.
price gains on consumer spending is investors. Bernanke discusses this in his remarks Articles may be reprinted on the condition that
likely to be drawn out, giving mon- at the 2007 Jackson Hole symposium (note 2). the source is credited and a copy is provided to the
Research Department of the Federal Reserve Bank of
etary policy time to adjust if necessary. 4
The figures are for securitized mortgages. See
Dallas.
Second, the Federal Reserve has “Mortgage Liquidity du Jour” (note 1). Economic Letter is available free of charge
been successful in slowing core inflation 5
“Making Sense of the U.S. Housing Slowdown,” by writing the Public Affairs Department, Federal
while maintaining economic growth. by John Duca, Federal Reserve Bank of Dallas Reserve Bank of Dallas, P.O. Box 655906, Dallas, TX
This gives policymakers inflation-fight- 75265-5906; by fax at 214-922-5268; or by telephone
Economic Letter, November 2006.
at 214-922-5254. This publication is available on the
ing credibility, which enables them to 6
See “How Large Is the Housing Wealth Effect? Dallas Fed web site, www.dallasfed.org.
coax down market interest rates should A New Approach,” by Christopher D. Carroll,
the economy need stimulus. Misuzu Otsuka and Jirka Slacalek, National
Third, even if the tightening of Bureau of Economic Research Working Paper
mortgage credit standards undesirably
no. 12746, December 2006; and “Housing,
slows aggregate demand, monetary
Credit and Consumer Expenditure,” by John
policy could still, if need be, help offset
Muellbauer, paper presented at the Federal
the overall effect by stimulating the
Reserve Bank of Kansas City’s Economic
economy via lower interest rates. This
Symposium, Jackson Hole, Wyo., Aug. 31–Sept.
would bolster net exports and business
1, 2007. Also see “Booms and Busts in the
investment and help cushion the impact
of higher risk premiums on the costs of UK Housing Market,” by John Muellbauer and
financing for firms and households.10 Anthony Murphy, Economic Journal, vol. 107,
November 1997, pp. 1701 – 27; and “House
DiMartino is an economics writer and Duca a Prices, Consumption, and Monetary Policy: A
vice president and senior policy advisor in the Financial Accelerator Approach,” by Kosuke Aoki,
Research Department of the Federal Reserve Bank James Proudman and Gertjan Vlieghe, Journal of
of Dallas. Financial Intermediation, vol. 13, October 2004, Richard W. Fisher
President and Chief Executive Officer
pp. 414 – 35.
Notes 7
“Estimates of Home Mortgage Originations, Helen E. Holcomb
The authors thank Jessica Renier for research Repayments, and Debt on One-to-Four-Family First Vice President and Chief Operating Officer
assistance. Residences,” by Alan Greenspan and James
Harvey Rosenblum
1
See “The Subprime Slump and the Housing Kennedy, Finance and Economics Discussion Executive Vice President and Director of Research
Market,” by Andrew Tilton, US Economics Series Working Paper no. 2005-41, Board of
Analyst, Goldman Sachs, Feb. 23, 2007, pp. Governors of the Federal Reserve System, W. Michael Cox
Senior Vice President and Chief Economist
4 – 6. Securitized mortgages account for roughly September 2005; and “Mutual Funds and the
70 to 75 percent of outstanding, first-lien U.S. Evolving Long-Run Effects of Stock Wealth on Robert D. Hankins
residential mortgages, according to estimates in U.S. Consumption,” by John V. Duca, Journal Senior Vice President, Banking Supervision
“Mortgage Liquidity du Jour: Underestimated No of Economics and Business, vol. 58, May/June
Executive Editor
More,” Credit Suisse, March 13, 2007, p. 28. 2006, pp. 202 – 21. W. Michael Cox
2
See, for example, Federal Reserve Chairman 8
This is a possibility to which Muellbauer (2007,
Ben Bernanke’s remarks, “Housing, Housing Editor
note 6) alludes.
Richard Alm
Finance, and Monetary Policy,” at the Federal 9
See Duca (note 5).
Reserve Bank of Kansas City’s Economic 10
For a discussion of the channels of monetary Associate Editor
Symposium, Jackson Hole, Wyo., Aug. 31, 2007. policy, see “Aggregate Disturbances, Monetary Monica Reeves
3
Part of the reason lenders eased credit stan- Policy, and the Macroeconomy: The FRB/US Graphic Designer
dards was that they planned to sell, rather Perspective,” by David Reifschneider, Robert Ellah Piña
than hold, the mortgages. The earlier easing of Tetlow and John Williams, Federal Reserve
standards may have partly owed to the potential Bulletin, January 1999, pp. 1–19.
moral hazard entailed when nonconforming loans

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2200 N. Pearl St.
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