Statements And Speeches Of Henry S. Newport: Statement On Extension Of .
Statement onEXTENSION OF THE HOME MORTGAGE DISCLOSURE ACT OF 1975Presented toCommittee on Banking, Housing, and Urban AffairsUnited States SenateDigitized for FRASERhttp://fraser.stlouisfed.org/Federal Reserve Bank of St. Louisby1{Henry S. Newport, DirectorOffice of Compliance ProgramsFederal Deposit Insurance Corporation1,0:00 a.m.Tuesday, February 19, 19805302 Dirksen Senate Office Buildingj
Mr. Chairman, Members of the Committee:I appreciate the opportunity to discuss with you today theHome Mortgage Disclosure Act (HMDA) of 1975 and to set forth theFederal Deposit Insurance Corporation’s position on renewal andamendment of the Act.Chairman Sprague on several occasions has publicly supportedpermanent extension of the Act, and I am here today to reaffirmthat commitment.HMDA data are used extensively in Standard MetropolitanStatistical Areas by FDIC examiners in assessing the records ofbanks in meeting community credit needs under the CommunityReinvestment Act.We foresee that with improvement and refine ment in reporting techniques, HMDA data can be developed intoan even more significant contribution to our enforcement of CRAand other consumer laws.A two-year study by outside contractorshas confirmed our own observations that HMDA reporting accuracyneeds improvement.We plan to continue working with our insti tutions and helping to show them how to meet their reportingobligations under HMDA.The law requires each depository institution that has ahome or branch office in a Standard Metropolitan Statistical Area(SMSA) and assets of more than 10 million to compile and makepublicly available the number and total dollar amount of mortgageloans which it originated or purchased during its fiscal yearon properties within each SMSA in which it has an office.Digitized for FRASERhttp://fraser.stlouisfed.org/Federal Reserve Bank of St. Louis
-2-Regulated institutions are required to aggregate mortgageloan data on property located in SMSAs and to itemize such databy census tracts if possible, or by ZIP code.The data mustindicate the number and amount of conventional mortgage loans,federally-insured and guaranteed mortgage loans, home Improve ment loans and loans on properties In which the mortgagor didnot intend to reside at the time of the purchase.The statute requires a covered institution to maintain thisinformation for at least five years at its home office and atleast one branch office within any SMSA in which it has offices.If the Institution has branches in more than one SMSA, one branchwithin each SMSA is required to maintain detailed data by censustract only with respect to mortgage loan activity within that SMSAHMDATs objective is to make publicly availabledata on theamounts, types and locations of mortgage lending activity of regu lated depository institutions within SMSAs.USES OP HMDA DATAThe supervisory agencies are probably the most regular,systematic users of the data.At PDIC, use of HMDA statements isan integral part of our compliance examinations —operations thatare demanding an increasing proportion of examiner time andresources."*We expect to conduct 5,525 compliance examinations in1980, an increase of 900 from 1979, and we estimate that each suchexamination will average 70 hours, an Increase of 14 hours from1979.Digitized for FRASERhttp://fraser.stlouisfed.org/Federal Reserve Bank of St. Louis
-3Compliance with 15 consumer and civil rights laws arereviewed during these examinations, and HMDA disclosurestatements are an important resource in our review of threelaws which together constitute a significant part of thatworkload —the Community Reinvestment Act, which alone accountsfor about 15 percent of compliance examination time, the PairHousing Act and the Equal Credit Opportunity Act.An accurate and complete HMDA statement gives our examinersa convenient listing of mortgage loans aggregated by censustract and thus is particularly useful in examining institutionswith large mortgage volumes.Without such a listing, ourexaminers would have to compile similar data from individualloan records and then laboriously geocode them —that is,assign them to census tracts.A check with our regions last week showed that HMDA ismost heavily used by our examiners in the New York, Chicagoand other big-city regions.We find that HMDA is primarilyan urban tool.Our examiners use HMDA data in three ways in connectionwith CRA.The data are used, first, as one factor in assess ing the reasonableness of the community delineated by the bank.They are used, second, to assess the bank’s performance inmeeting community credit needs within its delineated community,including minority and lower-income neighborhoods in that area.And finally, the data are used in investigations connectedwith bank applications for a deposit facility.Digitized for FRASERhttp://fraser.stlouisfed.org/Federal Reserve Bank of St. Louis
Reviewing the reasonableness of banks’ community delinea tions is a continuing need.As banks merge, move or open newoffices, their communities may change and require a new reviewby our examiners.Bank performance under CRA is a continuing obligation, andour examiners must periodically review banks’ records to assesscompliance.Investigating for applications is also a continuing,function.Under the law, we must consider the records of banksin meeting community credit needs in connection with all applica tions —not just those that are protested.In 1980, we expectto make 1,800 investigations for applications, an increase of 250from 1979«In brief, there is a definite and continuing need for HMDAdata during our regular operations.As we continue to assistbanks in understanding their obligations and learning how tocompile HMDA data, we expect the accuracy of the data toimprove and our compliance programs to benefit accordingly.HMDA data are also used to some extent by community organ izations, public interest groups and local governments to promotegreater reinvestment in communities in SMSAs.Such use can cutboth ways: it can assist in documenting a charge of lack ofresponsiveness to community needs, or it can help to refuteunsubstantiated or inaccurate accusations against individualinstitutions.Digitized for FRASERhttp://fraser.stlouisfed.org/Federal Reserve Bank of St. Louis
-5To date, the FDIC has received 25 CP.A protests ofapplications by banks —22 involving new branches, one relat ing to a merger request, one associated with the relocationof a main office, and one involving the granting of depositinsurance to a new bank being formed by a bank holding company.In 23 of these cases, including five protests by other banksbased on competitive considerations, HMDA disclosure statementswere used by the protesting party to support its challenge tothe bank's application.The two CRA protests which did not relyon HMDA statements were also brought by other banks.HMDA STUDYLast month the FDIC and the Federal Home Loan Bank Boardsubmitted to your committee the report of our jointly sponsoredstudy on the Home Mortgage Disclosure Act.Part of the study, contracted to Resource Consultants,Inc., of Phoenix, Arizona, sought to show the correlation ofmortgage lending activity to the nature of various kinds ofneighborhoods.The remainder of the study, contracted to JRBAssociates, Inc., of McLean, Virginia, focused on the useful ness, accuracy and completeness of HMDA data for purposes ofimproving administration of the Act and the institutions'ability to comply.Resource Consultants, Inc., used U.S. census data toclassify kinds of neighborhoods within each of three SMSAs —Buffalo, Chicago and San Diego —Digitized for FRASERhttp://fraser.stlouisfed.org/Federal Reserve Bank of St. Louisaccording to location and
-6-age of housing stock and the Income and ethnic heritage ofresidents.Then RCI extracted mortgage lending statisticsfrom the HMDA disclosure reports submitted to the PDIC andFHLBB (for banks and savings and loan associations respectively)and matched these figures with the neighborhood categories.Both sources of data are imperfect:the U.S. censusmaterial because it dates from the 1970 decennial census andthe HMDA disclosure reports (which are from 1977) because theyreflect considerable error of content.RCI attempted to includein its review all 525 HMDA-covered institutions in the threeSMSAs but was able to obtain usable reports only for three quartersof these institutions.Prom the usable data, RCI constructed a table for each ofthe three SMSAs showing the number and amount of mortgage loansin 1977 for multifamily (five or more units) and one-to-fourfamily dwellings in various kinds of neighborhoods as theywere composed In 1970.Generally, the tables showed thatsignificant portions of the mortgage lending activity wentfor residences outside SMSAs and for lending within SMSAsto newer areas inhabited largely by non-minority, middleto-upper income borrowers.The JRB Associates portion of the study, in evaluatingthe extent of the error rate in HMDA reports, found that 35percent of institutions in the Chicago SMSA had an unaccept ably low accuracy record on geocoding (assigning loans to theproper census tract) and that half of the Institutions inDigitized for FRASERhttp://fraser.stlouisfed.org/Federal Reserve Bank of St. Louis
-7Buffalo and San Diego SMSAs and 80 percent of those in theChicago 3MSA had unacceptably low accuracy on aggregation(compiling the loan disclosure data by amount, type ofloan, type of property, census tract and other features).The JRB portion of the study was based on detailedreview of 44 institutions chosen at random, as follows:eight in the Buffalo SMSA, 10 in San Diego and 26 in Chicago.In the course of its work, JRB performed a series of componentstudies on such aspects of HMDA as "Compliance Analysis,""Completeness," "Double Counting," "Accuracy of DisclosureStatement Preparation," and other features.In its Compliance Analysis, undertaken to determine use fulness of HMDA data in determining compliance with the PairHousing Act, the Equal Credit Opportunity Act, and theCommunity Reinvestment Act, the contractor concluded:"The regulatory agencies currently use home mortgage dis closure data as an integral and essential part of theircompliance examinations, and investigations and proceduresfor use differ among various regions and districts."In its component study on "Cost of Compiling HomeMortgage Disclosure Statements," JRB Associates found thatcosts of compliance to institutions varied substantially in1977: an average 4,200 per institution in Buffalo, 2,800in San Diego and 1,400 in Chicago.The contractor reportedthat cost per loan incurred by the 44 institutions rangedfrom a low of 0.21 to a high of 13-73.Digitized for FRASERhttp://fraser.stlouisfed.org/Federal Reserve Bank of St. LouisJRB developed an
-average cost per loan for the8-Institutions of 1.42 andprojected an annual industry wide cost of 5-8 million.*AMENDMENTS TO THE ACTI believe that the Act should be made permanent.Thepublic disclosure purposes of the statute and the law’scontribution to our own compliance enforcement effortsjustify it.The functioning of the law can be reviewedperiodically for amendment as experience demonstrates theneed.Congressional oversight and our own review processwill provide information on which to judge the need forfuture changes in the law.The PDIC also supports amending the Act to requireall reporting institutions to adhere to a standardizedcalendar year reporting period.A standardized periodwould make the data for a given SMSA more meaningful forcomparison and data aggregation purposes and would increasetheir utility for public users and regulators.We recognize that the concept of improved public access ibility to mortgage lending data has certain merit; however,we believe that any proposal for the establishment and main tenance of centralized collection points nationwide requiresfurther exploration.Most of the 288 SMSAs in the United States do not havean office of a Federal regulatory agency or a governmentdepository library within their boundaries.Digitized for FRASERhttp://fraser.stlouisfed.org/Federal Reserve Bank of St. LouisEstablishing
-9centralized collection points in such areas would be a sizableand expensive undertaking.Additionally, we understand thatmost of the institutions we supervise have received relativelyfew requests from individuals for disclosure statements.Requests from community and consumer organizations seemedto pick up in 1979 as these groups began to make use of HMDAdata in connection with CRA activities.We would propose that any move toward centralized collec tion points be preceded by an experimental program which wouldseek to determine costs, benefits, administrative workload andother considerations involved in deploying a nationwide system.An experimental approach would help assess the need and determinethe costs to institutions and regulators of various methods ofimproving public availability of HMDA disclosure data.We believe our efforts should now be concentrated onimproving implementation of the Home Mortgage DisclosureAct within its present scope, and we would therefore recom mend no expansion of coverage either to institutions outsideSMSAs or to institutions with less than 10 million in assetsat this time.The primary value of HMDA statements is thatthey can be used in conjunction with other demographic data*based on census tracts to help determine the geographicdistribution of housing-related loans among neighborhoodsaccording to borrowers’ income level and ethnic heritage.Outside SMSAs, census tracts are virtually nonexistent.ZIP code areas are not so suitable for neighborhood-typeDigitized for FRASERhttp://fraser.stlouisfed.org/Federal Reserve Bank of St. Louis
-10-comparisons because ZIP codes in rural areas usually covermuch more territory and tend to be demographically lesshomogeneous than urban census tracts.We would not object to proposals to authorize theSecretary of Housing and Urban Development to release suchinformation as HUD has with respect to mortgage loansoriginated by lenders, such as mortgage bankers, who areapproved for mortgage insurance under Titles I and II ofthe National Housing Act and who are not subject to afinancial institution regulator.With regard to the establishment and definition ofSMSAs, we support an amendment to reflect the transfer ofstatistical functions from the Office of Management andBudget to the Department of Commerce.Finally, the FDIC recommends that HMDA1s coverage beextended to include insured branches of foreign banks.Thelaw is unclear on the applicability of HMDA to thesebranches, although it is our view that insured foreignbranches probably are subject to HMDA to the extent thatthey make federally-related mortgage loans.Insured branchesof foreign banks are subject to the Community ReinvestmentAct, the Truth-in-Lending Act, the Equal Credit OpportunityAct and other consumer laws and regulations.Clarificationof the applicability of HMDA would be appropriate.Digitized for FRASERhttp://fraser.stlouisfed.org/Federal Reserve Bank of St. Louis
-11-We at the FDIC remain committed to even more effectiveadministration of HMDA.Our objectives will remain unchangedto help lending institutions better understand and comply withthe requirements of the Act, to improve the efficiency andeffectiveness of our enforcement, and to make HMDA data moreuseful to banks, the public and the regulators.Digitized for FRASERhttp://fraser.stlouisfed.org/Federal Reserve Bank of St. Louis
loan records and then laboriously geocode them — that is, assign them to census tracts. A check with our regions last week showed that HMDA is most heavily used by our examiners in the New York, Chicago and other big-city regions. We find that HMDA is primarily an urban tool. Our examiners use HMDA data in three ways in connection with CRA.
James must have taken great care in preparing his speeches and memorizing them for delivery. I began my study of James's speeches and speechmaking by collecting as many extant speeches as possible and creating a master list. James's speeches were scattered throughout various primary and secondary sources.
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2.7 Statements 2.7.1 Expression Statements and Compound Statements Expression Statement: Similar to C, classical statements are expression statements. Compound Statement: A group of statements could be chained back to back, but only when expected by conditional statements if, while or for. Collectively we can refer those as statement lists.
Welcoming address. c. taster of ceremonies and after-dinner speeches (1. Nomination and acceptance speeches. 0. Tributes and eulogies. 2. Stages of speech preparation. a. State purpose of speech. b. Identify nature or occasion. c. Employ sound public speaking practices. 3. Guidelines for composition and delivery. a. Elements of a speech (1 .
