The Social & Ethical Dimensions of the Subprime Mortgage Crisis

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The Social & Ethical Dimensions of the Subprime Mortgage
Crisis: An Analysis of Lending and Regulations that Contributed
to the 2008 Financial Crisis
March 2, 2009 (ams)
EXECUTIVE SUMMARY
The 2008 financial crisis was the culmination of many variables: subprime lending and its
lack of financial regulation and oversight, deregulation, and the risky securitization of
mortgage loans to Wall Street investment banks and the global financial market. Prior to the
emergence of these variables there was a push towards increasing homeownership to fulfill
the ‚American Dream.‛
Research indicates that the Clinton and Bush Administrations supported changes in lending
policy to achieve these goals. In addition, the repeal of the Glass-Stegall Act had severe
implications to the financial market relaxing the investment practices of financial
institutions, thus creating a similar crisis reminiscent of the Great Depression.
As mortgage lenders began taking advantage of the new subprime market, the fixation for
higher profits and unethical corporate culture started a domino effect resulting in unrealistic
ratings of mortgage securities as they were bundled and sold on Wall Street. When these
risky subprime loans began to default, the financial crisis resulted. Subsequently, the Fed
was critized for not utilizing the definitions of the Home Ownership and Equity Protection
Act (HOEPA), to monitor relevant subprime activity. Within this research project are the
supportive details of how relaxed lending practices and regulations contributed to a
financial crisis of global magnitude.
2
Table of Contents
RESOURCES & SUMMARIES ........................................................................................................ 4
Articles ............................................................................................................................................. 4
Atlas, J. & Drier, P. (2007) ‚The Conservative Origins of the Sub-Prime Mortgage
Crisis‛ The American Prospect ..................................................................................................... 4
Flynn, M. (2009) ‚Anatomy of a Breakdown‛ Reason ............................................................ 4
Kuttner, R. (2007) ‚Repeal of Glass Steagall has caused the Subprime Crisis‛ .................. 5
Periodicals ....................................................................................................................................... 5
Krinsman, A. (2007) ‚Subprime Mortgage Meltdown: How Did It Happen and How
Will It End?‛ Journal of Structured Finance ............................................................................... 5
Taylor, J. B. (2009) ‚How Government Created the Financial Crisis‛ The Wall Street
Journal............................................................................................................................................ 6
Working Papers .............................................................................................................................. 6
Park, K. (2008) ‚Subprime Lending and the Community Reinvestment Act‛ The Joint
Center for Housing Studies of Harvard University ...................................................................... 6
Mozilo, A. R. (2003) ‚The American Dream of Homeownership: From Cliché to
Mission‛ The Joint Center for Housing Studies of Harvard University...................................... 6
Books ................................................................................................................................................ 7
Gramlich, E. M. (2007) Subprime Mortgages: America’s Latest Boom and Bust .............. 7
Shiller, R. J. (2008) The Subprime Solution: How Today’s Global Financial Crisis
Happened, and What to do about it. ........................................................................................ 7
Websites ........................................................................................................................................... 8
Center for Responsible Lending ................................................................................................ 8
CNBC – House of Cards ............................................................................................................. 8
National Association of Mortgage Fiduciaries ........................................................................ 8
PBS – Frontline Homepage: Inside the Meltdown.................................................................. 8
Links ................................................................................................................................................. 8
American Bar Association Web link ......................................................................................... 8
Consumer Affairs Web Link ...................................................................................................... 8
Harvard Kennedy School Web Link ......................................................................................... 9
House Financial Services Committee Web Link ..................................................................... 9
Page 2 of 12
The Social & Ethical Dimensions of the Subprime Mortgage Crisis: An Analysis of Lending and Regulation that Contributed to the
2008 Global Financial Crisis, March 02, 2009 (ams)
USER’S NOTE: This Research Document and all Original Summary Language is the claimed PROPRIETARY PROPERTY of the
Banta Center for Business, Ethics and Society. No replication of the research document as a whole or original summary language
may be made without the express written permission of the director of the Banta Center.
3
Naked Capitalism Web Link...................................................................................................... 9
Videos/Media ................................................................................................................................ 10
MSNBC Interview with Mark Zachary .................................................................................. 10
CBS – Confessions of a Subprime Lender .............................................................................. 10
CBS – An Invitation to Fraud ................................................................................................... 10
CBS – Countrywide CEO Scrutinized .................................................................................... 10
CBS – Subprime Mortgage Meltdown .................................................................................... 10
CBS – Where is the Bottom? ..................................................................................................... 10
House of Cards Slideshow – Origins of the Financial Crisis ‚Then and Now‛ ............... 11
House of Cards Video ............................................................................................................... 11
Frontline: Inside the Meltdown Documentary ...................................................................... 11
Exhibits .......................................................................................................................................... 11
Exhibit A – Stipulated Judgment and Injunction: ................................................................. 11
Exhibit B – Plantiff’s Original Complaint: ............................................................................. 11
CONCLUDING REMARKS ........................................................................................................... 12
ADDITIONAL THREADS FOR FUTURE REFERENCE .......................................................... 12
Bond, C. & Williams, R. (2007). Residential Segregation and the Transformation of
Home Mortgage Lending. Societal Forces. Vol. 86 No. 8 pp. 671-696. ................................ 12
Calem, P., Gillen, K. & Wachter, S. (2004). The Neighborhood Distribution of Subprime
Mortgage Lending. Journal of Real Estate Finance and Economics. Vol. 29 No. 4. pp. 393410................................................................................................................................................ 12
U.S. Department of Housing and Urban Development. ...................................................... 12
Page 3 of 12
The Social & Ethical Dimensions of the Subprime Mortgage Crisis: An Analysis of Lending and Regulation that Contributed to the
2008 Global Financial Crisis, March 02, 2009 (ams)
USER’S NOTE: This Research Document and all Original Summary Language is the claimed PROPRIETARY PROPERTY of the
Banta Center for Business, Ethics and Society. No replication of the research document as a whole or original summary language
may be made without the express written permission of the director of the Banta Center.
4
RESOURCES & SUMMARIES
Articles
Atlas, J. & Drier, P. (2007) ‚The Conservative Origins of the Sub-Prime Mortgage Crisis‛
The American Prospect
This article can be retrieved from:
http://www.prospect.org/cs/articles?article=the_conservative_origins_of_the_subprime_mor
tgage_crisis
In this article, the authors claim that the root of the problem of subprime mortgages stems
from, ‚old failure of government to adequately regulate the banking industry.‛ They
explain what subprime mortgages are, and suggest that they became a ‚goldmine‛ as
‚subprime business had become a $1.5 trillion global market for investors seeking high
returns.‛ In addition, they reveal that many of these mortgage executives cashed out before
the market took its catastrophic crash, giving detail to the millions they received in personal
profits. They point out the conspiratory relationships built on predatory loans between loan
agents and contractors or appraisers, yet on the contrary explain that some of these
subprime borrowers were, ‚speculators themselves, seeking to profit from the real estate
housing bubble.‛
Flynn, M. (2009) ‚Anatomy of a Breakdown‛ Reason
This article can be retrieved from: Research Library Core database. (Document
ID: 1611293851) at http://www.redlands.edu/x1962.asp
The article begins with the thought that, ‚concerted government policy helped trigger the
financial meltdown—and will almost certainly extend it.‛ The author promotes the idea
that politicians became ‚intoxicated‛ with promoting affordable housing in the 1990’s
stating that ‚Congress was mandating 50 percent of mortgages issued by Fannie and
Freddie were going to households making below their area’s median income.‛ He suggests
that Bill Clinton and George W. Bush pushed for lending to low-income households and
changes in federal policy that made this achievable. He points out that Fannie and Freddie
had no oversight and potentially was involved with, ‚extensive financial fraud‛.
Page 4 of 12
The Social & Ethical Dimensions of the Subprime Mortgage Crisis: An Analysis of Lending and Regulation that Contributed to the
2008 Global Financial Crisis, March 02, 2009 (ams)
USER’S NOTE: This Research Document and all Original Summary Language is the claimed PROPRIETARY PROPERTY of the
Banta Center for Business, Ethics and Society. No replication of the research document as a whole or original summary language
may be made without the express written permission of the director of the Banta Center.
5
Kuttner, R. (2007) ‚Repeal of Glass Steagall has caused the Subprime Crisis‛
This article can be retrieved from: http://www.tigerboard.com/boards/missouritigers.php?message=5408339
Founding Co-Editor of The American Prospect, Robert Kuttner, testifies before the Committee
on Financial Services on October 2, 2007 paralleling the risks of the 1920’s to our current
financial state claiming that, ‚the abuses and risks are all too similar and enduring.‛ In his
testimony, he lists and identifies the exact abuses that took place before the Great
Depression. He makes an important statement declaring, ‚yet another parallel is the failure
of regulation to keep up with financial innovation that is either far too risky to justify the
benefit to the real economy, or just plain corrupt, or both.‛ He stated that the 1994 Home
Equity and Ownership Protection Act gave the Fed authority to oversee the lending
practices, claiming that they should have ‚policed‛ the underwriting standards and
practices. He concludes to the committee that the parallels leave him with a startling sense
of ‚déjà vu.‛
*Original testimony by Robert Kuttner to the U.S. House of Representative October 2, 2007
also found by visiting:
http://financialservices.house.gov/hearing110/testimony_-_kuttner.pdf
Periodicals
Krinsman, A. (2007) ‚Subprime Mortgage Meltdown: How Did It Happen and How
Will It End?‛ Journal of Structured Finance
This article can be retrieved from: ABI/INFORM Global database. (Document
ID: 1326940091) at http://www.redlands.edu/x1962.asp
This article begins with explaining why the subprime mortgage market was so prosperous,
detailing how ‚borrower friendly criteria‛ allowed these mortgage products to prevail in
the market. The author emphasizes the fact the there were relaxed underwriting standards
and characteristics of risk layering. He also details how the lender verification and
document requirements were relaxed thus earning the title, ‚low and no document loans.‛
In conclusion, he reasons that the best approach to handle the situation is for new federal
regulations, but ends with the question, ‚how will the problems end?‛
Page 5 of 12
The Social & Ethical Dimensions of the Subprime Mortgage Crisis: An Analysis of Lending and Regulation that Contributed to the
2008 Global Financial Crisis, March 02, 2009 (ams)
USER’S NOTE: This Research Document and all Original Summary Language is the claimed PROPRIETARY PROPERTY of the
Banta Center for Business, Ethics and Society. No replication of the research document as a whole or original summary language
may be made without the express written permission of the director of the Banta Center.
6
Taylor, J. B. (2009) ‚How Government Created the Financial Crisis‛ The Wall Street
Journal
This article can be retrieved from: http://online.wsj/article/SB123414310280561945.html
The Bowen H. and Janice Arthur McCoy Senior Fellow at the Hoover Institution and the
Mary and Robert Raymond Professor of Economics at Stanford University, John B. Taylor,
reveals that many people want some sort of commission or investigation into the financial
crisis. He claims that his research shows that, ‚government actions and interventions – not
any inherent failure or instability of the private economy caused, prolonged and
dramatically worsened the crisis.‛ He also notes that GSE’s, Fannie Mae and Freddie Mac
were encouraged to buy such risky mortgage related securities.
Working Papers
Park, K. (2008) ‚Subprime Lending and the Community Reinvestment Act‛ The Joint Center for
Housing Studies of Harvard University
This article can be retrieved from:
http://www.jchs.harvard.edu/publications/governmentprograms/n08-2_park.pdf
Kevin Park provides data from the Home Mortgage Disclosure Act (HMDA) that
statistically proves that the Community Reinvestment Act (CRA) only accounted for a
fraction of the subprime mortgages, where as others strongly believe that the CRA
attributed to a larger portion of mortgage lending in lower income communities. This study
provides the premise that the CRA was not a significant factor in subprime lending, while
reinforcing the predominant opinion that the financial ruin was attributed by lack of
regulation.
Mozilo, A. R. (2003) ‚The American Dream of Homeownership: From Cliché to
Mission‛ The Joint Center for Housing Studies of Harvard University
This article can be retrieved from:
http://www.jchs.harvard.edu/publications/homeownership/M03-1_mozilo.pdf
Countrywide CEO, Angelo Mozilo’s, presentation to The Joint Center for Housing Studies
of Harvard University shows his intentions before the fall of Countrywide. He expands on
all of the goals he desired for his corporation and practices of predatory lending that he
Page 6 of 12
The Social & Ethical Dimensions of the Subprime Mortgage Crisis: An Analysis of Lending and Regulation that Contributed to the
2008 Global Financial Crisis, March 02, 2009 (ams)
USER’S NOTE: This Research Document and all Original Summary Language is the claimed PROPRIETARY PROPERTY of the
Banta Center for Business, Ethics and Society. No replication of the research document as a whole or original summary language
may be made without the express written permission of the director of the Banta Center.
7
stood so strongly against yet became one of the most notorious CEO’s within the subprime
scandal. While his paper supports his mission that he wanted to expand homeownership
following in line with certain politicians, his tactics of doing such clearly bred an unethical
culture in many of his branches thus contributing to the financial crisis in the end. This
paper shows his good intentions and goal for the expansion of homeownership, yet his
actions apparently declared that he would achieve this by any means necessary.
Books
Gramlich, E. M. (2007) Subprime Mortgages: America’s Latest Boom and Bust
This article can be reviewed at: http://www.urban.org/books/SubprimeMortgages/
The Richard B. Fisher Senior Fellow at the Urban Institute and former Federal Reserve
Governor, Edward M. Gramlich, describes the new mortgage market, its products and the
evolution of subprime mortgages. Gramlich describes how the Depository Institutions
Deregulatory and Monetary Control Act of 1980 allowed mortgage lenders to make high
interest loans to, ‚the worst credit prospects of the new borrowers.‛ In addition, he
describes how Community Based Organizations (CBO’s) began receiving funding to
support this growing subprime trend. Giving accounts to the lack of supervision in the
market, he delves into how subprime mortgages opened up the gates to predatory lending
practices, loan flipping and equity stripping. Essentially, this book is important in
explaining to readers what allowed subprime mortgages to occur, thus expanding
individual’s knowledge of how these mortgages and lending tactics contributed to the
financial crisis.
Shiller, R. J. (2008) The Subprime Solution: How Today’s Global Financial Crisis
Happened, and What to do about it.
This article can be reviewed at: http://press.princeton.edu/titles/8714.html
Robert Shiller is the Arthur M. Okun Professor of Economics at Yale University. In his book,
he details that the subprime crisis began with the ‚psychology of the real estate bubble‛
giving an account to the fact that there was a growing increase in ‚dishonesty among
mortgage lenders; increasing greed among securitizers, hedge funds, and rating agencies; or
the mistakes of former Federal Reserve chairman Alan Greenspan.‛ The author often gives
reference to the similarities of the Great Depression and blames the ‚housing bubble‛ as the
major cause of the greater financial trouble that we are in today. He describes this ‚belief in
Page 7 of 12
The Social & Ethical Dimensions of the Subprime Mortgage Crisis: An Analysis of Lending and Regulation that Contributed to the
2008 Global Financial Crisis, March 02, 2009 (ams)
USER’S NOTE: This Research Document and all Original Summary Language is the claimed PROPRIETARY PROPERTY of the
Banta Center for Business, Ethics and Society. No replication of the research document as a whole or original summary language
may be made without the express written permission of the director of the Banta Center.
8
the bubble‛ that allowed lenders to relax standards, lead to no documentation loans and
new mortgage products. The book ends with viable solutions, and offers the thought that it
does not do us any good to point the finger at anyone and in doing so, people and policy
makers will, ‚lose sight of the real solution.‛
Websites
Center for Responsible Lending
http://www.responsiblelending.org/
CNBC – House of Cards
http://www.cnbc.com/id/28892719
National Association of Mortgage Fiduciaries
http://mortgagefiduciaries.com/
PBS – Frontline Homepage: Inside the Meltdown
http://www.pbs.org/wgbh/pages/frontline/meltdown/
Links
American Bar Association Web link
http://abanet.org/buslaw/blt/2008-07-08/nelson.shtml
Nelson, Travis P. ‚Trends in Subprime Lending‛ – Legislation, Litigation, and Enforcement
on the Rise
This article proves that the Subprime market collapse, ‚was a result of two distinct factors:
investors’ continuing search for higher yields and ordinary Americans’ pursuit of the
American dream of home ownership – at whatever cost or terms.‛ In addition, the article
details how Subprime loan products were presented to consumers and offers tips on
prevention for the future.
Consumer Affairs Web Link
Page 8 of 12
The Social & Ethical Dimensions of the Subprime Mortgage Crisis: An Analysis of Lending and Regulation that Contributed to the
2008 Global Financial Crisis, March 02, 2009 (ams)
USER’S NOTE: This Research Document and all Original Summary Language is the claimed PROPRIETARY PROPERTY of the
Banta Center for Business, Ethics and Society. No replication of the research document as a whole or original summary language
may be made without the express written permission of the director of the Banta Center.
9
http://www.consumeraffairs.com/news04/2006/01/predatory_states.html
Bosworth, Martin H. ‚States Battle Feds Over Predatory Lending Laws‛ – Financial Interests
Shower Money on a Corrupt Congress
This article emphasizes the benefits that lenders received as a result of deregulation, and
argues the issue of Congressional leaders receiving favors as a result of extensive lobbying
efforts. In addition, the author highlights consumer advocates such as the Center for
Responsible Lending (CRL), which was an advocate against the ‚Responsible Lending Act‛
saying that the bill would put ‚subprime borrowers at even greater risk of expensive
prepayment penalties, excessive additional fees and outright mortgage fraud.‛
Harvard Kennedy School Web Link
http://www.hks.harvard.edu/news-events/news/any-breathing-borrowing
‚Harvard Retsinas Commentary: The End of the ‘Any Breathing Borrower’ Era‛
The Director of the Joint Center for Housing Studies, Nicolas Retsinas, comments on that the
Community Reinvestment Act of 1977, which set government standards of lending in
communities to people with modest credit. He states that the subprime market had few
regulations and minimal federal oversight. In addition, he claims that this new market
made its money by ‚liar loans‛ proving that this was a trend in the new subprime lending
era, and reminds the reader that brokers and lenders were compensated on the ‚origination
of the loans not on loans repaid.‛ In short, this article supports the idea that the lack of
regulation is a dominant factor in the cause of the financial crisis.
House Financial Services Committee Web Link
http://financialservices.house.gov/predatory.html
‚Predatory and Subprime Mortgage Lending Issues‛ – Congressional Progress on
Minimizing and Improving Subprime Lending
This article argues the fact that there was no legislation or national standard that patrolled
predatory lending and admits that ‚abusive lending practices contributed to the current
mortgage crisis.‛ The article introduces the House of Representatives establishment of The
Mortgage Reform and Anti-Predatory Lending Act of 2007, and details the major provisions
of the proposed legislation.
Naked Capitalism Web Link
Page 9 of 12
The Social & Ethical Dimensions of the Subprime Mortgage Crisis: An Analysis of Lending and Regulation that Contributed to the
2008 Global Financial Crisis, March 02, 2009 (ams)
USER’S NOTE: This Research Document and all Original Summary Language is the claimed PROPRIETARY PROPERTY of the
Banta Center for Business, Ethics and Society. No replication of the research document as a whole or original summary language
may be made without the express written permission of the director of the Banta Center.
10
http://www.nakedcapitalism.com/2007/06/greenspan-opposed-greater-oversight-of.html
‚Greenspan Opposed Greater Oversight of Subprime Lenders‛
This article discusses the Fed’s choice to not invoke the Home Ownership and Equity
Protection Act (HOEPA), which requires subprime mortgage activity to be reported to the
relevant regulators. In addition, the author criticizes the Fed for not requiring banks to
perform random audits. However, the primary focus of the article is its criticism against
Alan Greenspan for not paying more attention to banking activity with respect to subprime
mortgages.
Videos/Media
MSNBC Interview with Mark Zachary – Time: 3:06
http://www.msnbc.msn.com/id/21134540/vp/25462215#25462215
CBS – Confessions of a Subprime Lender – Time: 2:03
http://www.cbsnews.com/video/watch/?id=4264657n%3fsource=search_video
CBS – An Invitation to Fraud – Time: 1:33
http://www.cbsnews.com/video/watch/?id=4831599n%3fsource=search_video
CBS – Countrywide CEO Scrutinized – Time: 2:31
http://www.cbsnews.com/video/watch/?id=3916362n%3fsource=search_video
CBS – Subprime Mortgage Meltdown – Time 1:57
http://www.cbsnews.com/video/watch/?id=2599048n%3fsource=search_video
CBS – Where is the Bottom?
-Video Clip – Time 0:28
http://www.cbsnews.com/video/watch/?id=4667206n%3fsource=search_video
-Full Video on YouTube – Time: 5:58
http://www.youtube.com/watch?v=Kin1fxZAJZE&feature=related
Page 10 of 12
The Social & Ethical Dimensions of the Subprime Mortgage Crisis: An Analysis of Lending and Regulation that Contributed to the
2008 Global Financial Crisis, March 02, 2009 (ams)
USER’S NOTE: This Research Document and all Original Summary Language is the claimed PROPRIETARY PROPERTY of the
Banta Center for Business, Ethics and Society. No replication of the research document as a whole or original summary language
may be made without the express written permission of the director of the Banta Center.
11
House of Cards Slideshow – Origins of the Financial Crisis ‚Then and Now‛ - Time: 18 Slides
http://www.cnbc.com/id/28993790?slide=1
House of Cards Video - Time: 0:44
http://www.cnbc.com/id/15840232?video=1029028275
Frontline: Inside the Meltdown Documentary – Time: 56:23
http://www.pbs.org/wgbh/pages/frontline/meltdown/view/
Exhibits
These legal documents provide an important perspective upon what types of illegal and
unethical corporate practices Countrywide participated in regarding the subprime mortgage
meltdown that became a contributory factor in the financial crisis.
Exhibit A – Stipulated Judgment and Injunction:
The People of the State of California v. Countrywide Financial
Superior Court of California Filed October 20, 2008
http://ag.ca.gov/cms_attachments/press/pdfs/n1618_cw_judgment.pdf
Retrieved from: http://ag.ca.gov/newsalerts/release.php?id=1618
Exhibit B – Plantiff’s Original Complaint:
Mark Zachary v. Countrywide Financial
Texas Southern District Court Filed January 17, 2008
http://www.responsiblelending.org/pdfs/cwd-zachary.pdf
Retrieved from: http://www.responsiblelending.org/issues/mortgage/countrywidewatch/litigation/zachary-v-countrywide-financial-corporation-et-al.html
Page 11 of 12
The Social & Ethical Dimensions of the Subprime Mortgage Crisis: An Analysis of Lending and Regulation that Contributed to the
2008 Global Financial Crisis, March 02, 2009 (ams)
USER’S NOTE: This Research Document and all Original Summary Language is the claimed PROPRIETARY PROPERTY of the
Banta Center for Business, Ethics and Society. No replication of the research document as a whole or original summary language
may be made without the express written permission of the director of the Banta Center.
12
CONCLUDING REMARKS
It is important that individuals understand from this research and analysis how the financial
crisis originated and what factors contributed to the market meltdown, to show the
consequences and results of regulation, deregulation and unethical behavior. Consequently,
understanding the social and ethical dimensions of this crisis can help foster solutions that
deterring this type of financial devastation from occurring again. This is critical because
while the US crisis threatened the livelihood of our own financial market, it also resulted in
severe implications to the global economy. The most reliable solutions will be present in a
strategic balance of effective economic policy, appropriate regulation and oversight, and
strong ethical corporate culture and values.
ADDITIONAL THREADS FOR FUTURE REFERENCE
All of the references below have threads for future reference toward the idea that subprime
lending was a matter of gender and or race differential. In addition, the study by the U.S.
Department of Housing and Urban Development provides an origination of subprime
lending, its expansion and the role of GSE’s and risk-based pricing, while also detailing a
historical perspective of the original intents of the subprime market.
Bond, C. & Williams, R. (2007). Residential Segregation and the Transformation of
Home Mortgage Lending. Societal Forces. Vol. 86 No. 8 pp. 671-696.
Calem, P., Gillen, K. & Wachter, S. (2004). The Neighborhood Distribution of Subprime
Mortgage Lending. Journal of Real Estate Finance and Economics. Vol. 29 No. 4. pp. 393-410.
U.S. Department of Housing and Urban Development.
Unequal Burden: Income and Racial Disparities in Subprime Lending in America. Retrieved
on January 29, 2009 from: http://www.huduser.org/Publications/pdf/unequal_full.pdf
Page 12 of 12
The Social & Ethical Dimensions of the Subprime Mortgage Crisis: An Analysis of Lending and Regulation that Contributed to the
2008 Global Financial Crisis, March 02, 2009 (ams)
USER’S NOTE: This Research Document and all Original Summary Language is the claimed PROPRIETARY PROPERTY of the
Banta Center for Business, Ethics and Society. No replication of the research document as a whole or original summary language
may be made without the express written permission of the director of the Banta Center.
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