sponsored by: w. k. kellogg foundationkirwaninstitute.osu.edu/fairhousing_faircredit/... · 3:45...
TRANSCRIPT
KIRWAN INSTITUTE
FOR THE STUDY OF RACE AND ETHNICITY
THE OHIO STATE UNIVERSITY
Regional Convening Notes:Washington, D.C.
PRESENTED BY
NOVEMBER 18, 2009Sponsored by Kirwan Institute for the Study of Race and Ethnicity, Poverty & Race Research Action Council, National Community Reinvestment Coalition, National Fair Housing Alliance, Center for Responsible Lending, and the National Council of La Raza
FAIR HOUSING and FAIR CREDIT
THEFUTURE
OF
Sponsored by: W. K. KELLOGG FOUNDATION
The Kirwan Institute for the Study of Race and Ethnicity is a university-wide interdisciplinary research institute. We generate and support innovative analyses that improve understanding of the dynamics that underlie racial marginality and undermine full and fair democratic practices throughout Ohio, the United States, and the global community. Responsive to real-world needs, our work informs policies and practices that produce equitable changes in those dynamics.
The Future of Fair Credit: a Policy-Building Meeting National Council of La Raza, 1126 16th St. NW, Washington, DC
11:30-4:00 on Wednesday, November 18, 2009
Sponsored by the Kirwan Institute for the Study of Race and Ethnicity,
Poverty & Race Research Action Council, National Community Reinvestment Coalition, National Fair Housing Alliance, Center for Responsible Lending, and the National Council of La Raza
With Funding from the W.K. Kellogg Foundation
Agenda
11:30 Check-in / Lunch available 12:00 Welcome: john powell, Executive Director, Kirwan Institute Round-robin introductions 12:15 Session One: Promoting fair housing and fair credit in the real
estate credit markets
The Home Affordable Mortgage Program
The Neighborhood Stabilization Program (NSP 1 & 2)
Community Reinvestment Act
Affirmatively promoting sustainable credit in underserved communities
2:30 Session Two: Fair credit and fair banking in non-real estate
transactions
Regulation of credit card interest and fees
Bank overdraft fees
The remittance market
The Consumer Financial Protection Agency Act
Credit scoring and other issues
3:45 Wrap-up/Next Steps
ATTENDEES
Last First Organization Email
Aponte Graciela Wealth-Building Legislative Analyst, National Council
of La Raza, Washington, DC (202) 776-1578 [email protected]
Bowdler Janis La Raza
Carr James
Chief Operating Officer, National Community Reinvestment Coalition (NCRC), 727 15th Street, NW, Suite 900 | Washington, DC 20005, TEL: (202) 464-
2717 www.ncrc.org. Jim's assistant is Kathryn Lucas Smith at (202) 464-2726
[email protected]; [email protected]
Clark Ben NFHA [email protected]
Cohen Rick Freelance writer; former executive director of the National Committee for Responsive Philanthropy
(NCRP). [email protected]
Cohen Alys NCLC (202) 452-6252 x102 [email protected]
Del Rio Deyanira (NEDAP) Neighborhood Economic Development
Advocacy Project, 73 Spring St. #506, New York, NY 10012, Tel:, (212) 680-5100, Fax: (212) 680-5104
Donner Lisa Americans for Financial Reform [email protected]
Fitzpatrick Thomas J.
Thomas J. Fitzpatrick IV, Esq., Economist, Office of Policy Analysis, The Federal Reserve Bank of
Cleveland, P.O. Box 6387, Cleveland, OH 44101, Ph: 216.579.3087 Fax: 216.579.3050 {Home: 1541
Crossings Parkway, Westlake, OH 44145, 330.347.3566}
[email protected]; [email protected]
Fredrickson Steve
Advocacy Coordinator, Northwest Justice Project, 401 Second Avenue South, Suite 407, Seattle, WA 98104,
206.464.1519 ext. 248, 888.201.1012, Fax: 206.903.0526
Goldberg Debby NFHA [email protected]
Goldstein Ira
The Reinvestment Fund |718 Arch Street, Suite 300 North | Philadelphia, PA 19106 | [Assistant: Morgan Johnson, Associate, Communications and Investor
Development; p: 215.574.5810]
[email protected]; [email protected]
Halperin Eric Center for Responsible Lending (DC), 202-349-1859 [email protected]
Harris Mark Kirwan Institute
Hill Lauren PRRAC [email protected]
Jones-De Weever
Avis NCNW [email protected]
King Uriah Center for Responsible Lending [email protected]
Leigh Wilhelmina Joint Center for Political and Economic Studies [email protected]
Leonova Sofya
LoVoi Annette Appleseed [email protected]
Magnuson Benet Appleseed [email protected]
Ollinger Jillian Kirwan Institute
Peterson Chris
Christopher L. Peterson, Professor of Law, University of Utah, S.J. Quinney College of Law, 332 South 1400 East, Room 101, Salt Lake City, Utah 84112, (801)581-
6656
powell john Kirwan Institute
Randhara Rob Leadership Conference on Civil Rights [email protected]
Rice Lisa NFHA [email protected];
Rich Joe Lawyers Committee [email protected]
Rogers Christy Kirwan Institute
Rose Kalima Policy Link [email protected]
Shapiro Tom
Director, Institute on Assets and Social Policy Pokross Professor of Law and Social Policy The Heller School
for Social Policy and Management Brandeis University, Office: 781.736.4671; Fax: 781.736.3851
Stevens Stacey
Community Organizer, Michigan Roundtable for Diversity and Inclusion, 525 New Center One, 3031
West Grand Boulevard, Detroit, MI 48202-3025; Cell: (248)331-7036
Swesnik DeeDee
Deidre Swesnik, Director of Public Policy and Communications, National Fair Housing Alliance, 1101
Vermont Avenue, NW; Suite 710, Washington, DC 20005. Phone (202) 898-1661 x131; fax (202) 371-
9744
Tegeler Phil Philip Tegeler, Poverty & Race Research Action
Council, General: (202) 360-3906; Phil direct 202-906-8024
Thomas Hannah IASP (Tom Shapiro's Doctoral Student) [email protected]
Willis Mark Mark A. Willis, Visiting Scholar, Ford Foundation, 212-573-5286. Former Executive Vice President and head
of Community Development, JP Morgan Chase. [email protected]
The Future of Fair Credit: A Policy-Building Meeting National Council of La Raza – Raul Yzaguirre Building
November 18, 2009 In attendance: Graciela Aponte, National Council of La Raza Janis Bowdler, National Council of La Raza James Carr, COO, National Community Reinvestment Coalition (NCRC) Ben Clark, National Fair Housing Alliance (NFHA) Rick Cohen, Freelance writer; former executive director of the National Committee for Responsive Philanthropy (NCRP). Alys Cohen, National Consumer Law Center (NCLC) Deyanira Del Rio, Neighborhood Economic Development Advocacy Project (NEDAP) Lisa Donner, Americans for Financial Reform Thomas J. Fitzpatrick IV, Esq., The Federal Reserve Bank of Cleveland Steve Fredrickson, Northwest Justice Project Debby Goldberg, NFHA Ira Goldstein, The Reinvestment Fund Eric Halperin, Center for Responsible Lending (DC) Mark Harris, Kirwan Institute for the Study of Race and Ethnicity Lauren Hill, Poverty and Race Research Action Council (PRRAC) Avis Jones-De Weever, National Council of Negro Women (NCNW) Uriah King, Center for Responsible Lending (Durham, NC) Wilhelmina Leigh, Joint Center for Political and Economic Studies Sofya Leonova, CFED Annette LoVoi, Appleseed Benet Magnuson, Appleseed Jillian Ollinger, Kirwan Institute for the Study of Race and Ethnicity Christopher L. Peterson, University of Utah, S.J. Quinney College of Law john powell, Kirwan Institute for the Study of Race and Ethnicity Rob Randhava, Leadership Conference on Civil Rights Lisa Rice, NFHA Joe Rich, Lawyers Committee for Civil Rights Christy Rogers, Kirwan Institute for the Study of Race and Ethnicity Kalima Rose, Policy Link Tom Shapiro, Institute on Assets and Social Policy (IASP) Stacey Stevens, Michigan Roundtable for Diversity and Inclusion Deidre Swesnik, NFHA Philip Tegeler, PRRAC Hannah Thomas, IASP Mark A. Willis, Visiting Scholar, Ford Foundation
Introductory Remarks – john powell, Kirwan Institute for the Study of Race and Ethnicity Framing issues:
1. The importance of race and place: At previous Kirwan conference on the sub-prime crisis, the conclusion was that the discussion needs to be broadened beyond foreclosure to credit markets. We have segregated dual housing and credit markets with the same roots and dynamics.
2. Evolution of markets: Laws put into place 20-30 years ago don’t deal with global changes, and agencies are behind the curve. Global and unregulated capital is coming into markets that were racialized and segregated by place.
We have had credit available on unreasonable terms – the conditions were a problems waiting to explode and they did. This project is working to get a handle on the dual credit market, both inside the United States and outside of it. What does this mean going forward? We have to take the lessons learned to their logical conclusions.
1. The Community Reinvestment Act (CRA) is too narrow in terms of its market share and it waits until something happens. It assumes banking has a physical location, instead of being “cyber” or global.
2. We need to focus at the micro-, macro-, and meso-levels. The micro-level is well-covered. We are less focused at the macro-level. The bad news is that we haven’t re-set the credit market even a year after the crisis, bailout, and recovery act, and many of us are frustrated. The good news is that gives us a chance to be deliberate about what we do. We can re-set the global market.
3. Social justice and racial justice groups normally don’t work on that level: we need to think about how the local is connected to the global. What does it mean when 20% of mortgages in Cleveland are held in China? In Minnesota they found that not even banks could find who held a mortgage, and that spoke to the complexity of our modern market.
4. A quote from “Sustainable Advocacy for Fair Credit and Fair Banking” (Pastor, Ortiz, Carter), a piece commissioned for this project: “Our point is simple. While we do need a new policy package, such advocacy also needs to be embedded in a broader social movement for financial justice. The focus should not simply be on foreclosure relief, but on a new financial frame that has at its heart the restoration of opportunity for all.” The agenda must be affirmative about how we structure a credit market where individuals, communities, and places have fair access to credit.
Home Affordable Mortgage Program (HAMP) Summary – Deirdre Swesnik, NFHA
The dual mission of the Fair Housing Act is to eliminate discrimination and promote integration. Any federal funding used for affordable housing must “affirmatively further fair housing” (AFFH). This applies to all agencies and grant recipients.
HAMP is a $50 billion program under TARP that ends in 2012. TARP is the largest program to address the economic crisis and since it was supposed to encourage banks to lend again, it theoretically falls under the AFFH mandate. HAMP unambiguously falls under this mandate.
Any attempt to ease the recession and crisis must address root issues of segregation and discrimination.
None of the current programs is helping families that are hit by the unemployment crisis, which will cause the next wave of foreclosures. In 2010, another 7 million foreclosures are expected, and the biggest wave of foreclosures for Latinos will be that year.
Enforcing AFFH mandate on financial institutions o Make sure the industry is putting out responsible, sustainable loans that allow people
housing choice; o Sponsor non-discriminatory home lending practices and other types of community
development.
Treasury should be analyzing its data for disparate impact o Actively promote healthy neighborhoods, including the way grantees and recipients
of funds can AFFH; o Allocate funds to community groups experienced with connecting people to housing
and economic opportunities.
If data shows that HAMP is disproportionately benefitting white homeowners, what can be done?
o For people still in the process in 2012, there may be remedies available. o For those who have gone through the process, the question is much more complex
(forensic accounting, etc.) Key Policy Objectives and Principles
NFHA wants to make sure that fair lending data is gathered as part of the HAMP process. o They got HUD involved to force Treasury to do so. o Treasury has come out with some short reports that contain aggregated data that
can’t be used for analysis. o Fair lending data will be at the servicer and individual loan level, which is a real
victory for advocates, but race data won’t be connected to servicers. o Fannie Mae is collecting the data as an agent of the Treasury. o Treasury hasn’t given a clear timeline for the release of data, although they have
suggested a March date that doesn’t satisfy advocates. Advocacy Opportunities
Reminding government of the importance of AFFH: constant demonstration, including legal action and research that shows direct links with law
Challenging individual TARP recipients who are neglecting responsibilities
Partnering with responsible recipients.
Can Freddie Mac penalize servicers who don’t comply with data requirements, for example by withholding incentive monies? They were originally on board with this but have backed off.
Resources
NFHA
Freddie Mac data on Home Price Decline Protection Program
Important source of data that has been neglected is real property databases held by county recorder offices: counties are required to report who owns real property. This is an important source because it tells us who owns what. Community organizers could change the way county recorder rules are written to gather more social info and insist that financiers
report ownership with recorder. This system predates the Constitution and needs to be preserved.
o This source of information is being undermined by Mortgage Electronic Recording Systems (MERS), which the real estate industry created to streamline trading. MERS is listed as the mortgagee regardless of who is servicing the mortgage and privatizes a formerly public function, reducing transparency. We should insist that titles be recorded at the county.
State of Research
Many are suffering from foreclosures without getting HAMP review – who are these people?
Who falls out between temporary and permanent modification?
How are credit swap derivatives affecting the modification process? Lenders are advising their clients not to agree to modifications because they affect their ability to collect on claims for indemnification.
Is anyone doing any research on the quality and sustainability of loan modifications? What’s on the horizon?
How many people participated in HUD’s strategic planning process? Their strategic plan for 2010-2016 is coming out next month. They are trying to change HUD from being the “weak sister” compared to Treasury. Ron Sims and Mercedes Marquez are the key people on this project.
GAO is conducting a review on the AFFH mandate. If GAO hasn’t contacted your organization for an interview, you should reach out to them to schedule a meeting.
Most loan modification happens outside of HAMP, so this is something of a dry run to show us what we want in the future. Maxine Waters is spearheading servicing reform in the House, Jack Reed in the Senate – and proper data has to be part of this effort.
Neighborhood Stabilization Program I & II (NSP1, NSP2) Summary – Ira Goldstein, The Reinvestment Fund
NSP1 disbursed funds through community development block grant (CDBG) program, but not NSP2. Congress did communities a favor by making the 2nd round more flexible than the first.
HUD’s fair housing program is not on the radar at all: in working with practitioners, Ira Goldstein has found few to none are familiar with fair housing beyond certification procedure – so programs are not designed with fair housing in mind. There is not even passing attention paid to a pro-integration agenda.
Congress and HUD tried to build out scores with an eye towards likelihood of foreclosure in census tracts and neighborhoods in NSP1. They were hampered by lack of data in this process and did better in NSP2.
In regional HUD offices the message was that funds had to go to neighborhoods with scores of 18 or above.
There is a strong, but not invariant, relationship between minority concentration and higher scores, which doesn’t sound problematic on its face; however, with NSP forcing long-term affordability requirements on these neighborhoods they may not be able to take advantage of the recovery of the market and economy.
Change of tenure is an important aspect of what’s happening to these communities: in Twin Cities, foreclosures have changed them from low- to moderate-income homeownership to 80% investor-owned communities where they are just slumlords. There needs to be more regulation on TARP and on the servicers who control NSP funds.
Relatively small amounts of NSP grants to cities means that they have to use funds to leverage other sources (public or private), or use money in very concentrated, targeted ways in affected neighborhoods (e.g., targeting “catalytic” blocks for redevelopment).
Key Policy Objectives and Principles
We need to identify the issues we need to focus on, not wait for the data. What can we do in the meantime?
Advocacy Opportunities
Making fair housing a more explicit obligation in any future funds.
Training planners on fair housing? Resources
LISC and Enterprise created National Community Stabilization Trust to pass REOs to CDCs. About 4-600 properties have been acquired nationwide, and they’re in the process of making arrangements with fund recipients. The process is difficult because cities have to compile lists and then set out bid processes.
State of Research
Create a “crisis database” so we can understand the system. Case studies would be available for advocates to cite in their advocacy efforts. We need a repository so we can get things that aren’t fully done, but close enough.
What is the fair housing approach to communities that have been totally destabilized? What’s on the horizon?
NSP3 o Budget problems may stall this. Unless they significantly rewrite how dollars are
distributed, may not have a significant impact. o Baltimore Thompson case: HUD told communities where they had to use monies, and
ended up affirmative furthering segregated housing.
LIHTC regulations coming up for comment on whether they fall under AFFH mandate. Community Reinvestment Act (CRA) Summary – Mark Willis, Ford Foundation; James Carr, NCRC
CRA is not achieving its full potential. Its biggest incentive is for mergers and acquisitions, but since banks are consolidating due to financial pressure (and are already relatively consolidated), this is less effective as a point of leverage.
The market has changed and is no longer really based on local banks serving communities.
We understand community development better in terms of mixed-income communities et al., but the regulations discourage that and other acts.
There is no mechanism to regularly update regulations – and almost all necessary reforms can be done through regulations.
Most important changes are that CDFI and community development lending should be given more prominence and grade inflation needs to be addressed (i.e., if 97% of banks get a satisfactory rating, are we really measuring anything effectively?).
You need one regulator instead of four – James Carr argues that this makes CFPA an ideal enforcer of CRA.
House Bill 1479 to modernize the CRA has 50 co-sponsors but little energy.
1995 regulations caused a pernicious focus on loan volume instead of quality. Banks would trade loans to increase volume, which doesn’t help communities at all. Lisa Rice stated that some financial companies found that during CRA exams regulators gave them a hard time for affirmative measures on originating and servicing loans that increased sustainability but reduced volume. Regulators have leeway to be more responsive to efforts like these, but do not have an incentive to affirmatively do so.
Key Policy Objectives and Principles
Update regulations to reflect current trends in community development.
Reward performance and focus on community development and CDFI lending.
Cover all types of financial institutions under CRA. State of Research
What sort of rules do you establish for online banks such as ING and Charles Schwab that don’t have an assessment area?
Affirmatively promoting sustainable credit in underserved communities Summary – Deyanira Del Rio, NEDAP
Originally there was a push not to curb subprime lending because there was a concern that this would dry up credit for underserved communities. So now we have to develop policies that are remedial to help people already aggrieved by unfair lending and create a landscape for moving forward. For example NEDAP in NYC originally was created under a CRA model to deal with redlining and access to services, but has seen its work shift towards trying to fend off predatory loans and financial services.
One huge issue is credit scores and reports that foreclosure and the debt-buying industries will have a disastrous impact on people’s future access to credit.
Another is that community development credit unions have been the only ones providing lines of credit in underserved communities and they are threatened by the foreclosure crisis because the larger credit unions that provide credit to them were invested in mortgage-backed securities and have had to scale back lending due to losses. They had been providing fixed interest loans and are being discouraged by regulators because of interest rate risk.
Regulation of credit card interest and fees Summary – Janis Bowdler, NCLR
Latino households seeing uptick in demand for emergency credit. Gaps between income and need; cost of credit is increasing or missing. Some key findings from group:
o Consensus on importance of building credit history, but many unsure of what this means or how to do it. Knew it was important but struggled when interacting with the credit market.
o Concern over getting credit when job is insecure. Immigrants take themselves out of the credit market because of job insecurity, so scared of debt
o Used cards for emergencies, but these were described as groceries/diapers. Especially acute for 18-25 yr olds w young families (1/3 of the participants in this age had families)
o Introductory cards with low limits led to borrowers getting multiple cards to cover emergency expenses; managing these quickly became an issue.
State of Research
What are the models for filling these gaps and extending a lifeline so they can recover financially rather than send them on a downward trajectory w debt?
What are ideas to plug the gap that families are facing as demand is increasing, credit is tightening?
Bank overdraft fees Summary – Eric Halperin, Center for Responsible Lending
Overdraft fees are a poster child example of why we need CFPA. Federal institutions clearly sided with the financial institutions not the public.
In 2004 80% of banks would’ve rejected insufficient fund transactions; now it’s a major profit center: $24B in fees, up 35% over the past 2 years.
$1.5B in Social Security checks goes to overdraft fees, and a minority of people are responsible for 70% of overdrafts.
Overdraft fees are equivalent to loans with 5-digit interest rates!
Victims of overdraft fees are more likely to be low-income and of color, despite overdraft fees originally being sold to regulators as a tool to assist high-income account holders who held most cash in stocks not checking accounts.
Overdraft fees are the leading cause for people being unbanked. Key Policy Objectives and Principles
New Federal Reserve rule requires customers to opt-in to overdraft fees instead of being automatically enrolled.
Remittance market Summary – Benet Magnuson and Annette LoVoi, Appleseed
Immigrants send $47B in remittances to family overseas, accounting for much income in recipient countries (e.g., 27% of Honduras’ GDP, 3% of Mexico’s).
The average remitter sends $300/month abroad, a significant sum for low-income people; these funds are overwhelmingly spent on basic needs.
A significant amount of funds are lost to fluid fees and exchange rates that are not well-explained (or deliberately made obscure) to remitters: 15-20% overall, but only about 7% in the US-Latin American corridor, where there has been a consistent push for more transparency.
o Texas passed a remittance disclosure bill on exchange rates and fees. o CFPA requires pre-transaction disclosure of exchange rate and fees.
Remittance transactions are segregated from the rest of the financial industry, even though this is the #1 interaction immigrants have with financial services. Only 3-10% of remittances go through banks, the rest dominated by two services.
In Texas, it was found that immigrant laborers were being targeted on paydays because they were unbanked and carried large sums of cash.
Advocacy Opportunities
S139 of CFPA bill introduced by Frank in House, Dodd in Senate contains the aforementioned amendment.
State of Research
How can we use remittances for asset-building and bringing people into the financial market?
Consumer Financial Protection Agency Summary – James Carr, NCRC
Very bold proposal to consolidate enforcement of 17 consumer protection laws
When it went to the House, it changed dramatically: o House bill excludes 8000 of 8200 banks in country because of concentration of
deposits. This could create loopholes where banks spin off small subsidiaries exempt from regulation and foster a two-tier structure that could encourage risky behavior.
o Prohibited agency from requiring banks to offer “plain vanilla” products. o Preemption is a major issue: the decision whether to allow preemption of state
consumer protection laws was left with OCC and OTS, which performed miserably in the subprime crisis, but this authority has been significantly weakened.
o Watered down advisory board.
Experts of Color Network offered several proposals to improve law: o Collection of detailed info on consumer complaints by age, gender, race/ethnicity,
location. o Requirement of diverse representation on advisory board o Office of Financial Education to educate financial institutions on how to better serve
marginalized communities. Key Policy Objectives and Principles
Strengthening House bill
Keeping Senate bill as strong as possible Advocacy Opportunities
Bill still hasn’t been reported out of committee in Senate or passed by the full House. What’s on the horizon?
Floor vote on CFPA expected in House in mid-December.
Senate Banking Committee likely to take up bill around the same time. Credit scoring
Summary (no presenter)
The “father of securitization” spoke at an industry conference about “strategic default” and the fact that some barriers to this had been removed. His point was that a credit card company will rehabilitate you in a year and you could get an FHA loan the day after that. He mixed up issues of credit scoring and underwriting standards in making his point.
When Moody’s and Chase began to look at their portfolios, FICO scores were not very predictive; instead yields by premium, pre-payment penalties, and broker fees were much more predictive of the performance of loans.
What could be the cause of disproportionate low FICO scores in communities of color? o One suggestion is that the lower incomes and lack of wealth makes their credit
situations more precarious and vulnerable to default. o Another is that the elements used in credit scoring do not capture the economic
activities of low-income borrowers in which they are actually stable, such as utility and rent payments.
o Vantage incorporates some of these factors into an alternative credit score in order to capture 10 million more people who are new entrants into the credit market or infrequent credit card users. Because data is not coded by race, it’s unclear what the racial impact of this is. Some research suggests there is a correlation.
o If banks don’t adopt new models, it doesn’t matter how effective or race-neutral they are.
State of Research
NFHA has done some research on the credit scoring issue. Other issues
Financial crimes o We need to incarcerate more bankers, perhaps using RICO and racketeering statutes o More resources need to go into investigating financial crime. o Legislation is being introduced by Marcy Kaptur to put more resources into
investigating financial crimes. o There is also a newly developed coalition working specifically on identifying
fraudsters and bringing them to justice.
New Pecora Commission o Run by Phil Angelides and probing the causes of the economic crisis. o We should be focused on helping that commission and telling them what they need
to be focused on with regards to communities of color.
Other issues o CFPA exemption for auto dealers and other non-bank lenders needs to be removed. o Different legislation is moving along different timeframes – how can we best focus
our energy and attention to keep pace with the legislative issues that are moving now?
Focus on the issue of products: One way subprime was allowed to proliferate was the so-called good guys who had good products kind of removed themselves from the game in the midst of the subprime explosion. Why was Ameriquest the biggest lender in Cleveland and not First City, etc.? One nuanced way was to make your product box so small that you could legitimately exclude people from it in the name of safety and soundness, that you pushed
people out of that box, especially impacted immigrant communities. The standardized box needs to be there and needs to be big enough to accommodate communities.
What unites all elements of this agenda is the historic extraction of housing wealth from communities of color and ending the dual credit market affirmatively.
Cover DesignSamir Gambhir
Sr. GIS/Demographic Specialist
Craig RatchfordGIS/Demographic Assistant
KIRWAN INSTITUTE FOR THE STUDY OF RACE AND ETHNICITYTHE OHIO STATE UNIVERSITY433 MENDENHALL LABORATORY | 125 SOUTH OVAL MALL | COLUMBUS OH 43210Ph: 614.688.5429 | Fax: 614.688.5592Website: www.kirwaninstitute.org
For more information on Kirwan Institute, please contact Barbara Carter | [email protected] more information on this report, please contact Christy Rogers | [email protected]