jeopardizing hispanic homeownership: predatory practices in the homebuying market

2005 No. 15

Jeopardizing HispanicHomeownership: Predatory Practices in the Homebuying MarketBy Janis Bowdler *

* Janis Bowdler is NCLR’s Housing Policy Analyst. Eric Rodriguez, Director of thePolicy Analysis Center, and Charles Kamasaki, Senior Vice President, providedsubstantive oversight for the completion of this brief. Jennifer Kadis, Editor,provided editorial guidance and Ofelia Ardon-Jones, Senior Design Specialist,prepared the brief for publication. The author benefited from the input of FreddieMac. The content of this paper is the sole responsibility of NCLR.

** The terms "Hispanic" and "Latino" are used interchangeably throughout this briefand refer collectively to Mexicans, Puerto Ricans, Cubans, Central and SouthAmericans, Dominicans, and others of Spanish and Latin American descent. Latinosmay be of any race; therefore, unless denoted as "non-Hispanic," persons ofHispanic origin may be included in both the "Black" and "White" racial categories.Data on Latinos do not include the 2.8 million residents of Puerto Rico.

Introduction . . . . . . . . . . .1

Mortgage Lending in theHispanic Community . . . .2

Barriers to the PrimeMarket . . . . . . . . . . . . . . . .6

Predatory Lending in theHispanic Community . . . .8

Federal Predatory LendingPolicy Debate . . . . . . . . .14

PolicyRecommendations . . . . .15

Conclusion . . . . . . . . . . .17

INSIDEINSIDE

NCLRNATIONAL COUNCIL OF LA RAZA

I S S U E B R I E F

INTRODUCTIONn 2001 the U.S. CensusBureau announced thatthe U.S. Hispanic**

population had grown to13%, making Hispanics thenation’s largest minority. TheLatino population hascontinued to grow rapidlysince that time, and isprojected to reach 15.5% ofthe population by 2010.1 Withthis explosive growth has come

considerable demand forhomes and accompanyingfinancial services, which hasbanking institutions searchingfor ways to engage theunderserved Hispanic market.Despite their efforts, themainstream housing markethas moved too slowly todevelop appropriate andaffordable mortgage productsand outreach services thateffectively meet the needs ofLatino consumers.With

I

mainstream institutions invisible to manyLatinos, other mortgage lenders haveaggressively moved to capitalize on theownership aspirations of Hispanic workers,bombarding Latino media and neighborhoodswith advertisements for mortgages and otherfinancial products and services from theseinstitutions and agents. In this targeted market,where regulation and oversight are poor andconsumers are largely uninformed, the groundhas become fertile for questionable mortgagelending practices known industry-wide aspredatory lending.

For many American families, homeownership isthe most important vehicle for building wealth.This is especially true for Latinos, whose wealthlevels lag behind those of non-Hispanic Whitesby more than ten to one, which is largelyattributable to differences in homeownershipand home equity.2 This issue brief examines thehome mortgage market as it serves, or does notserve, Latino consumers. Where deficiencies inthe market exist, the environment is ripe forpredatory lending – a collection of unethicallending products and practices that erode thehard-earned equity gains achieved byhomeownership.

MORTGAGE LENDING INTHE HISPANICCOMMUNITYThe powerful symbolism and imagery ofAmerican homeownership often stand in starkcontrast to the anxiety-filled and gruelingprocess of purchasing a home. Since mostfamilies do not have sufficient cash to purchasetheir homes, the vast majority borrow themoney from lenders, usually in the form of amortgage loan. Financial institutions thatfinance home mortgages protect theirinvestment by ensuring that the borrower hasthe capability to repay the loan. A would-behomeowner’s measured risk is evaluated in anumber of ways, including income, previouscredit history, and savings. There are two basickinds of home mortgage: prime – reserved forthose with the most favorable credit risk, andsubprime – offered to families who pose agreater risk of nonpayment to the lender.* Ingeneral, prime loans have a standard pricingsystem based on credit scores, income, andsavings; subprime loans, on the other hand, use"risk-based pricing," which uses a number of

* The interest rate and fees offered to mortgage customers are based on the customer’s proposed risk of default, known as creditrisk. These terms are graded on a scale from "A" to "D," or lower, with "A" loans representing the best terms, which areoffered to those who pose the least amount of credit risk. Prime mortgages are "A" and "A-" loans. Subprime loans may alsoinclude "A-," but are mostly "B" -grade loans and below. These loans are generally considered too risky for many mainstreambanks. As a result, subprime loans are offered through mortgage finance companies, some of which are affiliated with banks.The Department of Housing and Urban Development (HUD) keeps a list of subprime lenders, available athttp://www.huduser.org/datasets/manu.html.

factors to determine the likelihood of default,then uses fees and higher interest rates tocompensate the lender for the riskier nature ofthe loan.

Most American homeowners have a mortgageor have been through the mortgage lendingprocess. Millions of Americans apply formortgages each year including increasingnumbers of Latinos. Among all Americanhouseholds in 2003, 68% owned homes.3 Ofthose homeowners, 65% held outstandingmortgages.4 In 2003 approximately 17.5million mortgages were made to homebuyers;nearly 80% of those were loans that refinancedexisting mortgages.*

While the overall homeownership figures forLatinos may be modest relative to Whites, thenumber of Latinos entering the mortgagemarket each year continues to swell. Less thanhalf of Latino households nationwide own ahome, but of the more than five millionHispanic households who owned their home in2003, 71.6% had an outstanding mortgage.The number of Hispanic families closingpurchase mortgages was 185% higher in 2002than in 1993.5 Latinos are increasinglyinfluencing the shape and size of the U.S.mortgage lending market.

DISPARITIES IN THE MARKETIt appears that Latino consumers areincreasingly attractive to mortgage lenders;however, significant disparities exist in the types

of loans they are getting compared to Whites.They are more likely than Whites to finance ahome purchase with an expensive mortgageproduct and are less likely to refinance, whichoften can lower the cost of a mortgage.Subprime mortgages, and those insured by theFederal Housing Administration (FHA), both ofwhich are more expensive than primemortgages, accounted for more than 40% ofHispanic purchase mortgages and nearly aquarter of refinance mortgages in 2002. ForWhite families these products account for 18%of purchase mortgages and less than one in tenof refinance mortgages.6 Disproportionatelyhigh denial rates among Hispanic primemortgage applicants also suggest that the primemarket is not meeting the needs of Hispanicfamilies. It is likely that some of the disparity isattributable to demographic differences such asage, income, and immigration status; however,fair lending research has demonstratedconsistently that demographic factors alone donot entirely explain the inconsistent approvaland denial rates discussed above.7 For example,research pairing Hispanic and White testerswith similar financial information found thatthe Hispanic buyers were less likely to receiveassistance with financing and downpaymentassistance and were told they qualified for lowerloan amounts than their White counterparts.8

Other research estimates that as many as one-third to one-half of all subprime borrowerscould have qualified for prime credit.9

* Unless otherwise stated, estimates on the number of mortgages are based on figures publicly disclosed in accordance with theHome Mortgage Disclosure Act (HMDA). Most depository and mortgage finance institutions are required to disclose certainattributes of their mortgage business, including number of applications taken, approved, and denied, and their racial, ethnic, andgeographic representation. For more reporting information go to http://www.ffiec.gov/hmda/reporter.htm.

In contrast to Hispanics’ growing participationin the purchase market, there has not beensimilar growth in the refinance market.

Refinancing a mortgage isoften an opportunity forfamilies to apply for amortgage with a lowerinterest rate, or cash outequity for home repairs thatlead to an increase in homevalue. When Hispanicfamilies do refinance, they aremore likely than their Whitecounterparts to refinancewith a subprime loan. Thisdisparity was true whencontrolling for income, evenincreasing as incomesincreased.10

IMPACTInefficiencies in the mortgagelending market directlyimpact the ability of Latinofamilies to build and maintainwealth. Families who financetheir home with mortgageproducts more expensivethan warranted by theircredit risk pay more of theirmonthly payment towardinterest and fees, rather thanthe principal balance, whichis the only way to buildequity. This leakage ofincome and assets erodes theachievements of increasedhomeownership. In somecases families may beexposing themselves to an

increased risk of foreclosure when they opt forexpensive subprime products with certain

Federal Housing AdministrationMortgages insured by the Federal Housing Administration (FHA)have been a mainstay of minority mortgage capital, servingfamilies who would not otherwise qualify for a mortgage due toinsufficient cash for a 20% downpayment, poor credit, or otherbarriers. One in five Hispanic families with a mortgage in 2003had an FHA-insured mortgage. FHA products, however, areexpensive and financially risky. Several studies have pointed tothe loose regulatory structure of FHA, overreliance on under-regulated mortgage brokers and finance companies, and highLoan-to-Value ratios (LTVs) as reasons for the high foreclosurerates of FHA mortgages.* At the close of 2003, HUD reportedthat more than twice as many FHA mortgages were inforeclosure than prime mortgages. Of the top 50 FHAoriginators from 2003, ten were also on HUD’s 2002 SubprimeLender list, accounting for more than a third of the loansoriginated by those lenders, and nearly three out of four loansare not subject to CRA or HMDA

* For more information see Bradford, Calvin, The Two Faces of FHA: A Case of GovernmentSupported Discrimination Against Minority and Racially Changing Communities. Chicago, IL:Chicago Fair Housing Alliance, 1998; Immergluck, Dan, Hyper-segmentation and theExclusion in Financial Services in the U.S.: The Effects on Low-Income and Minority Neighborhoods.Grand Rapids, MI: Grand Valley State University, July 23, 2003. See also storiesregarding "fly-by-night" mortgage brokers that take advantage of FHA’s looseregulatory structure: Killingsworth, Inez, "FHA: Turning an American Dream into aNeighborhood Nightmare," Shelterforce Online, No. 124, July/August 2002; Harney,Kenneth, "FHA Seeks Property "Flip" Crackdown," RealtyTimes, November 5, 2004; Whatto Know When Buying Your First Home: Avoid ‘Property Flipping’ Scams. New York, NY: SouthBrooklyn Legal Services, available at http://www.sbls.org/forecfs2.htm.

Table 1: Analysis of Top 50 FHALenders, 2003

HUD Institutions withSubprime CRA/HMDA List Requirements

Number 10 11

Number of Loans Closed 176,737 134,744

Percent of Total Loans Closed 34.8% 26.5%

Source: www.hud.gov

features, such as excessiveinterest rates, high Loan-to-Value (LTV) ratios, andsubprime loans.

A driving force behindmaking homeownershipavailable to all who qualify isits ability to generate wealth.Home equity accounts forapproximately two-thirds ofHispanic families’ net worth,and is likely to be the onlyappreciating asset the familyowns.11 Hispanic familieswho pay too much for theirmortgage, or do not accesshomeownership despite theirability to qualify, lose anopportunity to build wealth.The example to the right,Prime vs. Subprime,demonstrates how an interestrate even slightly higher thannecessary can be a serioussetback for families,especially those shopping inhigh-cost markets.

Foreclosure is a dangerouspotential consequence ofputting families in loans thatare more expensive thanrequired by their actualcredit risk. According to theJoint Center on Housing,there was a 3.6% growth inhomeownership compared toa 335.6% increase in numberof foreclosures per home

Prime vs. SubprimeTable 2 demonstrates the economic impact on a family whoobtains a "prime" versus a "subprime" mortgage loan. Thescenario assumes the family purchases a modest $130,000 homewith a 3% downpayment, which is common among manyaffordable conventional and FHA products, and a standard 3%closing cost. The Federal Reserve Bank found there was a 3.8percentage point difference between the typical mortgage ratecharged on a prime loan and a subprime loan between 1998 and2001; this example uses a conservative three percentage pointdifference. Finally, it also assumes the subprime borrower wouldhave to pay higher points. Points are fees borrowers can pay atclosing to "earn" certain loan features, such as not having aprepayment penalty, using a mortgage broker, or financingclosing costs. In the example below, the borrower is financingpart of the fees due at closing and would likely pay a point forthat service.

The result of the scenario is that the subprime borrower wouldpay $285 more per month – a sizeable amount for a low-incomefamily. Perhaps more importantly, the family loses anopportunity to build wealth. The subprime borroweraccumulates 50% less equity than the prime borrower. Asubprime lender or mortgage broker would likely advertise thesubprime loan’s low closing cost (notice that the closing costsare the same, but the fees are financed into the loan in the caseof the subprime loan). Such features come at a cost. A housingcounselor would likely advise a family to wait and save additionalfunds in order to obtain the benefits of the prime loan.

Table 2: Affordability Scenario

SCENARIO: PRIME SUBPRIME

❚ Purchase Price: $130,000❚ Cost to close: $3,783❚ Downpayment: 3%❚ Loan Type: 30-year fixed

Interest Rate 6% 9%

Points Paid 1.0 2.5

Fees Financed $0 $3,000

Monthly Payment $844 $1,129 (including mortgage insurance)

Equity in five years $12,658 $6,218

between 1980 and 2002.12 On average, a familyloses $7,200 in net worth during a foreclosure,and the community stakeholders, including thelender, stand to lose approximately $73,300 perFHA foreclosure and $26,600 per conventionalforeclosure.13 Despite data limitations, severalcomprehensive case studies report similarfindings that draw connections betweensubprime loans and certain loan characteristicsand increased foreclosures in minority and low-income neighborhoods. These case studiesfound that increases in foreclosure followincreases in subprime lending, foreclosures areconcentrated in minority and low-incomecommunities, subprime loans aredisproportionately represented amongforeclosures, and high interest rates and Loan-to-Value (LTV) ratios are common in loans inforeclosure.14

BARRIERS TO THE PRIMEMARKETStructural impediments inherent in themortgage market hinder it from better servingpotential Hispanic homebuyers. More thaneconomic or cultural barriers, although thesemay be more prevalent in some areas thanothers, the manner in which the industry hasstructured its day-to-day business activities,such as where to locate bank branches, theirmanner of outreach, and underwriting tools,create barriers for Hispanic families trying toaccess appropriate mortgage products. As aconsequence, many families find themselves inhigh-cost loans unwarranted by their actual risklevel or are outright denied financing. Policiesand practices in the prime mortgage lendingmarket, described in more detail below,translate into ways in which Hispanic

homebuyers and owners are left open topredatory lenders. Specifically:

◗ Outreach. The financial institutions thatoffer prime mortgage products are beingoutperformed in Hispanic communities bysubprime lenders and mortgage brokers, asevidenced by their gaining market share. Inboth the purchase and the refinancemarkets, the proportion of Hispanicborrowers’ total applications taken bysubprime lenders compared to primelenders was nearly twice that of Whites. Insome cases this is due to the physicalabsence of prime institutions in Hispaniccommunities, but often it is a result of notusing effective outreach techniques thatresonate with potential Hispanichomebuyers.15 Subprime lenders andmortgage brokers have increased marketpenetration by hiring bilingual staff,translating materials, and spendingindividual time with the families. Familiesare unable to shop effectively when they donot have access to all the financingopportunities for which they qualify.

◗ Commission-Based Policies. Themortgage market is locally driven, largelydependent on the local branch managersand loan officers whose compensation istypically commission-based and dependenton the size and number of loans processed.In this context, lenders have a disincentiveto serve low- to moderate-income familiesapplying for modest-sized mortgages, andwhose applications may take extra time dueto downpayment assistance or other specialprocessing needs. Similarly, affordable

products and initiatives created at theheadquarters may be difficult to utilize atthe branch level, without which theyprovide little value to families.

◗ Workforce Diversity. Placement ofbilingual and bicultural staff throughout afinancial institution is critical to servingHispanic families well. Certainly somefinancial institutions have made the hiringof bilingual and bicultural staff at theirretail locations a priority; however, othersstill rely on centralized Spanish-languageservices, such as online or telephoneservices, as a substitute for local personnel.Further, while some institutions haveimproved diversity at certain branches,they lack diversity throughout the rest ofthe organization, particularly at the upperechelons. Of the 40 commercial banksranked among Fortune 1000 companies in2003, only eight had Hispanic boardmembers and four had Hispanic executiveofficers.16 The absence of diversity amongboard members and executive staff almostcertainly inhibits identifying, adopting, andinvesting in more effective Latino outreachstrategies.

◗ Credit Scoring. Hispanics are morelikely than Whites to have credit scoresbelow 620 – the generally accepted cutoffline between prime and subprime. Thefactors used in the calculation heavilyweight the borrowing activities of largelymiddle-class Americans, many of whom donot fit the borrowing activities of low- tomoderate-income Hispanic families,creating a negative bias against otherwise

creditworthy Latinos. Hispanic families aremore likely than other families to have adeficit of information on which to base ascore, resulting in thin or no credit filesand low credit scores. For example, creditscores do not take into account regularpayments such as rent payments, utilitybills, cell phone accounts, or evenremittances, which are likely to revealsignificant information about an Hispanicfamily’s spending and payment habits. Onthe other hand, the formulas negativelyscore activity from payday lenders, checkcashers, and subprime lenders, which arefrequented by Latinos. There are still othercomplications, such as negative informationhaving immediate impact while positivebehaviors take much longer to make anoticeable difference on a score,institutions sometimes reporting only thenegative information and not the positive,and reports often containing errors, whichare not easily corrected.17

◗ Automated Underwriting (AU). AUhas benefits, but it also exacerbates theproblems inherent in credit scoringsystems. AU removes discriminatoryjudgments that could negatively affectLatinos who are undeniably eligible forprime products. However, these systemstend to be rigid, and thus often relegatecreditworthy Hispanics with thin creditfiles or minor credit blemishes to thesubprime market, even though a morethorough review would demonstrate theireligibility for prime loans. Manycompanies seek ways to make their

processing systems more flexible, includingalternative credit scoring calculations andthe incorporation of nontraditional creditin their system, while maintaining itsbenefits (e.g., speed, efficiency, reducedbias). However, the efficacy of thoseefforts is unknown. For example, there arestill questions as to whether products thatmake use of these innovations are priced ata higher risk level than products that usetraditional credit scores. Industryadvocates argue that this technology allowslenders to spend more time with thosemortgage candidates who need humanjudgment, though there is evidence thatloan officers spend their extra timeprocessing additional underwriting-friendlyloans instead. Consumer and industryadvocates agree that automatedunderwriting systems must be revised on aregular basis to remain current andaccurate; however, there needs to be moreclarity about how often this happens, thecontent of the revisions, and transparencyof the factors used to measurecreditworthiness within these "black box"systems.

◗ Information and Awareness. Withoutproper information about the homebuyingprocess, many Latino families – as many asa million in 200218 – believe that they areunable to purchase a home or are unawareof their ability to qualify for a moreaffordable prime product. Research showsthat Hispanic families are not offered asmuch information on their financingoptions and available affordable loan

products as similarly situated Whitefamilies during the homebuying process.19

Other research reports that immigrantfamilies’ view of American financialinstitutions is influenced by the quality oftheir home country’s financial system.Thus, a poor-quality system in a family’scountry of origin may leave them leery ofAmerican institutions.20 Further, becausemany first-time Hispanic homebuyers arealso first-generation homebuyers – and onein ten first-time homebuyers is foreign-born – many Latinos do not benefit fromadvice on the homebuying process passedthrough family members or neighbors as iscommon in other communities.21

PREDATORY LENDING INTHE HISPANICCOMMUNITYThere is an important role for the subprimeindustry in delivering homeownershipopportunities to those considered "too risky"for conventional mortgage loans, for example,those with credit blemishes. However, thesubprime market is where predatory lendersthrive, and the growth of the subprime marketalong with the rise in subprime lending toLatinos raise serious concerns about the scopeof predatory lending in the Hispaniccommunity. The Federal Reserve calculatedthat the value of subprime mortgageoriginations grew 26% annually from 1994 to2000, and the subprime share of market shareexpanded from 5% to 13% during the sametime period.22 There is also some evidence thatsignificant numbers of individuals who qualify

for prime loans, and those who maintain a lowrisk of default, have subprime loans. Moreover,there is ample research documenting theconcentration of this growth among minority,elderly, and low-income communities,populations that have been traditionallyunderserved by prime mortgage lendingservices.23 Among Hispanic borrowers, theshare of subprime purchase mortgageoriginations of their total purchase originationsincreased by 1,525%, compared to a 1,080%increase in White borrowers’ share of subprimepurchase mortgages, between 1993 and 2002.Advocates commonly point out that while notall subprime loans are predatory, the majorityof predatory lending exists within the subprimemarket. Subprime lending is more easilyidentified and measured; predatory lending iscontextual and often difficult to pinpoint.

PREDATORY LOANS AND

PRODUCTSPredatory features are usually subtle anddifficult to define because the indicators arecontextual, depending on the situation of theindividual borrower. Predatory loans ofteninclude the following characteristics:

◗ High Interest Rates: Interest rateshigher than warranted by a borrower’scredit risk.

◗ Packing:The financing of fees and secondmortgages into the mortgage, oftenwithout the borrower’s awareness.

◗ Mandatory Arbitration Clauses:Forcing borrowers to give up their right tolitigate in the case that something is wrongwith their loan.

◗ Asset-based Lending: Lending based onthe value of the asset rather than on theborrower’s ability to repay the terms of the loan.

◗ Balloon Payments: A short-term, fixed-rate mortgage which requires that the fullbalance be paid at the end of the term,often as short as five to seven years.

◗ Prepayment Penalties: A fee added to aloan as a disincentive to more rapidrepayment or refinancing within a certainamount of time.

In addition to these often predatory features ofloans, there is an array of dubious products onthe mortgage lending market that are oftenused in a predatory manner. Abuses of theseproducts often slip beneath the regulatory radarbecause they are made by locally-driven,highly-unregulated entities whose sole purposeis to target vulnerable and unsophisticatedborrowers who are unlikely or unable tocomplain. Like other loan products andcharacteristics abused by predatory actors,these products are created for a specificclientele, but are often misused to scamunsuspecting borrowers. Product scams thatare prevalent in Latino communities include:

◗ Contract for Deed. Also called "LandContract," this product allows a buyer topay the seller directly, or through anescrow account, based on a writtencontract that stipulates that after a certainnumber of payments the buyer is eligible topurchase the property. Theoretically, thebuyer provides a downpayment and makespayments, typically for several years, atwhich time a balloon payment is due. In

theory, the buyer then pays the balloon viaa standard mortgage and thereby assumesthe property. This product may be usefulduring informal selling situations such asfamily member to family member.However, buyers have little control overthe property while making payments tosellers, they do not own the asset, receiveno tax benefits, and are excluded fromtypical homebuyer protections. Many findthemselves vulnerable to eviction andunable to recoup their downpayment andrent investment for even a late or missedpayment. This is especially common amonglimited-English-speaking communities, inthe U.S.-Mexico border region known asthe Colonias, and among undocumentedfamilies trying to purchase a home.Approximately 456,000, or 12.5%,Hispanic owners have a Contract for Deedmortgage.24

◗ Interest-only Loans. This is not aproduct, per se, but an option on amortgage in which a buyer makes paymentsonly on interest as a way to reduce monthlyexpenses, and is intended for borrowerswho expect their income or home value, orboth, to increase dramatically in a veryshort period of time. Few buyers,however, realize that they are not paying offthe loan principal. This option is oftenattached to an Adjustable Rate Mortgage(ARM), a mortgage in which the interestrate changes according to the marketplaceor other factors, with a low interest rate inthe first few months of the loan, which isattractive to families trying purchase a

home quickly. However, changes in theinterest rate could increase the paymenttwo percentage points every six months upto a cap of 9.875% after the introductoryperiod.25 Depending on how quickly thehome value does or does not appreciate,buyers may find themselves owing more ontheir property than the home is worth,called an "upside down mortgage," andwithout any equity. A recent survey ofARMs revealed that of those customerswho had interest-only loans, the majoritywere less educated, young adults, andLatinos.26

◗ Mobile and Manufactured Housing.Though a common affordable home choiceof families in rural and immigrantcommunities, most mainstream lendinginstitutions will not finance a mortgage fora mobile or manufactured home. In lieu oftraditional financing, most families must gothrough dealer financing similar to that ofan auto loan. A report by the ConsumersUnion Southwest Regional Officeinvestigated charges of fraud and deceptionsurrounding mobile and manufacturedhousing purchases in Texas and foundinterest rates between 9% and 13% higherthan normal rates, miscellaneous fees(many of which were financed),prepayment penalties, and unnecessaryinsurance add-ons. Borrowers alsocomplained of bait-and-switch scams; theywere delivered a mobile home differentfrom what they ordered, with few viableoptions for legal recourse. Several industrywhistleblowers verify that Hispanics, who

constitute almost half of Texas’manufactured housing population, arespecifically targeted by dealers who oftenmake verbal promises in Spanish that aredifferent than the terms contained in thecontract, which is in English.27 Nearly onein ten (9.7%) Hispanic homeowners livesin manufactured housing or mobilehomes.28

Although not discussed here, there are otherproducts that are easily abused, such as "gift"downpayment programs, Adjustable RateMortgages (ARMs), and Home Equity Loans.In the absence of legitimate mortgage productsfor Individual Tax Identification Number (ITIN)holders, priced according to actual risk similarto legitimate conventional and subprimeproducts, families with ITINs are especiallyvulnerable to being steered toward a dubiousproduct.*

Since most predatory lending tactics and loanfeatures are legal, it is difficult for homebuyersand owners to find legal recourse. Investigationand prosecution of predatory loans is time-consuming and expensive, and requires closeanalysis of loan documents, interviews withaffected parties to investigate lenders’disclosures, or evidence of widespread andsystemic discrimination by an institution.

PREDATORY BEHAVIORBeyond the features of the loan or product,predatory lending also manifests itself in theLatino community through a variety of abusivetactics by lenders and brokers. For example:

◗ "Push" Tactics. Push tactics areaggressive marketing techniques wherebyconsumers do not seek but areaffirmatively offered credit or loanproducts by a loan officer, broker, orfinance company, often sold via door-to-door sales, mail, or phone solicitation.Such solicitations are often accompanied byattractive characteristics that disappearwithin months of closing, such as low or nointerest in the case of credit offers ordeferred payments in the case of homeimprovement deals. In the purchasemarket, predatory advertisers seek outunderserved and less sophisticatedborrowers, promising to qualify them for ahome loan, regardless of theircircumstances (bad credit, no cash,previous foreclosure). In the refinancemarket, solicitors target vulnerablehomeowners, such as the elderly or thosewho appear financially troubled, and whohave accumulated equity in their home.Subprime loan products are even moreconfusing in this context – fees charged on

* As the immigrant population continues to grow, so does the demand for ITIN mortgage products. Mainstream lenders areslowly realizing the market potential. However, in the meantime, ITIN borrowers are at the mercy of those lenders that arewilling to make the loans, which are perceived as high-risk because of uncertainty surrounding immigration status. Pilotprojects experimenting with reasonably-priced ITIN products have been successful. The quality of lending to ITIN consumerswill continue to be inconsistent until more standardization is introduced via mainstream lenders, mortgage insurance providers,and the secondary market.

a loan are easily hidden, and informationabout the financial institution and loanterms are not publicly displayed forcomparison purposes as they are for primeloans.29 These examples are particularlyproblematic in immigrant communitieswhere families have little experience withthe market.

◗ Independent Third-Party Brokers.Many Hispanic families who mightotherwise be intimidated by thehomebuying process rely on independentthird parties, such as real estate agents,mortgage brokers, appraisers, andtranslators, to help them overcome thebarriers to prime services discussed in theprevious section. Many of these agentsprovide valuable services that connectfamilies to mainstream financial services.Unfortunately, others prey upon vulnerableconsumers who are trying to navigate thehomebuying process, especially those whoare limited-English-speaking.30 In somecases these unscrupulous agents steerfamilies to dubious products and high-costloans, or push them to unnecessarilyrefinance their home or automobile. Thefamily unknowingly and blindly trusts theagent because of their cultural connection.

◗ Mortgage Brokers. Mortgage brokersare independent third-party agents who sell

mortgages from a variety of sourcesincluding depository institutions, mortgagecompanies, and wholesale lenders.Theadvantage of mortgage brokers is the widevariety of loan products to which they haveaccess. The disadvantage is that they havean economic interest in pushing the cost ofa loan higher to produce a higher fee forthemselves, called a Yield Spread Premium(YSP). In 2002, mortgage brokersoriginated approximately two-thirds of thenation’s mortgages and between 65% and80% of the nation’s non-conformingmortgages* (this market share is higher inminority communities);31 approximately45% of Hispanic purchase mortgages, and25% of Hispanic refinance mortgages, arenon-conforming. Many finance companies,most of which are not subject to HomeMortgage Disclosure Act (HMDA) datareporting requirements or CommunityReinvestment Act (CRA) exams, prefer tomarket their mortgage products throughbrokers to avoid the expense of maintainingretail branches.32 In addition, the one-on-one approach adopted by many brokerswho visit the homes of their clients, oftenconducting the closing process there, isattractive to many Hispanic families whomay be intimidated by the formal,mainstream mortgage system or whoappreciate the personal attention.

* Mortgages that are typically not bought by Freddie Mac or Fannie Mae are called "non-conforming mortgages." This categoryincludes FHA, subprime, "A-," and "Alt-A" mortgages. "Alt-A" mortgages are "A" level risk, but with nontypical borrowercharacteristics such as nontraditional credit or stated income.

Federal Oversight

Federal oversight of financial institutions and mortgage lenders is complex and confusing. For thosewho wish to file a complaint against a financial institution, the process is unclear. In many cases,consumers are unsure of what actions to take, if any, and what happens to their complaint once filed.That said, there are a number of federal laws and regulations that are designed to protect consumersand shape practices in the marketplace. The principal law used by advocates and governmentagencies to combat abusive practices is the Home Ownership and Equity Protection Act (HOEPA).This legislation, passed in 1994 as an amendment to the Truth in Lending Act (TILA), was recentlyexpanded by the Federal Reserve and includes thresholds that define high-cost loans for whichadditional disclosures, restrictions, and consumer protections apply.*

These laws notwithstanding, enforcement has been limited. Except for one formal enforcementaction taken by OCC, there has been no other formal action against predatory lenders by federalregulators. The FTC, which is charged with enforcing consumer protection regulations among non-depository institutions that are not regulated by the other regulatory agencies,** has filed only17 cases since 1998.*** HUD instituted Credit Watch and Appraiser Watch to crack down on abusesmade by FHA-approved lenders through FHA purchase and refinance originations, but the overallimpact of the programs is unclear as the number of FHA foreclosures continues to increase.****

DOJ filed only nine cases involving discrimination by lenders between 2000 and January 2004.*****

Section 8 of the Real Estate Settlement Procedures Act (RESPA), which prohibits "kickbacks" forreferrals and only allows fees for bona fide services performed, is the main law that regulatesmortgage brokers at the federal level. Violations of this law are not as likely to be caught whenmortgages are closed through less-regulated mortgage finance companies and the absence ofHMDA and other data requirements make it difficult to demonstrate unlawful patterns ofdiscrimination. Further, the purpose of the regulatory agencies is to monitor certain lendingactivities; they are not designed to conduct routine investigations that would uncover suspiciouspatterns and practices.

* In December 2001, the Board issued new rules expanding the reach of HOEPA. Under the new rule, the threshold for a "high-cost"mortgage is eight percentage points above Treasury rates or with total points and fees over 8% of the loan amount; these loans requireadditional disclosure, prohibit lending without regard for borrower’s ability to make payments, limit prepayment penalties, andprohibit balloon payments (for loans made for five years or less) and negative amortization.

** Several federal agencies that play some role in enforcing predatory lending legislation or regulations are: Federal Deposit InsuranceCorporation (FDIC), Office of the Comptroller of the Currency (OCC), Office of Thrift Supervision (OTS), National Credit UnionAdministration (NCUA), Board of Governors of the Federal Reserve System (the Board), Federal Trade Commission (FTC), Departmentof Justice (DOJ), and the Department of Housing and Urban Development (HUD). Five of these agencies are financial regulators (FDIC,OCC, OTS, the Board, and NCUA) that are responsible for monitoring the lending activities of their respective institutions.

*** General Accounting Office, Consumer Protection: Federal and State Agencies Face Challenges in Combating Predatory Lending. Washington, DC:Special Committee on Aging, U.S. Senate, 2004.

**** "Bush Administration Announces Additional Protections For Homebuyers To Curb Predatory Lending," Press Release, U.S. Departmentof Housing and Urban Development, Washington, DC, August 9, 2002; "Bush Administration Announces ‘Appraiser Watch’"- NewProtections For Homeowners," Press Release, U.S. Department of Housing and Urban Development, Washington, DC, July 18, 2002.

***** See specifically: United States v. Associates National Bank; United States v. First National Bank of Dona Ana County; United States v. Northern TrustCompany; United States v. Shawmut Mortgage Company; United States v. Fidelity Federal Bank; United States v. Fleet Mortgage Company; United Statesv. Security State Bank; United States v. Long Beach Mortgage Company; and United States v. Mid America Bank, fsb.

However, unlike lenders, brokers have novested interest in the viability of a loan andhave nothing to lose if a borrower goes intodefault. Inconsistent state licensingrequirements and limited federal oversightleave brokers highly unregulated andunaccountable to consumers.

◗ Product Steering. Several studies havedetermined that between 35% and 50% ofsubprime borrowers could qualify for A orA- loans, such as those sold by primebanking institutions.33 Other researchhighlights the increase in prime-subprimelending disparities among high-incomeneighborhoods as compared to low-incomeneighborhoods. The evidence demonstratesthat Latinos are more likely than theirWhite counterparts to finance through asubprime lender and, somewhatcounterintuitively, that this disparityincreases as income increases.34 Thus, it isreasonable to assume that a significantnumber of Latino families have financedtheir mortgage using products pricedhigher than their risk level warrants.*

FEDERAL PREDATORYLENDING POLICY DEBATECurbing predatory mortgage lending hasincreasingly become a national priority. The

policy debate centers around three criticalissues: the extent to which federal law shouldpreempt existing state lending laws; thethresholds and definitions that trigger addedconsumer protections; and who in themortgage process can be held liable. Manyindustry representatives maintain that existinglaws are adequate and need only to be morevigorously enforced, and that the mortgagemarket will be more efficient and cost-effectivewith a uniform federal standard. Mostconsumer advocates point out that manypredatory tactics currently are not illegal underfederal law, thus improved standards must bepassed, and that states should be free to enactstronger legislation if they choose. Individualstates have found federal law to be insufficientand have enacted stronger laws to augmentborrowers’ protections.

There are number of points upon which bothmainstream industry representatives andconsumer advocates agree. For example, mostagree that the "bad actors" must be driven outof the mortgage system and that improvedenforcement of existing laws would be a step inthat direction. In some cases there is evenagreement on the need for stronger consumerprotections. Opinions among stakeholdersdiverge, however, on how these objectivesshould be accomplished. For instance, industryofficials argue that a patchwork of state lawswith varying restrictions, liabilities, anddefinitions drives up the cost of credit or limits

* There is also significant cause for concern over industry practices of referring "up" or "down." For example, if a Latino family’sfirst encounter with a financial institution is with its subprime lending arm, it is reasonable to assume that even if they wouldqualify, the family would not be referred "up" to the prime lending arm. Similarly, a low-income family may approach aninstitution’s prime arm, only to be referred "down" to the subprime arm despite qualifying for prime products because they aredifficult to serve (due to downpayment assistance requirements, or use of nontraditional credit, for example).

its availability to consumers who could benefitfrom such loans. Consumer advocates point tothe inactivity of federal regulators and thelimited scope of federal law as evidence of aninefficient federal enforcement system.*

Moreover, stakeholders disagree over whoshould be held liable for a predatory loan.Advocates argue for "assignee liability." Thismeans that the party who purchases a predatoryloan on the secondary market, therebyproviding the funds for a loan to be made,should be held liable. While views vary amongindustry representatives, most feel that assigneeliability will put undue pressure on thesecondary market, causing funders to disengagefrom the mortgage market, thereby drying upcredit. Finally, there is disagreementconcerning what loan characteristics triggeradditional federal protections. The HomeOwnership and Equity Protection Act(HOEPA),35 the main federal law regardingpredatory lending, sets a series of criteria, ortriggers, based on the interest rates and feesthat when met invoke a set of additionalprotections, such as disclosures and bans oncertain features (e.g., prepayment penalties andmandatory arbitration clauses).36 However,HOEPA covers only a fraction of subprimeloans; the Federal Reserve estimates as little as5%, though industry advocates suggest it maybe as high as 26% to 38%.37 Industryrepresentatives maintain that lowering thetriggers will result in the reduction of

mortgages available to credit-impairedborrowers. (See Federal Oversight on page 13).

POLICYRECOMMENDATIONSHispanic families want what other homebuyersexpect – a fair and equal opportunity to get the"best deal" possible on their home mortgage.The prime mortgage market must performbetter, work to more effectively assess risk, anddeliver their products directly to qualifiedLatino families. Those Latinos who findthemselves in the subprime market forwhatever reasons need adequate legalprotection from predators who seek to stripthem of assets, equity, and wealth. No minorityhomeownership policy agenda can be completeor fully effective without addressing theincidence of predatory lending in minoritycommunities. For Latino homebuyers, thepriority is not whether these protections existat the federal or the state level, but that theprotections are meaningful and the market isserving them adequately. Currently, manypredatory practices are legal, either because feethresholds are not inclusive enough or becauselegitimate mortgage products and features arebeing abused. As Congress grapples with thesechallenging issues, lawmakers should do thefollowing:

◗ Increase consumer protections thattarget abusive practices. Congress

* Approximately 26 states have enacted anti-predatory lending laws, presenting logistical challenges to lenders; however, it was acoalition of the 50 state attorney generals which prosecuted the groundbreaking predatory lending lawsuit against Household,Inc.

must increase protections that accuratelytarget abusive practices in both thepurchase and refinance markets. Remediesinclude: limiting excessive fees byincorporating all fees in the definition of ahigh-cost loan under HOEPA; prohibitingunnecessary add-ons that provide no addedhome value such as single premium creditinsurance, especially in high-cost loans; andholding brokers and financial institutionsaccountable for their role in structuring adeceptive or abusive loan at various pointsin the purchase process. Further, federallegislation should only improve, notweaken, available consumer protections.Currently, states’ laws are the onlymeaningful safeguards available to families,and reducing them without meaningfulfederal legislation in place would be a stepbackward in all Americans’ right to fairlending and equal access to credit.

◗ Stop "referral down" practices. Aspart of financial institutions’ regular CRAand fair lending exams, financialinstitutions should be required to submittheir policies and procedures for referringcreditworthy customers "up" to theirprime lending business. If such a policy isnot in place, it should count against theirfinal exam score. Moreover, for thoseorganizations not subject to CRA orregular fair lending exams, the FTC mustregularly investigate referral patterns byrequiring institutions to submit theirpolicies and procedures at their request toensure that families are getting the bestterms for which they qualify.

◗ Federal regulation and monitoringof mortgage brokers. Congress has anobligation to create a regulatory body, oramend an existing agency’s charter, tomonitor mortgage brokers. As the mainparty interfacing with customers,explaining loan terms, providingdisclosures, and securing the loan closing,more oversight is warranted to ensuresound and equitable activities andperformance. Congress can decrease theincentive to brokers to push families intohigher-cost loans by accounting for YSPs inthe calculation of a high-cost loan. Finally,mortgage brokers should be subject toHMDA data reporting requirements,including the type of institution for whichtheir loans are packaged. Suchtransparency will allow the public to betterunderstand the impact of mortgage brokerson the homebuying market.

◗ Increase access to the mainstreammortgage market. There are a numberof steps Congress can take to improveaccess to the mainstream mortgage market.First, standardization of the subprimemortgage market is critical to ensuring thatconsumers can find and compare the realcosts of a mortgage from lender to lender.Congress must empower and requireagencies to incorporate mortgage financecompanies into the regulatory oversightsystems and enforce existing legislation.Subprime lenders can make their businessmore transparent by providing a publiclisting of terms and fees, as is done forprime products. Second, Congress mustsupport housing counseling agencies that

prepare low- and moderate-income familiesfor homeownership by increasingappropriations and reducing agencies’regulatory barriers to self-sustainingrevenue. Finally, vigorous, routine, andindependent investigations of all mortgagelenders are necessary to regulate theirlending, as well as to better understand thepredatory lending market. Further, itshould be clear to consumers which agencyis responsible for receiving andinvestigating their complaints, andregulators should be encouraged tocoordinate efforts if complaints aresubmitted to the wrong agency.

CONCLUSIONPredatory lending is an indicator of marketfailure in the mortgage lending industry; toomany consumers, including a disproportionatenumber of minority families, are unable to

access the mortgage products that best meettheir needs. To combat it effectively,policy-makers, advocates, and financial servicesindustry representatives will have to work inconcert to implement new legislation backedby tough enforcement that will achieve effectivebest practices and the development of newlending models. While the aboverecommendations focus on national policysolutions, industry can also take steps to curbabusive lending in Hispanic communities byimproving outreach to the community,diversifying their workforce, reevaluatingautomated underwriting systems, and creatingflexible prime products that meet the needs of"mortgage-ready" families. Latinos are thenation’s largest minority and, as such, can nolonger be considered a niche market. Rather,those involved in the homebuying market mustincorporate the needs of the Latino communityinto their core business plan, delivering thequality financial services that Latinos deserve.

1. U.S. Census Bureau, 2004, "U.S. InterimProjections by Age, Sex, Race, and HispanicOrigin,"http://www.census.gov/ipc/www/usinterimproj/.

2. Kochhar, Rakesh, The Wealth of HispanicHouseholds: 1996 to 2002. Washington, DC: PewHispanic Center, 2004.

3. U.S. Housing Market Conditions, November 2004,Department of Housing and Urban Development.

4. U.S. Census Bureau, American Housing Survey,2003.

5. Ibid.

6. Home Mortgage Disclosure Act (HMDA), 2002,calculations by NCLR. For more information aboutlending disparities see: Austin Subprime Lending Patterns,1997-2000. Austin,TX: Consumer’s Union, 2002.

7. The State of the Nation’s Housing. Cambridge, MA:Joint Center For Housing Studies of HarvardUniversity, 2003.

8. See Discrimination in Metropolitan Housing Markets.Washington, DC: Department of Housing andUrban Development, December 2002;Turner,Margery Austin, Fred Freiberg, Erin Godfrey, CarlaHerbig, Diane K. Levy, and Robin R. Smith, AllOther Things Being Equal:A Paired Testing Study ofMortgage Lending Institutions. Washington, DC:Department of Housing and Urban Development,April 2002.

ENDNOTES

9. Carr, James H. and Lopa Kolluri, Predatory Lending:An Overview. Washington, DC: Fannie MaeFoundation, 2001; Automated Underwriting: MakingMortgage Lending Simpler and Fairer for America'sFamilies. McLean,VA: Freddie Mac, 1996.

10. Bradford, Calvin, Risk or Race? Washington, DC:Center for Community Change, 2003; and Separateand Unequal: Predatory Lending in America 2004.Washington, DC: ACORN, February 2004.

11. The Wealth of Hispanic Households, op. cit.

12 Saunders, Margot and Alys Cohen, "FederalRegulation of Consumer Credit:The Cause or theCure for Predatory Lending?" Cambridge, MA:Joint Center for Housing Studies, HarvardUniversity, March 2004.

13. "Homeownership at Any Cost? Not So Fast!"Washington, DC: National Multifamily HousingCouncil and National Apartment Association,January 2004.

14. For more information regarding foreclosures, see:Risky Business – An Econometric Analysis of theRelationship Between Subprime Lending andNeighborhood Foreclosures. Chicago, IL:WoodstockInstitute, March 2004; Gruenstein, Debbie andChristopher E. Herbert, Analyzing Trends inSubprime Originations and Foreclosures:A Case Studyof the Boston Metro Area. Cambridge, MA: AbtAssociates, September 2000; Gruenstein, Debbieand Christopher E. Herbert, Analyzing Trends inSubprime Originations and Foreclosures:A Case Studyof the Atlanta Metro Area, Cambridge, MA: AbtAssociates, February 2000; Families HUDAbandoned, Chicago, IL: National Training &Information Center, 2002; NCRC Fact Sheet onSubprime Lending and Foreclosures in Washington,DC during 2000,Washington, DC: NationalCommunity Reinvestment Coalition, 2000; Benfield,Nathan, Samantha Dwyer,Tonia Garnett, DavidHannah, and Amy Falcone, The SouthwestForeclosure Project. Chicago, IL:The Center forUrban Research and Learning, Loyola UniversityChicago, 2003;White, Alan M. and Cathy LesserMansfield, "Subprime Mortgage Foreclosures:Mounting Defaults Draining Homeownership,""Examining the Rising Foreclosure Rate," TheRegional Economy of Upstate New York, Spring 2003.

15. Chandrasekhar, Charu A., "Can New AmericansAchieve the American Dream? PromotingHomeownership in Immigrant Communities,"Harvard Civil Rights-Civil Liberties Law Review,Vol.39, No. 1,Winter 2004, pp. 169-216; andImmergluck, Dan, Hyper-segmentation and theExclusion in Financial Services in the U.S.:TheEffects on Low-Income and Minority Neighborhoods.Grand Rapids, MI: Grand Valley State University,July 23, 2003. See also: "Credit Scoring and FairMortgage Lending: Stepping up to Technology,"Communities and Banking, Fall 2002, see commentsby James Wheaton;Temkin, Kenneth and NoahSawyer, Analysis of Alternative Financial ServiceProviders. Washington, DC:The Fannie MaeFoundation, February 2004; and "OurNeighborhood Banks: High-Cost Loans for Low-Income Borrowers." Austin,TX: ConsumersUnion, Southwest Regional Office, 1998.

16. 2002-2003 HACR Corporate Governance Study.Washington, DC: Hispanic Association forCorporate Responsibility, 2003.

17. “Can New Americans Achieve the AmericanDream?”, op. cit.; "Millions of AmericansJeopardized by Inaccurate Credit Scores,"Consumer Federation of America, December 17,2002. See also, "Perspectives on Credit Scoring andFair Lending: A Five-Part Article Series,"Communities and Banking, Spring 2000.

18. NCLR calculations of a study by the Joint Center forHousing of Harvard University which determinedthat 26% of the homeownership gap was unable tobe explained by differences in age, income, or familycomposition. See State of America’s Housing: 2003.Cambridge, MA: Joint Center for Housing, HarvardUniversity, 2003; Figure 7.

19. Discrimination in Metropolitan Housing Markets, op. cit.

20. Singer, Audrey and Anna Paulson, Financial Accessfor Immigrants: Learning from Diverse Perspectives.Washington, DC:The Brookings Institution,October 2004.

21. “The State of the Nation’s Housing,” op. cit.

22. "Subprime Mortgage Lending and the CapitalMarkets," FRBSF Economic Letter, December 28,2001.

23. See HUD-Treasury Joint Report 2000.


25. Pullman-Weston, Liz, "Could You Handle anInterest-Only Loan?" MSN Money, available athttp://moneycentral.msn.com/content/Banking/Homefinancing/P73745.asp. See also: Harney,Kenneth, "Interest-Only Loans Are Potential TimeBombs," Washington Post, July 3, 2004.

26. "Lower-Income and Minority Consumers MostLikely to Prefer and Underestimate Risks ofAdjustable Rate Mortgages," Press Release,Consumer Federation of American,Washington,DC, July 26, 2004.

27. In Over Our Heads: Predatory Lending and Fraud inManufactured Housing. Austin,TX: ConsumersUnion, February 2002.


29. Mansfield, Cathy Lesser, "Consumer Choice andRisk in Society." Prepared for: 9th InternationalConsumer Law Conference, April 2003.

30. See Reaching to Market, Fannie Mae Foundation, formore information.

31. "New Research About Mortgage BrokersPublished," Press Release,Wholesale Access,Columbia, MD, August 6, 2003; and "Study ofMinority Lending Completed," Press Release,Wholesale Access, Columbia, MD, September 24,2002; and follow-up conversation with TomLaMalfa,Wholesale Access, Columbia, MD, October19, 2004.

32. “Can New Americans Achieve the AmericanDream?” op.cit.; Hyper-segmentation and theExclusion in Financial Services in the U.S., op. cit;and "Lenders and Third-Party Brokers: Perspectiveson Credit Scoring and Fair Mortgage Lending,"Communities and Banking,Winter 2002, seecomments by Kathleen Muller.

33. "Automated Underwriting: Making MortgageLending Simpler and Fairer for America’s Families."McLean,VA: Freddie Mac, September 1996; Car,James H. and Lopa Kolluri, Predatory Lending:AnOverview. Washington, DC:The Fannie MaeFoundation, 2001.

34. Credit, Capital and Communities:The Implications ofthe Changing Mortgage Banking Industry forCommunity-Based Organizations. Cambridge, MA:Joint Center for Housing, Harvard University, 2004.

35. Government agencies, advocates, and consumers useother laws to combat predatory lending as well,including Real Estate Settlement Procedures Act(RESPA), Federal Trade Commission Act (FTC Act),Fair Housing Act, and Equal Credit OpportunityAct.

36. See Facts for Consumers. Federal Trade Commission,Washington, DC athttp://www.ftc.gov/bcp/conline/pubs/homes/32mortgs.htm.

37. 65 Federal Register at 81441; Litan, Robert,"Unintended Consequences:The Risks of PrematureState Regulation of Predatory Lending."Washington, DC: American Bankers Association;Staten, Michael E. and Gregory Elliehausen, "TheImpact of the Federal Reserve Board ProposedRevisions to HOEPA on the Number andCharacteristics of HOEPA Loans." Washington,DC: Georgetown University, July 2001.

HISPANIC FAMILIES AND THE EARNEDINCOME TAX CREDIT (EITC) ISSUE BRIEFISSUE BRIEF NO. 1

FINANCIAL SERVICES AND HISPANIC AMERICANSISSUE BRIEF NO. 2

WELFARE REFORM, TANF CASELOADCHANGES, AND LATINOS: A PRELIMINARYASSESSMENTISSUE BRIEF NO. 3

THE LATINO VOTE IN THE 90’SISSUE BRIEF NO. 4

FINANCIAL INSECURITY AMID GROWINGWEALTH: WHY HEALTHIER SAVINGS ISESSENTIAL TO LATINO PROSPERITYISSUE BRIEF NO. 5

SAFE ROADS, SAFE COMMUNITIES:IMMIGRANTS AND STATE DRIVER'S LICENSEREQUIREMENTSISSUE BRIEF NO. 6

INCREASING HISPANIC HOMEOWNERSHIP:STRATEGIES FOR PROGRAMS AND PUBLIC POLICYISSUE BRIEF NO. 7

THE NO CHILD LEFT BEHIND ACT:IMPLICATIONS FOR LOCAL EDUCATORS ANDADVOCATES FOR LATINO STUDENTS,FAMILIES, AND COMMUNITIESISSUE BRIEF NO. 8

IMMIGRATION ENFORCEMENT BY LOCALPOLICE: THE IMPACT ON THE CIVIL RIGHTSOF LATINOSISSUE BRIEF NO. 9

COUNTERTERRORISM AND THE LATINOCOMMUNITY SINCE SEPTEMBER 11 ISSUE BRIEF NO. 10

PENSION COVERAGE: A MISSING STEPIN THE WEALTH-BUILDING LADDERFOR LATINOSISSUE BRIEF NO. 11

TANF IMPLEMENTATION INPUERTO RICO: A SUMMARY OFDATA ON LEAVERSISSUE BRIEF NO. 12

IMMIGRATION REFORM: COMPREHENSIVESOLUTIONS FOR COMPLEX PROBLEMSISSUE BRIEF NO. 13

ACHIEVING A HIGH-QUALITY PRESCHOOLTEACHER CORPS: A FOCUS ON CALIFORNIAISSUE BRIEF NO. 14

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