Neighborhood Level Foreclosures in Durham County: Community Impact and Mortgage Details

advertisement

Neighborhood Level Foreclosures in

Durham County:

Community Impact and Mortgage Details

Report #3

April 2014

UNC Center on Poverty, Work and Opportunity

Neighborhood Level Foreclosures in Durham: Report #3 2

Acknowledgments

Special thanks to the Office of the Attorney General for the State of North Carolina for making this research possible. Thanks also to Center on Poverty, Work and Opportunity research fellow, Joseph Polich, and research assistants Stephanie Mellini, Kat Gardzalla and David Harper.

About the Center

The Center on Poverty, Work and Opportunity is a nonpartisan, interdisciplinary research center located in the UNC School of Law and designed to study, examine, document, and advocate for proposals, policies and services to mitigate poverty in North Carolina and the nation.

Contact information:

323 W. Barbee Chapel Road

Campus Box #3382

Chapel Hill, NC 27599-3382

919.445.0196 poverty_center@unc.edu

www.law.unc.edu/centers/poverty/

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3 3

Introduction

This is the third in a series of reports examining foreclosures on a neighborhood level in Durham County,

North Carolina. Data informing this series was obtained from records filed at the Durham County Clerk of

Courts’ office, consisting of foreclosure starts initiated primarily in January and February 2011.

The first report pinpointed where foreclosures were happening in greatest number and concentration. The second report provided a demographic and socioeconomic breakdown of census tracts with and without foreclosures, with special attention paid to the tracts with the highest number and rate of foreclosures.

This report will focus on the economic impact of foreclosure on nearby residences and neighborhoods, as well as provide detailed information about home loans, including the prevalence of subprime loans, in this sample.

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3 4

Spillover Costs of Foreclosure

Foreclosure is detrimental to the households that experience it directly. The loss of a home destabilizes families; destroys wealth; wrecks credit ratings and impedes future asset building. But the economic harm of foreclosure doesn’t stop at the household level. Local governments lose tax revenue and incur costs associated with foreclosed properties. And homes in the vicinity of a foreclosed property lose value due to the presence of the foreclosure itself. This section calculates the amount of home value depreciation caused by the Durham foreclosure starts analyzed in this research.

To calculate the spillover cost of foreclosure, we applied methodology adopted by the Center for Responsible

Lending. It estimated that every residence within 1/8 th mile of a foreclosure experiences a .744% reduction in home value.

i We plotted addresses for the foreclosure starts in our sample on a map of residential parcels in Durham County (Map 1). By creating a buffer with a 1/8 th mile radius around each foreclosure start address, we could count the number of residential parcels that fell within each 1/8 th mile buffer. We then added up the number of residential properties inside all the buffers in each census tract and multiplied that sum by the tract’s median home value to yield the total estimated home value per tract affected by foreclosure. That number was then multiplied by .744%, resulting in the total amount of depreciation for each census tract.

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3

Map 1: Residential Parcels in Durham County and Location of Foreclosure Starts

5

Source:(Durham(County(GIS(and(Foreclosure(Project(data.((All(maps(made(using(QGIS.((

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3 6

Over 11,000 residential parcels in Durham came in contact with at least one of the buffer areas surrounding the foreclosure start addresses in our sample. The total estimated value of the affected homes is over $1.7 billion and the total amount of depreciation stemming from foreclosure starts in our sample is over $13 million. While this is an astonishing sum, it is a fraction of the total annual loss in home value.

The average spillover cost per tract is $285,934. However, the amount of depreciation in each tract varies widely due to the number and location of foreclosure starts within each tract, neighborhood density, and the tract’s median home value. Census Tract 18.07, the tract with the largest number of foreclosure starts, also has the largest number of affected properties (1,408) as well as the greatest loss in value (over $1.5 million)

(Map 2). All told, the foreclosure starts in our sample touch about one in seven residential properties in

Durham.

Map 1: Tract 18.07 (Yellow) and Residential Properties Near Foreclosure (Purple)

Source:(Durham(County(GIS(and(Foreclosure(Project(data(

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3 7

Approximately 75% of homes affected by spillover costs are in tracts where the majority of residents are people of color. Homes in majority minority tracts lost over $8.7 million in value, compared to $4.4 million lost to homes in predominantly white tracts.

While the spillover cost caused by the foreclosures in our sample represents a substantial loss in home value, it is probably an underestimate. As shown in Map 2 above and Map 3 below, many residential parcels are contained within multiple buffer areas. Research shows that homes experience a greater drop in value if exposed to more than one foreclosure.

ii We did not calculate the number of homes lying within two or more buffer areas, but many homes are so situated and would therefore have suffered a greater loss of value than estimated here.

Map 3: Example of Overlapping Buffers (Yellow)

Source:(Durham(County(GIS(and(Foreclosure(Project(data(

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3

Mortgage Information

8

Financial Institutions

One of the most striking features of the files we examined is the variety of lenders that appear. While not all files contain loan information, those that do identify a slew of traditional and nontraditional lenders. All told, in our sample 78 different lenders issued 125 mortgages.

iii As discussed in the section on subprime lending below, some of these lenders gained national notoriety for their questionable lending practices.

iv

The number of foreclosing entities is considerably smaller, with only 36 institutions represented in 137 records. This reduction may reflect the contraction in the mortgage industry after the housing bubble burst.

v

Table 1: Most Common Lending and Foreclosing Companies

Most(frequent(lenders((n=125)(

Wells(Fargo(

BB&T(

JPMorgan(Chase(

American(Home(Mortgage(

Flagstar(Bank(

Bank(of(America(

CTX(Mortgage(Co.(

Generations(Community(Credit(Union(

Option(One(Mortgage(Corp.(

Wachovia(Mortgage(Corp(

3(

3(

3(

3(

4(

3(

5(

4(

Number(of( loans(

12(

6(

Most(frequent(foreclosing(lenders(

(n=(137)(

Wells(Fargo(

Chase(Home(Finance(

CitiMortgage(

BB&T(

JP(Morgan(Chase(

Flagstar(Bank((

HSBC(Bank(USA(

Bank(of(NY(Mellon(

Bank(of(America(

Nationstar(Mortgage(

3(

3(

4(

3(

6(

5(

11(

7(

Number(of(foreclosure(( starts(

32(

17(

Source:(Foreclosure(Project(data(

The list of originating lenders in foreclosure-burdened census tracts is diverse and closely resembles

Durham County overall.

vi Forty-five lenders made 54 loans in the tracts with the most foreclosure starts, while 15 lenders made 16 loans in the tracts with the highest foreclosure start rates. Among the lenders in the high foreclosure rate tracts are American Home Mortgage (which made two loans), CTX Mortgage

Company, American Brokers Conduit, BNC Mortgage, FM Lending Services, Option One Mortgage

Company, Union Bank of Indianapolis, BancPlus Mortgage Company and Mortgage Lenders Network.

In high foreclosure start tracts, 32 lenders were responsible for 52 foreclosure starts, with Wells Fargo the most common (12), followed by Chase Home Finance (5), CitiMortgage (3), Flagstar Bank (2), Generations

Community Credit Union (2), and Nationstar Mortgage (2). Fifteen lenders initiated 19 foreclosure starts in

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3 high foreclosure rate tracts, with CitiMortgage (3 foreclosure starts), Wells Fargo (2) and HSBC (2) at the top of the list.

Loan Amounts

Most loans in our sample were for modest amounts. Of the 148 records with this information, the largest amount borrowed is $560,000; the smallest $34,400. The average amount is $127,069 and the median

$115,760. By way of comparison, the average home loan amount in North Carolina in 2011 was $207,037.

vii

Fifteen census tracts have an average loan amount of less than $100,000.

The range for loan amounts in the foreclosure-burdened tracts is narrower: from $75,723 to $163,333 for high foreclosure start tracts and $57,500 to $107,255 for high foreclosure rate tracts. The average loan for high foreclosure start tracts is $124,604 and the median is $115,082, both of which align closely with overall numbers. For tracts with the highest foreclosure start rate, average ($83,555) and median ($81,050) loan amounts are significantly lower.

Year of Origination

Of the 142 records that contain information on year of origination, 97 loans (68%) were made between 2002 and 2008 (Figure 1). This makes sense given heightened home buying activity during the period leading up to the housing crisis. The mortgages in our sample that were obtained during this period are also more likely to contain terms that made them apt to fail, a topic we discuss in greater detail in the next section.

9

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3

Figure 1: Number of Loans by Year for All Tracts

30(

25(

20(

15(

10(

5(

0(

10

18(

16(

14(

12(

10(

8(

6(

4(

2(

0(

Source:(Foreclosure(Project(data(

One third of loans in high foreclosure start tracts were originated in 2007 and 2008 and over half (52%) were taken out between 2005 and 2008. For high foreclosure rate tracts, 11 out of 18 loans (61%) were taken out in 2005 and 2006 (Figure 2).

Figure 1: Number of Loans by Year for Foreclosure-burdened Tracts

High(foreclosure( start(tracts(

High(foreclosure( rate(tracts(

Source:(Foreclosure(Project(data(

UNC$Center$on$Poverty,$Work$and$Opportunity

15(

10(

5(

0(

25(

20(

Neighborhood Level Foreclosures in Durham: Report #3

Subprime Lending

To measure rates of subprime lending over time in Durham, we use high cost home loans as a proxy.

viii In

Durham County, the rate of high cost home loans rose through 2004 and 2005, peaked in 2006 and fell off quickly. This pattern follows state and national patterns, though the county’s rates are lower (Figure 3).

Figure 3: Percentage of High Cost Home Loans, 2004-3Q 2009

11

30(

2004( 2005( 2006( 2007( 2008( 2009(

US(

NC(

Durham(County(

City(of(Durham(

Source:(HMDA(data(courtesy(of(PolicyMap(

Between 2004 and 2009, the rate of high cost home loans in individual census tracts varied tremendously, from a high in census tract 13.01 of 93.75% in 2005 to tracts that remain below 10% for all six years. The tracts with the highest average rate between 2004 and 2009 begin this period with more than double the county rate and all see high cost loan rates upward of 60%. As with the county overall, high cost loans in these tracts drop rapidly on the heels of the housing crash (Figure 4).

ix

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3

Figure 2: Tracts with the Highest Rate of High Cost Home Loans, 2004-3Q 2009

100(

90(

80(

70(

60(

50(

40(

30(

20(

10(

0(

2004( 2005( 2006( 2007( 2008( 2009(

Tract(13.04(

Tract(14(

Tract(13.03(

Tract(13.01(

Tract(9(

12

Source:(Foreclosure(Project(analysis(of(HMDA(data(courtesy(of(PolicyMap(

Although not all the foreclosure files we examined contain mortgages or other loan documentation, 43 of the

196 files in our sample show at least one sign of subprime lending. Over half of these (27) contain adjustable rate mortgages (ARMs). While ARMs are not inherently or necessarily subprime, nationally a large proportion of subprime mortgages originating between 2000 and 2007 were ARMs.

x Furthermore, one third of ARMs in this sample were accompanied by additional unfavorable terms. We also found other indicia of subprime lending such as option ARMs (which allow the borrower to chose the method for determining payment every month), balloon payments, interest only payments, prepayment penalties and/or high interest rates.

Only 4 subprime home loans in our sample originated between 1987 and 2003. As with national, state and regional trends, the majority occurred in the mid-2000s (Figure 5).

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3

Figure 5: Number of Mortgages with Subprime Terms in Sample by Year

12(

10(

8(

2(

0(

6(

4(

Number(of( mortgages(with( subprime(terms(

13

Source:(Foreclosure(Project(data(

Twenty out of the 46 tracts in our sample contain at least one mortgage with subprime features. All tracts with at least two high cost mortgages are listed in Table 2. The tracts with the most high cost loans are also those with most foreclosure starts. Additionally, as tract 9, 18.02, 13.04 and 17.08 demonstrate, tracts with high rates of foreclosure starts are also present.

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3 14

Table 2: Tracts with Highest Number of Mortgages with Subprime Terms

Census& tract&

18.07(

17.09(

9(

18.01(

18.02(

13.04(

20.26(

16.01(

18.08(

17.08(

18.06(

#&of&foreclosure& starts&

18(

9(

12(

2(

4(

9(

8(

8(

5(

6(

12(

#&of&mortgages&with&subprime& terms&&

7(

4(

3(

2(

3(

3(

2(

2(

2(

2(

2(

*These(tracts(did(not(exist(until(2010.(

Source:(Foreclosure(project(data(and(HMDA(data(courtesy(of(PolicyMap(

Average&rate&of&high&cost&home& loans,&2004<3Q&2009& n/a*(

31.1%(

Foreclosure&rank&in&sample&

1 st

(in(#(of(foreclosures(

5 th (in(#(of(foreclosures(

53.6%(

25.9%(

2 nd

(in(foreclosure(rate(

4 th (in(#(of(foreclosures(

32.1%( 3 rd

(in(#(of(foreclosures,(10 th

(in(rate(

46.2%( n/a*(

13.2%( n/a*(

30.0%( n/a*(

5 th (in(foreclosure(rate(

9 th

(in(#(of(foreclosures(

8 th (in(#(of(foreclosures(

6 th

(in(#(of(foreclosures(

7 th (in(#(of(foreclosures,(8 th (in(rate(

2 nd

(in(#(of(foreclosures(

Thirty-four percent of the mortgages from tracts in Table 2 show signs of being subprime and they constitute three-quarters of the irregular mortgages in our sample. With the exception of 16.01, these tracts are all majority minority. Many of them, notably 17.09, 9, 18.02, and 13.04, have crippling poverty rates and low median household incomes. Their high subprime and foreclosure start rates raise questions about how and why these loans were made in the first place, whether certain neighborhoods were targets for lax or unscrupulous lenders, and the extent of the toll taken by foreclosures in these neighborhoods.

High cost mortgages are fairly evenly distributed among the lenders in our sample. Two lenders made three high cost loans; three lenders made two high cost loans (Table 3). The remaining 25 made one each.

However, Option One Mortgage Corp., which tied for first on our list, holds the distinction of being the lender that most consistently peddled high cost loans. BB&T, with whom Option One shares top honors, has a subprime rate of 50% (3 out of 6 mortgages), while all three of Option One’s mortgages were high cost.

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3 15

Table 2: Lenders with Most Mortgages with Subprime Terms

Lender&

Option(One(Mortgage(Corp.(

BB&T(

Bank(of(America(

Generations(Community(Credit(Union(

Mortgage(Investors(Corp.(

Wells(Fargo(

American(Home(Mortgage(

SPH(Mortgage((LLC(

Suntrust(Mortgage(

The(remaining(lenders(made(one(loan(each.(

Number&of&mortgages&in&sample& with&subprime&terms&

3(

3(

2(

1(

2(

2(

1(

1(

1(

Source:(Foreclosure(Project(data(

Total&number&of&mortgages&in&sample&

Option One was named the sixth largest high interest lender in the nation by the Center for Public

Integrity.

xi A number of other infamous companies are present here too: First Franklin, Long Beach

Mortgage, Wells Fargo, WMC Mortgage, BNC Mortgage, Equifirst, American Home Mortgage Investment,

Decision One and Aegis Mortgage—all among the country’s most egregious and prolific high cost lenders— are found in our sample.

xii

2(

12(

4(

2(

2(

(

3(

3(

3(

6(

Conclusion

The foreclosure starts in this sample drained over $13 million from nearby homes. Each foreclosure start in this sample cost its neighbors $67,107. Because this sample represents only two months worth of foreclosure starts, the annual home value depreciation due to foreclosures in Durham is many times this amount.

Tracts that are primarily minority residents lost almost twice the home value than tracts that are mostly white.

Many lenders of varying types were active in Durham, and home loan originations peaked between 2002 and

2008. Fewer financial institutions were involved in the foreclosure process. On average, loan amounts were modest, especially for high foreclosure rate tracts. A significant portion of loan documents show signs of subprime lending. These loans are concentrated in minority neighborhoods and seem to be correlated with high numbers and rates of foreclosure.

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3 16

The three reports in this series have documented that foreclosures in Durham follow national patterns in a number of important ways. The geographically concentrated distribution of foreclosure starts, the disproportionate effect of foreclosure starts on neighborhoods of color, patterns of lending and subprime lending—these all bear similarities to the way the foreclosures unfolded across the country. Yet despite these similarities, foreclosure’s impact is intensely local. It is our hope that these and future reports deepen our understanding of foreclosures on a local level, help advocates and policymakers better serve their constituents, direct resources to the people and places that need them the most and ultimately foster policies that support adequate and affordable housing for renters and homeowners alike.

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3

Tract&17.06&

Tract&17.07&

Tract&17.08&

Tract&17.09&

Tract&17.10&

Tract&17.11&

Tract&18.01&

Tract&18.02&

Tract&18.06&

Tract&18.07&

Tract&18.08&

Tract&18.09&

Tract&19&

Tract&20.07&

Tract&20.08&

Tract&20.09&

Tract&20.13&

Tract&20.17&

Tract&20.18&

Tract&20.20&

Tract&20.21&

Tract&1.01&

Tract&2&

Tract&5&

Tract&6&

Tract&7&

Tract&9&

Tract&10.01&

Tract&10.02&

Tract&11&

Tract&13.03&

Tract&13.04&

Tract&14&

Tract&15.02&

Tract&16.01&

Tract&16.03&

Tract&16.04&

Appendix A

Census&tract& Number&of&homes&in& buffer&

635(

1408(

486(

187(

80(

88(

122(

233(

387(

100(

86(

222(

213(

243(

80(

384(

557(

60(

91(

445(

531(

43(

210(

145(

162(

49(

97(

202(

86(

85(

244(

246(

305(

246(

235(

74(

210(

Median&home&value&in& tract&

$110,100(

$191,900(

$117,400(

$219,200(

$272,800(

$65,000(

$76,800(

$85,400(

$76,100(

$89,500(

$104,200(

$84,200(

$114,700(

$167,800(

$187,300(

$220,100(

$192,200(

$207,700(

$155,700(

$118,500(

$141,700(

$125,300(

$135,300(

$118,500(

$155,800(

$143,800(

$213,900(

$182,000(

$199,400(

$227,300(

$415,700(

$110,000(

$166,700(

$327,900(

$310,300(

$322,800(

$227,400(

Total&value&of&affected& homes&

$27,084,600(

$45,096,500(

$8,687,600(

$46,032,000(

$23,188,000(

$15,860,000(

$18,892,800(

$26,047,000(

$3,728,900(

$8,681,500(

$21,048,400(

$7,241,200(

$4,932,100(

$35,238,000(

$27,158,500(

$35,656,200(

$11,532,000(

$18,900,700(

$69,286,500(

$62,923,500(

$34,433,100(

$10,024,000(

$51,955,200(

$66,004,500(

$98,933,000(

$202,470,400(

$103,955,400(

$34,034,000(

$15,952,000(

$20,002,400(

$50,715,400(

$25,630,000(

$64,512,900(

$32,790,000(

$26,685,800(

$71,661,600(

$48,436,200(

Depreciation&in&value&

$85,798(

$140,621(

$515,492(

$468,151(

$256,182(

$74,579(

$386,547(

$491,073(

$736,062(

$1,506,380(

$773,428(

$253,213(

$118,683(

$148,818(

$377,323(

$190,687(

$479,976(

$243,958(

$198,542(

$533,162(

$360,365(

(

$201,509(

$335,518(

$64,636(

$342,478(

$172,519(

$117,998(

$140,562(

$193,790(

$27,743(

$64,590(

$156,600(

$53,875(

$36,695(

$262,171(

$202,059(

$265,282(

17

UNC$Center$on$Poverty,$Work$and$Opportunity

Neighborhood Level Foreclosures in Durham: Report #3

Census&tract &

Tract&20.22&

Tract&20.23&

Tract&20.24&

Tract&20.25&

Tract&20.26&

Tract&20.27&

Tract&20.28&

Tract&21&

Tract&23&

Total&

Number&of&homes&in& buffer (

280(

71(

239(

24(

75(

69(

407(

391(

196(

11,029( (

Median&home&value&in& tract (

$192,100(

$231,800(

$191,900(

$173,900(

$130,100(

$179,700(

$202,200(

$233,800(

$65,500(

Total&value&of&affected& homes (

$14,407,500(

$15,994,200(

$78,103,300(

$67,994,900(

$36,428,000(

$12,758,700(

$48,325,800(

$5,611,200(

$12,838,000(

$1,767,873,500(

Source:(Foreclosure(Project(data(and(analysis(of(2012(American(Community(Survey(5fYear(Estimates(

UNC$Center$on$Poverty,$Work$and$Opportunity

18

Depreciation&in&value (

$107,192(

$118,997(

$581,089(

$505,882(

$271,024(

$94,925(

$359,544(

$41,747(

$95,515(

$13,152,979(

Neighborhood Level Foreclosures in Durham: Report #3 19

Endnotes

i Debbie Gruenstein Bocian, Peter Smith and Wei Li, Collateral Damage: The Spillover Costs of Foreclosures

(Center for Responsible Lending, Oct. 24, 2012), http://www.responsiblelending.org/mortgagelending/research-analysis/collateral-damage.pdf

. ii John P. Harding, Eric Rosenblatt and Vincent W. Yao, The Contagion Effect of Foreclosed Properties , July

13, 2009, http://www.business.uconn.edu/Realestate/publications/pdf%20documents/406%20contagion_080715.pdf. iii CitiFinancial Mortgage, CitiFinancial Services and CitiMortgage were or are subsidiaries of CitiGroup and are counted as one company. iv The Center for Public Integrity, “The Subprime 25,” May 6, 2009, http://www.publicintegrity.org/2009/05/06/5554/subprime-25 . v Rick Green, “Lehman Shuts Unit; Toll of Lenders Tops 100: Subprime Scorecard,” Bloomberg.com, Aug. 23,

2007, http://www.bloomberg.com/apps/news?pid=newsarchive&sid=aQBUrPcefMtc&refer=realestate vi “Foreclosure burdened tracts” are census tracts with the five highest numbers and rates of foreclosure starts. The tracts with the highest number of foreclosure starts are, in descending order, 18.07, 18.02 and

18.06 (tied), 17.09, 18.08 and 17.08 (tied), and 16.01. The tracts with the highest rate of foreclosure starts are 23, 9, 15.02, 17.09 and 13.04. vii Daily Real Estate News, “What Does the Average Home Owner Pay on a Mortgage,” Realtor Mag,

National Association of Realtors, January 3, 2012, http://realtormag.realtor.org/daily-news/2012/01/03/whatdoes-average-home-owner-pay-mortgage . viii The Home Mortgage Disclosure Act defined high cost home loans as a loan where the annual percentage rate is higher than US Treasury yield by three or more percentage points for a first lien loan or five or more for a second lien loan. Because the definition changed at the end of 2009, we consider data only up through the 3 rd quarter of 2009. Fortunately, this covers most of the home loans in this sample. ix This data refers to the 2000 census tract boundaries. As a result, it does not provide data for tracts created in 2010. x Geetesh Bhardwaj and Rajdeep Sengupta, Where’s the Smoking Gun? A Study of Underwriting Standards for US Subprime Mortgages , Working Paper (Research Division, Federal Reserve Bank of St. Louis, October

2008), http://economics.rutgers.edu/dmdocuments/Sengupta_SmokingGun.pdf

. Between 2000 and 2007, adjustable rate mortgages comprised well over half of first lien subprime mortgages. xi The Center for Public Integrity, “The Subprime 25,” May 6, 2009, http://www.publicintegrity.org/2009/05/06/5554/subprime-25 . xii The Center for Public Integrity, “The Subprime 25,”; Office of the Comptroller of the Currency, U.S.

Department of the Treasury, “Worst Ten in the Worst Ten,” November 11, 2008, http://www.occ.treas.gov/news-issuances/news-releases/2009/nr-occ-2009-112b.pdf

.

UNC$Center$on$Poverty,$Work$and$Opportunity

Download